INQ00001168 - Transcript (27/06/2024): Post Office Horizon IT Inquiry - Gareth Jenkins [WITN0046]

Evidence on official site

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The Post Office Horizon IT Inquiry

Thursday, 27th June 2024.

(9.45 am)

GARETH IDRIS JENKINS (continued)
Questioned by MR BEER (continued)

SIR WYN WILLIAMS: Morning, my colleague,

Ms Eliasson-Norris, can't be here in person today.

MR BEER: Thank you, sir.

>

prop

prproe

Good morning Mr Jenkins.
Good morning.
Can we start with the Seema Misra case study, please.
Just for reference, no need to display it, you set out
in your third witness statement, paragraphs 326 to 521,
your involvement in Seema Misra's case. Just by way of
reference, before you ever became involved in it, back
on 1 April 2008, Mr Singh, Jarnail Singh, had advised
there was sufficient evidence for a prosecution of
Mrs Misra. The reference for that, again, no need to be
displayed, is POL00049658.

Can I turn, please, to what might be your first
involvement or the genesis of your first involvement in
the case.

Okay.
FUJ00152866, please. If we can turn to page 6, please.
An email -- if we just scroll down, and a bit more. We

can't in fact see it. We'll have to scroll up to see it
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Okay?
Yes.
You're not included at this stage?
Correct.
If we go to page 3, please. If we just scroll up a bit
more -- thank you -- you'll see an email from Penny
Thomas to David Hinde. Do you remember David Hinde?
Oh, yes, he was one of the Programme Managers within the
Post Office Account and I worked quite closely with him
on a number of occasions.
So he was a Post Office --
No, he was a Fujitsu person.
Working on the POA?
Yes.
Thank you:
"David
"We had a conversation last week and you advised me
I should no longer ask Gareth to support our prosecution
... activity. I now have a request from [the Post
Office], which they would like addressed prior to
Christmas, and I need an expert to respond. Could you
help me to identify a suitable candidate?”
Then she attaches the expert's report.
Do you know anything about why you were not to be

approached, "We should no longer ask Gareth to support
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was sent from Mr Dunks. There. Can you see an email of
26 November 2009 from Mr Dunks to Jane Owen?

I think it's copied to Mr Dunks, isn't it from Jon

Longman?

You're quite right. Mr Longman to Ms Owen, copied to

Mr Dunks. You're quite right. If we scroll down it

says:

"I attach a report from the defence expert where he
has highlighted a number of problems with the Horizon
system. Our barrister, Warwick Tatford, has asked that
the problems with Horizon that he has raised in his
report are replied to in a witness statement form.
I presume that an employee of Fujitsu would have to
produce the witness statement ...

"In addition to this the defence have also requested
some information", which I'm not going to read.

Okay?

Okay.

If we go to page 5, please, at the top of the page. We
can see that Jane Owen sends that to Penny Thomas in
Fujitsu on 1 December:

"This is the email and attachments that we chatted
about. Please let me know if there is anything else you
need from me and if this kind of request needs to be

raised in a more official way."
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our prosecution" --

Possibly because I was quite business working on Horizon
Online at the time.

All right so it was about capacity, was it, as far as

you knew?

As far as I know, yes.

Then if we scroll up, please, at page 2. Mr Hinde

replies:

"Penny

"We have not identified anyone else who can take
this on at present so this will need to be handled by
Gareth."

Then scroll up. An email that we've looked at
before, I think we looked at it yesterday or the day
before, which is really about generally what you do to
support prosecution activity.

Yes.

So this chain doesn't actually -- even though there's

a request for the provision of an expert report in the

form of a witness statement, or an expert's reply to the

expert's report in the form of a witness statement --

ask you directly to perform that function, does it, when

it's sent on to you?

No not at this stage, no.

Can you help us, do you know why you're replying to this
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chain with this series of questions and answers?

The questions are from this Dave Jennings and the
answers are mine. So, again, I'm interspersing things
so I think the darker font is his questions and the

lighter font, more to the left, are my responses, is how
I'm interpreting that.

My question was more: do you know why you're saying all
this in answer to the series of emails below, which is
about, "Can we have a reply from somebody within Fujitsu
in the form of a witness statement", to the defence
expert report in the Seema Misra case?

I don't have a clear answer. I'm assuming, from what
this is saying, that Dave Jennings wanted to have some
sort of background as to the sort of things I'd done in
the past but I'm -- I'm guessing from the sort of
questions he's asking.

Can you recall when you were first asked to provide
assistance to the Post Office in relation to Mrs Misra's
case?

I think it was from -- as a consequence of this email.
There may be -- I think there may be a later one, either
on this chain or a separate chain, that actually passes
me the report to have a look at but it was certainly
some time in December 2009.

You tell us in your witness statement that you do not
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something you mentioned previously in your oral

evidence -- as "fairly chaotic".

Yes, I would agree with that.

What did you mean by your reference to the management by
the Post Office of Mrs Misra's case as being "fairly
chaotic"?

I think this came a bit more later. There were a number

of cases where I would respond to an email and then get
asked exactly the same question again by the same person
and, therefore, ended up sort of saying, "Well, I told

you this yesterday, here's the answer I gave you when

you asked me the question before". And there are number
of examples of that in the exchanges I had with Jarnail
Singh.

Other than receiving repeated requests for the same

thing, was there anything else that made their
management of the case chaotic or fairly chaotic?

I wasn't being asked very clear questions. I was having

to make all sorts of assumptions of what they wanted me
to do, I did try and set out what I thought I was being

asked to do, but it was very much a case of I definitely
didn't have clear instructions as to "Please do exactly

this", let alone formal instructions, as I now realise

I should have had.

Did you realise at the time that you weren't receiving
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think you received any kind of briefing or explanation
about the background to Mrs Misra's case; is that right?
At that stage, I don't believe I did.

And that you weren't in fact provided with Professor
McLachlan's first interim technical report?

I don't believe I've ever seen that.

Without a briefing or explanation about the background
to Mrs Misra's case or the prosecution case against her
and without a copy of Professor McLachlan's first
interim report, how did that impact on your ability to
respond to the Post Office's requests?

I saw the Post Office's requests as being purely to
comment on the second report that I was provided with,
either at this time or shortly afterwards.

So, again, performing a narrow function?

Yes, because that's what I thought I was being asked to
do.

Did you ever think, "Hold on, I don't know anything
about this case"?

No, I was just being asked "Please can you comment on
this report", so I commented on the report in the way

I normally did by interspersing my comments within the
electronic version of the report.

You also, in your witness statement, describe the Post

Office's management of Seema Misra's case -- this is
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clear instructions?
I just thought that was the way things worked. So --
That's a slightly different point. Did you realise at
the time that you were not receiving clear instructions?
No, because I didn't know that I should have been.
Irrespective of the formality of a letter of
instruction, which you say you now realise that you
ought to have received, did you at the time realise that
the requests being made of you were unclear?
They were certainly unclear and I did the best I could
to interpret what I thought I was being asked. And
sometimes I did actually seek clarification to say,
“I think what you mean is this, isn't it?"
You also describe in your witness statement that:

"At times I struggled to deal with the Post Office's
demands."

Is that because you were heavily involved in the
rollout of Horizon Online?
Yes. I mean, there was clearly a scheduling problem
I had, which I think I managed to fulfil, but, yes.
Did you feel that there was pressure applied to you by
the Post Office to provide evidence in Mrs Misra's case
that conformed to the Post Office's expectations?
Yes, they clearly wanted me to say that everything was

perfect and I don't think I actually said that.
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In what way did that pressure manifest itself?
I kept on getting emails -- it was in spurts, it wasn't

solid throughout the time, but I kept on being asked
please can I do this, please can I do that, and I kept
getting occasional phone calls as well.

Did you feel uncomfortable about the pressure you were
being placed -- that was being placed upon you?
Uncomfortable -- I just got on with things, which is

what -- my normal reaction to try and handle things,
rather than worry about things.

So you felt uncomfortable but got on with it?

Yes.

Did you raise the fact that you felt uncomfortable with
any of your managers?

I -- yes, for example, there was the discussion with
David Jones at the beginning of February that we had and
that was part of my uncomfortableness, if you like, and
there were occasions when I'd raised with my line
manager, "Look, I'm being asked to do all this but you
want me to do all my day job stuff, how does this all

tie together?"

I was not thinking so much about the capacity issue but
rather the "we want evidence", the substance of the
evidence.

In your words, I think you said to say that the
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As I said already, by this time, you'd been asked to
provide a witness statement?
Yes.
“When Gareth completes his statement could he also
mention whether there are any known problems with the
Horizon system that Fujitsu are aware of. If none could
this be clarified in the statement."

This is an email from the Post Office to three of
you in Fujitsu, correct?
Yes.
You're getting the request directly here from the
lawyer, the prosecution lawyer, Jarnail Singh?
Yes.
Just looking at of the request in number 3, would you
agree that that's a broad request?
Yes, itis.
It does not ask whether there were known problems which
affected Seema Misra’s branch at West Byfleet, does it?
No, not at that stage.
It doesn't ask you whether you personally know of
problems within Horizon; it asks whether you can say
whether Fujitsu knows of problems with Horizon, doesn't
it?
Yes, and I responded to that saying that -- identifying

a problem that I was aware of that would need to be
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system was all okay or all alright, and you felt
uncomfortable about doing that.
I think that was the reason why we got in touch with
David Jones, for example, at the beginning of February.
Other than that, did you escalate it in any way within
your organisation?
I can't remember properly. I think there may be some
examples within the emails but I can't remember off the
top of my head exactly which ones they were.
Okay. Can we look, please, at FUJ00122794.

By this time, this is February 2010, for context,
you had received, by this time, a request to produce
a witness statement and, if we go down, please, to
page 2 -- thank you -- we'll see an email from Jarnail
Singh, in fact it's from his secretary or PA on his
behalf, of 5 February at 3.50 to Mr Jones, and copied to
you and Penny Thomas.
Yes.
The email body is addressed to you:

"Dear David and Penny..."

He says:

"On first glance points 2-4 have not been answered
and I reproduce below."

Item 3:

"When Gareth completes his statement ..."
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checked out.

I'm going to come to your answers in a moment. I'm just
looking at what the request means at the moment.

I think you've agreed that it was broad. It's not

limited to Seema Misra's branch and it's not limited to
your own knowledge; it's Fujitsu's knowledge?

I see now that is what it said. I'm not sure that

I would have analysed it in that way at the time.

Why might you not have analysed it or why -- put aside
analysis of it: why might you not have read it that way
at the time?

I thought that all I could be really commenting on was
what was happening in the particular branch when we
actually had some data to look at for the specific
branch.

That plainly doesn't say that though, does it? It

doesn't ask that?

I realise that now.

We now know that request originated from the prosecution
barrister, Warwick Tatford. If we go up, please, to the
bottom of page 1, if we just look at your reply, 16.06.
Can you see that you replied to David Jones and Penny
Thomas?

Yes.

So you have cut the Post Office person, Jarnail Singh,
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out of the chain?
Yes.
Why did you cut Jarnail Singh out of the chain?
I wanted advice from David Jones in particular as to
exactly what I should be saying, particularly since
I was reluctant to make a clear statement and I was
aware of this problem so I wanted guidance as to what
I should be saying about it.
So you were really looking for a steer from Fujitsu
Legal on how to deal with this request?
Yes.
You say:

"Brief responses as [below], but not sure that
I should put them in a witness statement ..."
Again, I was seeking guidance.
Just help us with why you weren't sure you should put
them in a witness statement?
I was just trying to get some clarity as to whether I --
exactly what I should be saying. I was looking for
guidance particularly from David Jones as to what
I should be saying.
But why were you not sure you should put them in
a witness statement?
I just didn't know. I'd not really had such much to do

with this sort of thing, so I was just seeking some sort
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statement. I am aware of one problem where transactions
have been lost in particular circumstances due to

locking issues. When this happens we have events in the
eventing logs to indicate that there was an issue and
whenever we provide transaction logs to [the Post

Office] we check for any such events. In the case of
West Byfleet we have not provided any transaction logs
and so have not made these checks."

Would you agree that the implication of that was
that you may be able to respond to question 3 when you
had the ARQ data?

Yes. I think that's basically what I was trying to say
there.

Now, you refer to one problem in that answer: you were
referring to the Callendar Square bug, right?

No, I was referring to the Craigpark issue. I wasn't
aware of the Callendar Square issue at that time.
Could be the Craigpark be checked for by reference to
ARQ data?

It could be -- no, but it could be checked in reference
to the NT event logs.

Is that what you're referring to where you say
“transaction logs"?

Well, the transaction logs I'm referring is to ARQ data,

but I was saying that, when we provide transaction logs,
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of guidance.
But what were the reasons that would prevent you from
putting them in a witness statement?

I didn't know. I was just ignorant.

What, that, "Is this something that we do, we provide
witness statements?" I mean, you were providing one
already?

Yeah, yeah. I was just -- I was just asking the

question.

Wasn't it more about the content; you were worried about
putting the content in a witness statement?

I was just looking for guidance as to what I should be
saying.

Weren't you really not focusing on "Should I provide

a witness statement or not", you were saying by that,

"I'm not really sure that I should put this content in

a witness statement"?

I don't know.

Look at number 3. You'll remember this is the answer to
the question:

"Could he also mention whether there are any known
problems with the Horizon system that Fujitsu are aware
of? If none, could this be clarified in the statement?"

You say:

"This is where I'm reluctant to make a clear
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we also check against the corresponding NT events as
part of that process.

That's what you refer to when you say "eventing"?
Correct.

So that means NT event logs? So the third line --

Yes, yes.

At this time, did you know of other problems which would
require more than the ARQ data to investigate whether
they were in play at this branch?

I wasn't aware of any other such problems.

What about accounting discrepancies due to hardware
failures?

I thought that those would have been picked up as --
would have been picked up at the time because they would
have been fairly obvious at the time when there were
such hardware failures.

You'd need to look, wouldn't you? Whether they'd been
picked up at the time or not was the very issue that
you'd be looking for, wouldn't you?

I'm not sure whether I was thinking of that at the time.
This was --

You agree now?

This was this issue that I thought about, so therefore

I raised this and asked for guidance as to what should

be done about it.
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What about bad blocks; do you remember what they were?
I don't think bad blocks actually caused problems. What
that effectively meant was that the system came to

a halt and then needed to be restarted to sort things
out.

Would that be shown on an NT event log?

Yes.

You'd need the Horizon Helpdesk records to look for
calls suggesting that hardware had been at fault,
wouldn't you?

I was aware that someone else had done an analysis of
Helpdesk calls or --

Were you aware --

-- maybe not at this point but I became aware of that,
as time went on.

At this point, in order to answer that question, even if

it was restricted in your mind to West Byfleet, you
would need to look at the Horizon Helpdesk records to
look for calls made by Mrs Misra or other people at
branch level, for example suggesting hardware issues,
wouldn't you?

I wasn't aware that I would have needed to have done
that because, as I say, I thought that was something
that someone else would be covering.

Why did you think that it would be something that
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I did so at some point.

You would need to look at KELs to see which problems
were in play for at least the period when Mrs Misra was
alleged to have stolen money from the West Byfleet
branch, wouldn't you?

I'm not sure I would have thought of looking at KELs
because my normal approaches was to look at the PEAKs
and PinICLs which are sat behind them, rather than the
actual KELs.

But you agree that, if you were to answer the question
completely of whether there were known problems with
Horizon that Fujitsu are aware of, you would at least
have to look at any PinlICLs or PEAKs to see whether any
known problems were in play for at least the period when
Mrs Misra was alleged to have stolen money from West
Byfleet?

I wasn't actually answering the question at this point;

I was just saying that I didn't think I could answer the
question --

I'm asking you: if you were to answer it accurately and
completely, that's what you would need to do?

Possibly. As I say, I don't think I ever did actually
answer that question, as such.

We know that you didn't. I'm looking at what you would

need to do in order to have done it properly,
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somebody else would be covering?
Because my expertise was in the software rather than the
hardware.

Wouldn't you need the full message store to look for
unusual restarts?

You could see those, you should be able to see those
from the ARQ data, I think.

You think or you know?

I'm trying to remember now. It's a long time ago since

I looked thorough the detailed ARQ data.

If you were going to give a complete answer to the
question whether there were any known problems with the
Horizon system that Fujitsu are aware of, you would need
to investigate PinICLs and PEAKs, wouldn't you?

Yes, but, as I say, at this stage, I was just saying

I couldn't make a clear statement and I wasn't thinking
about what else I would need to do. I was just saying,
"This is my immediate response to the question I've been
asked".

But do you agree that, if you were going to give

a complete answer to the question of whether there were
any known problems with the Horizon system that Fujitsu
are aware of, you would need to look at PinICLs and
PEAKs?

There would have been some need to do that and I believe
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accurately, completely. The implication of the answer
that you gave, namely "I could answer the question if

I was given event logs and ARQ data”, that wasn't right,
was it? You needed much more information to answer it
accurately and completely?

I had not thought of that at the time.

Do you agree now?

Possibly. I don't know.

Why don't you know?

Yeah, I probably would have had to do some further
research.

Thank you.

Now, I think you and your colleagues within Fujitsu
made a number of suggestions to the Post Office in the
following days to obtain relevant transaction data in
relation to Mrs Misra's tenure at the West Byfleet
branch, didn't you?

Yes.

Can we look at those repeated requests to the Post
Office. FUJ00122713, and page 1. Thank you.

5 February, 2.46; Mr Jones, the lawyer, to Mr Singh, the
lawyer; you and Penny Thomas copied in. It's just in
relation to the part -- if we scroll down, please, the
penultimate paragraph, Mr Jones says to the Post Office:

"One concern is that [the Post Office] have not
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apparently requested transaction data for West Byfleet
for the period and transactions in question. This would
normally be provided in previous cases and would include
Fujitsu extracting log files from the system to enable

us to provide details of transactions. Surprisingly

this has not been requested in this case. Perhaps you
would consider the need for this."

That's a request or sentiment I think you would
agree with?

Oh, definitely.
Thank you.

If we look, please, at FUJ00152930. Same day at
5.10; same distribution, Jones to Singh; you and Penny
Thomas copied in. If we scroll down, please -- thank
you -- he effectively passes your reply, that we've just
looked at, into numbered paragraph 3 --

Yes.
-- and, in the last part of the paragraph, he says to
Mr Singh:

"In the case of West Byfleet we have not been asked
to provide any transaction logs and so have not made
these checks."

Yes.
Correct? So, essentially, making a similar demand or

request or point to the Post Office?
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relating to this branch. The logs would show any
equipment failures and replacement which might possibly
relate to lost transactions."

So, again, you're making the point, this time a bit
more formally in a witness statement, that there has
been no request for any data relating to the branch.
Correct.

Was that unusual?

My understanding was that it was normal when there was
a prosecution to request the data to have the basis of
what was alleged to have taken place in the branch, but

I wasn't very close to things but I thought that was the
whole point of the prosecution support team within the
Fujitsu, was to provide that data in support of
prosecutions. And I assumed it was done in all cases
but I didn't really know.

And normal to obtain the data relating to the period
covered by the charge?

Whatever period Post Office requested. As I say,

I wasn't that close to know exactly what period we were
talking about.

Did you know whether they normally requested the period
covered by the charge?

No, I didn’t know that.

You didn't know one way or the other?
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Yes.

Agreed?

Agreed.

So twice in one day, essentially?

Yes.

Then can we look at POL00093961, page 19, please. This
is a draft witness statement you provided on 8 February
2010 in Seema Misra's case. If we just go forwards for
present purposes to page 21. We can see in the top
paragraph, I think you're performing the familiar task

of cutting into a document of yours what somebody else
says, here it's Professor McLachlan; is that right?

Yes, I think this is his third report, I believe?

Yes.

And so the italics is my response to the normal font of
his actual statements in the report --

So in his report he'd said:

"The implication is that EPOSS transactions can be
lost due to equipment failures. Without access to the
sub post office data records and the intermediate data
records in the end-to-end process it will not be
possible to identify the extent to which this may
explain the accounting discrepancies.”

You say in your draft witness statement:

"No request has been made to Fujitsu for any data
22

Correct, yes.

Would it make sense to you that they would request data
for the period covered by the charge?

Yes, I can understand that.

Can we go forwards, please, in fact on the same day.
FUJ00083722. If we scroll down, please, to the top of
page 2, we see a chain there beginning -- I'm not going
to go through it all -- from Anne Chambers to others
about Callendar Square in 2006; do you see that?

Yes, I see that.

If we just go back up to the bottom of page 1, we see on
8 February, so the same date we were looking at that
draft witness statement, Anne Chambers essentially
forwarding you that chain; is that right?

Yes, that's right.

Do you remember the circumstances in which she forwarded
you that chain?

I think I'd asked her to do so because one of the
requests I had -- and if we go back to the witness
statement we were just looking at, there's a comment
there saying I've asked about Callendar Square and

I don't know anything about it but I can do some
research, and this was me doing the research.

Okay, so you had been asked to comment in a witness

statement about the Callendar Square bug, you had no
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personal knowledge and you were trying to find out some
information --
Yes.
-- from Anne Chambers?
Yes.
One of the things she did was forward you this chain?
Yes.
She highlights a KEL and asks you, "Can you see KELs?",
and says:

"I'd forgotten -- this did give a discrepancy, but
also a receipts and payments mismatch, if they persisted
and rolled over (though it was usually obvious that
something was wrong).

"And a flood of NT events (not 'Riposte events'!)
which SMC should have noticed at the time.

"Since we are now checking for these particular
events, and did a catch up for old retrievals, can you
say that the current branch did not have this problem??

"Anyway it stopped happening once S90 was installed
(around 4 March 2006, according to the info below).

"This particular problem would only affect branches
with more than one stock unit. It happened several
times at Callendar Square, though we never found why
they were so badly affected.

“Is this sufficient?”
25

have this problem??"

Well, at that stage I couldn't but that was a check that
we did later do when we checked the NT events for the
West Byfleet branch.

Do you agree that there's an implication there that

you're looking for ways to find or to say that the bug

had no application in Seema Misra's case?

Yes.

Was there a bigger point arising from this email, namely
the fact that the Callendar Square bug existed, that it
produced discrepancies, meant that before testifying as
to the reliability of Horizon accounts, you needed to
carry out a thorough review of PiniICLs, PEAKs and KELs?
I thought that what I needed to do was a thorough review
of the NT events, which is what I did.

I think you reflected earlier in your evidence that

you've now realise that something more broad was needed
or a broader --

Looking back now but, at the time, I thought it was
sufficient to just look at the NT events.

And Helpdesk records as well, would you include that in
the list of things that you ought to have looked at?

Now, yes; at the time, I felt that that had -- or at

least maybe not at this exact time but I was aware at

some stage that Andy Dunks had actually done a survey of
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She said, "I'd forgotten -- this did give
a discrepancy", had you asked her whether the bug would
produce discrepancies?
I can't remember the conversation I had at the time.
I was just asking for information.
That rather implies there had been an exchange or
a conversation when she had forgotten that this bug had
produced discrepancies?
Yes, I could well have asked about that. As I say,
I just can't remember that conversation.
Would you be interested to know whether the bug did or
did not produce discrepancies?
Clearly, because, if there had been a discrepancy, then
that would be something important to have reported on.
Also, whether the bug was or the effects of the bug were
noticeable to the user, the branch user?
Yes.
That would be something that would be important to
discover?
Yes.
She asked the question, or she says:

"Since we are now checking for these particular
events, and did a catch up for old retrievals ..."

She then asked the question:

"... can you say that the current branch did not
26

Helpdesk calls and --
We're going to come to those a bit later.

Do you agree that, in order to answer the question
that had been asked of you, you would need to look at
the full message store?
I would certainly need to look at the ARQ data, whether
I needed to look at the full message store or not, I'm
not 100 per cent sure.

Why aren't you 100 per cent sure?

I'm not sure what I would have found in the full message
store that was not obvious in the ARQ data. It's

certainly useful to have the full message store there to
look at if I would need to do so, and I made sure I did

get it.

Winding forwards, you say eventually in your witness
statement that you had little personal knowledge of the
Callendar Square bug until 2010, when you were asked to
find out about it and comment on it in the Misra case?
And that's what this email exchange is all about.

If you didn't have any personal knowledge at all, do you
know why you were asked to comment on it?

No, is the simple answer.

Did you question why somebody with no knowledge about
an issue was asked to provide a witness statement and

then go to court about the issue?
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No. I don't know why that was done.

Well, did you question why somebody with actual or real
experience of the bug in question was not being asked to
answer the questions?

No, I don't know why that was done.

Do you agree that, if you had no firsthand knowledge of
the bug, you weren't truly in a position to give

evidence about it, its effects, and whether or not it

had afflicted Mrs Misra's branch?

I think in the research that I did, I learnt sufficient

about the bug to be able to say that it hadn't affected

that particular branch.

What about the broader issues as to the bug itself?
Were you in a sufficiently knowledgeable position to

give evidence about that?

I knew enough about it, I don't think anyone knew what
the real underlying cause was because that was something
in the Escher software, as we discussed the other day.
Can we move forwards, please. POL00054220, and look at
page 2, please. If we just look at the foot of page 1,

we can see that this is an email from you, I think.

There we are: you to Mr Singh, copied to Penny Thomas,
and we're on 25 February now.

Okay.

Scroll down. You apologise for a delay in replying and
29

looking at FUJ00152992. Can we see you send a further
email the next day to Mr Singh, copied again to Penny
Thomas, and you say:

"Jarnail

"I've no idea what it is that the defence is looking
for in this case or exactly what is alleged to have
happened. It is normal to identify a specific time
period of about a month to look for some specific
fraudulent transactions. As I've no idea exactly what
is being alleged I can't really advise as to what
evidence might be required either to support the
prosecution or the defence. [The Post Office's]
Prosecution Support Team have a formal mechanism to
request logs for specific periods and there is a process
to do that. Although I have suggested for some time
that these logs are requested, I understand that no such
request has been made to Fujitsu. Trying to analyse
transactions over a period of 2 or 3 years ..."

There you're referring essentially to the period of
the allegations against Mrs Misra; is that right?
I'm not sure that I was fully aware of the period of the
allegation at that stage, but I think I was probably
generally aware that we were talking about a long
period, not a short period.

"... is likely to take several weeks or months of
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say things were hectic and you had a day of leave. Then
you're essentially reporting back your communication or
conversation with Professor McLachlan, yes?

Yes.

In the fourth paragraph, you say:

"I also explained to him how some of Horizon works
and why this means that some of his hypotheses were
invalid. I also pointed out that in order to identify
exactly what was happening, then it would be necessary
to go through the detailed logs of the relevant times
and that as far as I was aware, no request had been made
for any such logs (though I think they may now have been
requested)."

So it was still the case that you were, by
25 February, conducting a conversation with the defence
expert without an analysis having occurred of what you
call the detailed logs of the relevant times?

Correct.

Was that problematic?

It really depended what the questions were. So, I mean,
I think we had quite a useful discussion in terms of, at

a high level, how Horizon was operating but, clearly, in
terms of proving some of the detail and some of his
hypotheses, we would need to examine the logs.

Can we go to the next day, please, 26 February 2010, by
30

effort -- especially if it is not clear what is being
looked for -- and I certainly cannot commit that amount
of time to it."

So, again, you're pressing the point that you've
been asking for some time now -- or Fujitsu have been
asking for some time now -- that the logs be requested?
Yes.

Can we look, please, at POL00169122, and look at page 3,
please -- thank you. This is an email from Jon Longman
to Mark Dinsdale but copied to Jarnail Singh, but it

records the fact that:

"Jarnail Singh has just telephoned me ... to get
transaction log data for the above [post office] from
1 December 2006 to 31 December 2007."

Had you advised or suggested that that limited time
period be the extent of the request for transaction log
data?

No.

But, in any event, it seems that, at this time or by
this time, on the 26th, there had been a request for
transaction log data for that limited period?

So I understand, and I know that's the data that

I eventually got.

When you eventually got the data for that limited

period, did you think, "Why am I getting the data for
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this period"?
I took the fact that I was being given data for that,
period, that that was the limit of what I needed to
investigate.
That's circular. Did you know why you were given data
between those two time periods?
I think I may have been told that that was the period
during which false accounting had occurred and there'd
been some question about theft. I think I've set that
out in my witness statement but I can't remember the
exact details.
Can we go forwards, please, to what you say about the
analysis of that transaction data, FUJ00156128. We're
on 3 March now, email from you to Warwick Tatford,
copied to Penny Thomas:

"Warwick,

"... 've added my comments to [the] fifth report.”

The paragraph below, you say:

"I've now also got hold of the transaction logs for
December 2006 to December 2007. These amount to a total

of nearly half a million transactions
Can you see that?

Yes.

So by this time you had the ARQ data, is that right, for

the limited period that had been requested?
33

-- of 9 March, which is your third witness statement in
the Misra case. By this time, you'd got the ARQ data
for the limited period that had been allowed and you'd
also had the exchange with Anne Chambers about Callendar
Square?
Yes.
I think you addressed both of those in this witness
statement?
Yes, and I think I also addressed Professor McLachlan's
first report as well.
Do you agree in the witness statement it's not disclosed
on the face of the witness statement what work you had
done yourself and what work had been done by others?
Yes, because, at that point, I wasn't aware that there
was a need to make that sort of distinction, though
I realise now that I should have done.
If we go forward to page 12, please. You're here
dealing with request to comment on Callendar Square.
Yes.
You say:

"I have been requested to comment on the issue
raised by the defence in relation to a post office
called Callendar Square, Falkirk that was mentioned at
the Castleton trial. I have examined our records and

can confirm the following:
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Yes, and I think I also had the raw logs, but the
analysis I did was restricted to what I had in the ARQ
data.

Why was the analysis restricted to what you had in the
ARQ data?

Because I was looking for specific things that had been
mentioned in Professor McLachlan's second report, as
lay out in this email. And this email is saying,

"This is the investigation that I have done on the data
that I've got", and I also, I believe, suggested other
things that could be looked at and I don't think anyone
ever took me up on it and said, "Can you please go and
have a look at that as well?"

So, again, it was a restricted function that you were
performing, ie responding to that which Professor
McLachlan had alleged?

Yes. I believe I'd been told that this was all needed
very quickly because I believe there was a court date
about a week or so later, so there wasn't really time to
do anything more thorough than that.

Indeed. Can we look at your witness statement, please.
It's your third witness statement in the Misra case.
POL00001643. Can you see that's your witness
statement --

Yes.
34

"The problem occurred when transferring cash or
stock between stock units. Note that West Byfleet ...
does operate multiple stock units so the issue could
have occurred. It manifests itself by the receiving
stock unit not being able to ‘see’ the transfer being
made by the 'sending' stock unit and is compounded by
attempting to make a further transfer. Please note that
such transactions usually reappear the next day. It is
clearly visible to the user as the ‘Receipts and
payments mismatch’ at the time that one of the stock
units is balanced. This usually results in the branch
raising a call. There are no such calls in Andy Dunks’
witness statement of 29 January which summarises the
calls raised by West Byfleet. Also this can be checked
on any balance reports or trading statements that are
available from the branch which should show that
receipts and payments do [not] match and that the
trading position is zero. The problem is also visible
when looking at the system events associated with the
branch. The system events from 30/06/2005 to 31/12/2009
for West Byfleet have been checked and no such events
have been found. The problem was fixed in the S90
release which went live in March 2006 and so would not
have been relevant at the time of the detailed

transaction logs obtained for West Byfleet between
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December 2006 and December 2007."

Do you agree much of what you said here was
assertions made by you, based on what Anne Chambers had
told you?
I had also looked at the underlying PEAK, which had got
the analysis that she had done at the time.

Is that the reference, if we go back up the page, to

"I have examined our records"?

I think so, yes.

So, for example, you say the problem was fixed. Could
you say that the problem was fixed?

I -- the PEAKs said that -- the PEAK was closed with the
comment saying that this is -- this fix appears to have
done it and the problem has not reoccurred since the fix
has gone in.

That's slightly different from asserting in a witness
statement that the problem was fixed, wasn't it?

I didn't think so at the time.

Looking back now, do you appreciate the difference?
Okay, yes, I probably appreciate the difference now but,
at the time, I felt that it was the same thing.

If you carry on reading, over the page, you say:

"Therefore I can conclude that the problems
identified in Callendar Square ... are not relevant to
West Byfleet ..."

37

from live user feedback would be investigated and
resolved appropriately. I am not aware of any such
faults that have been raised by West Byfleet. If
specific transactions can be identified where the user
feels the system has caused losses then further
investigation can be made."

Was that last paragraph as close as you ever came to
answering the broad question that originated from
Mr Tatford, namely whether there were any known problems
with the Horizon system that Fujitsu are aware of?
That was probably addressing that request, yes.
You make your answer conditional, don't you: any such
faults, whether found during testing, et cetera, would
be investigated and resolved appropriately, don't you?
That was my belief.
But it's conditional, isn't it? It suggests to the
reader that there weren't any which Fujitsu actually
knew about, other than Callendar Square?
And I believed I was confident of that because, by this
time, I had actually looked at the NT event logs at the
time and I would have expected, if there had been
faults, for there to be evidence in the NT event logs to
reflect those.
The first part of the paragraph is dealing with Horizon

more generally though, isn't it?
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27 June 2024

Then you go on to say:
"On 2 October 2009 I produced a report about Horizon
data integrity. Within this report are details about
transactions (sometimes known as EPOSS transactions) and
various scenarios that could occur following system
failures. In rare circumstances it is possible for
transactions to not be recorded on the local system but
in all such cases the user would be aware of this.
I produce this report as [your] exhibit GJ/01."
That's your Horizon data integrity report, the first
‘one, that we looked at yesterday --
Itis.
- is that right?
Yes.
The cross reference -- no need to go there -- is
FUJ00080526.
Why were you producing that report in the context of
the Misra case?
Because I thought it gave a useful summary in section 3
of the sort of hardware errors that could occur that
could possibly cause loss of data.
You continue:
"As with any large system, there will be occasional
failures, such as the one found in Callendar Square,
Falkirk. Any such faults, whether during testing or

38
Yes.
Not the branch in question: West Byfleet?
Yes.

Would you agree that a complete answer would say: There
are many known problems with Horizon. Fujitsu keeps
records of them in documents called PinICLs, PEAKs and
KELs?

I.can understand that now. I don't think I would have
thought of it that way at the time.

By answering the question in this way, you did not
disclose the existence of PinICLs, PEAKs and KELs, did
you?

I didn't know that I needed to.

By answering the question in this way, conditionally,
“Any such faults would be investigated", rather suggests
that the only one is Callendar Square, doesn't it?

But certainly later on in the process, I did make it

clear that there were PiniCLs, PEAKs and KELs, and no
‘one asked me to say anything about those in any sort of
statement.

In any case, you say that any faults would be
investigated and resolved appropriately?

That was my belief.

You believed in the life of Horizon all faults had been

resolved appropriately?
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That was my understanding.
What investigation did you carry out in order to be able

to confidently assert that?

I'm not sure that I did any specific investigation at

the time.

Thank you.

Can we turn to a different topic, please, whether
you mentioned in your witness statements your knowledge
of other bugs --

Okay.
- by looking to start with, please, at FUJ00117478.

This a document I don't think we've seen before or
much before. It's prepared by you, correct, on
29 January?

Yes, but this relates to Horizon Online, not Legacy
Horizon.

I'm going to look at a series of Horizon Online -- just
so you know where I'm going -- issues?

Okay.

The heading tells us what it's about, the "Issue of
Duplicate Statements found at Derby":

"The purpose of this note is to describe the issues
found at Derby this week with duplicate settlements and
present options for fixing the defect[s]."

So it sets out the problem and this had led to
41

What does that mean, "full regression testing of the
counter"?

That before we would put that change into live, then we
would need to go through a regression testing cycle,
which would take a few days, so it was a case of how
quickly were we going to get the fix in place, and so,
therefore, there may be some benefit in doing the
tactical solution first and then the strategic solution
later, so as to actually make sure that other branches
were -- had the minimum impact of the problem.

Got it. Can we go forward, please, to 8 February.
FUJ00092922.

These are some notes of a Horizon Next Generation
implementation meeting on 8 February, and we can see
that you are present.

Yes.

This is to discuss the Derby issue, or the Derby bug
issue. Yes?

I think there were -- it's not just the Derby bug.

I think other things were being discussed as well.

Are they the issues at Coton, Warwick?

Yes, I can't remember what those issues were now but we
had a number of issues during the pilot period.

I think the note records that what was called the Derby

bug had manifested itself at Coton and Warwick?
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27 June 2024

duplicate transactions; is that right?
Yes, I need to put this a bit of context.
Oh, please do.
We're talking now about the pilot of Horizon Online. At
that stage it was operating in about a dozen/couple of
dozen branches, so we were expecting to get some initial
problems, and we did, as expected, get a number of
problems during the pilot phase. But, as far as I'm
aware, the problems were all resolved before we actually
rolled out Horizon Online later on that summer.
Okay, that's important context which may --
Very important. That's why I wanted to bring it out.
That may apply to a number of the issues that I'm going
to ask you about.
I suspect it will apply to all of them but we'll see.
You, at the foot of the page -- if we just go over the
page -- suggest some solutions/fixes which are either
a tactical solution or a strategic solution, yes?
Yes.
If we look at the foot of the page, second paragraph
under "Strategic", you say:

"The change is a straightforward code change ...
However, full regression testing of the counter is
recommended."

Yes.
42

Ah, okay.

Does the fact that this group of people were drawn
together reflect the fact that the Derby bug was

a serious issue?

Yes, because it affected the accounts and, obviously, we
didn't want any problems that affected the accounts in
Horizon Online moving forward.

Can we go forwards, please, to FUJ00093031. This is the
next day, 9 February. I don't think you're on this
circulation list.

No, but I think it was forwarded to me later.

Did the Derby bug issue lead to a full Fujitsu internal
audit, essentially?

Yes. It took place the previous week when I was off
sick, which is probably why I wasn't actually involved

in the circulation of it, because the auditors wouldn't
have talked to me.

If we just look at the foot of page 1, please. The last
paragraph. It says:

"The net effect [I think that's of the bug] would be
that the Post Office and the branch records would not
match. Where this happens, the Post Office investigates
the branch and postmaster, with a view to retraining or
even uncovering fraud. It would seriously undermine

Post Office credibility and possibly historic cases if
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it could be shown that a discrepancy could be caused by

a system error rather than postmaster/clerk action.

More importantly, the central database as the system of

record would be called into question.
Is what is recorded there reflective of the views

that you held at the time about the bug?
I was certainly -- my view was that these bugs all

needed to be fixed before we could put any reliability

into the way that Horizon Online operated. I didn't see
that it had been particularly important in terms of
prosecution. What we needed was a system that correctly
handled accounts and, until we had a system that

correctly handled the accounts, then we needed to do

that moving forward, and I believe that that's what
happened by the time the rollout of Horizon Online
happened.

Why would you not have seen it through the complexion or
the lens of it affecting prosecutions?

Because I didn't think we should be going anywhere near
prosecutions, in terms of the state of that system,

until we actually had the system that was stable and
operating correctly. Prosecutions was -- the important
thing was to have the system operating correctly.

Do you agree the existence of the bug, if revealed,

would seriously undermine the Post Office's credibility?
45

agreed with that, but my focus, as I say, was on.

actually getting the bugs fixed not on what the impact
they would have had if they hadn't been fixed. Because
it was clearly very important that these bugs were

fixed.

You didn't reveal the existence of this bug in your
March 2010 witness statement or any of the subsequent
witness statements, did you?

No, because it was totally irrelevant.

Was that the view: because this was about Horizon
Online --

Yes.

-- you needn't reveal anything about Horizon Online
in--

It was a totally separate -- oh, it - it was a totally
separate system.

Was that your mindset at the time?

Yeah.

"I needn't tell the court or the defence anything about
the existence of bugs that caused financial
discrepancies, which aren't revealed to a subpostmaster
in the system we're currently operating, because those
facts cannot be relevant to the court?"

Yes, and that is still my technical belief.

I understand now that the legal position is different
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If the bug was left unfixed yes, but my approach was
much more to do with fixing the bug, rather than any
suggestion of not fixing it and that was where I was
coming from: that the important thing to do was to get
these bugs fixed and so that we actually had a properly
operating system.

Do you agree that the existence of the bug would
possibly undermine historic cases?

Don't see that it was anything to do with historic cases
because, as I say, the important thing was to get the
thing fixed, rather than leave the thing unfixed, and

that was what I was focusing on.

Do you know how it was said, then, in this document,
that the existence of this bug in Horizon Online could
possibly undermine historic cases?

I didn't see that it could affect the historic cases

because Horizon Online was a totally different system
from the Legacy Horizon system, as far as the accounting
was concerned. So I didn't see that it would have that
sort of impact.

The paper explains it in terms of that that is because

it could be shown that a discrepancy could be caused by
a system error, rather than the postmaster or clerk
action?

I see that’s what it says. I wouldn't have necessarily
46

from that but, as a technician, which is basically what

I am, not a lawyer, then I still believe that that's the

case.

But you were stepping out of the computer lab and
walking into a court, weren't you?

I didn't realise that there was that difference that

I needed to worry about and no one advised me as to
that.

Did you think, "I need to take a bit of advice here.

There are problems with the current system where, as I'm
making these witness statements in the Seema Misra case,
we're discovering problems which don't reveal themselves
to subpostmasters, which cause financial discrepancies,
and they're caused by bugs. Have I got to reveal that;
should I reveal that in a candid way to the court"?

It never occurred to me that anything to do with Horizon
Online was relevant to Legacy Horizon.

You said that --

Yeah --

-- that it never occurred to you, and so it didn't occur

to you to reveal it but it didn't occur to you to ask

whether you should reveal it?

No, it just seemed so totally illogical to me.

You didn't know how the legal system worked --

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~ you tell us --

I assume the legal system had some sort of logic to it.
I still don't understand why the legal system would
think that I should be revealing problems to do with
Horizon Online in Legacy Horizon. Okay, I understand
now, having been told that I should have considered it
but it just doesn't actually make an awful lot of sense
to me as a technician.

Again, I'll ask the question: do you not realise that's
the very reason why you should seek advice?

I didn't ... well, I had sought advice from --

Not about this issue?

Well, not this specific issue but I had sought advice in
terms of what I should be saying from David Jones.
Yes, but not about the broader issue of "I've got this
knowledge of many bugs, including bugs that are
revealing themselves as we roll out or as we develop
Horizon Online, have I got to reveal those too?”

It just never occurred to me that it was at all

relevant.

Just remember that last paragraph, there, in particular
the sentence, "It would seriously undermine Post
Office's credibility and possibly historic cases", and
can we look at FUJ00094392. Look at the foot of the

page, please. This is an email exchange, if we just go
49

Post Office credibility and possibly historic cases if

it could be shown that a discrepancy could be caused by
a system error rather than a postmaster/clerk action.
Most importantly the central database as the system of
record would be called into question’. As discussed,
there is no need to paint this in the worst possible

light. I would suggest the following as being accurate
without being unduly alarmist ..."

Then the new drafting is:

"If it could be shown that a discrepancy could be
caused by a system error rather than a postmaster/clerk
action, it could potentially call into question the
effectiveness of the central database as a system of
record.”

If we scroll up, please:

"After review with Legal ... two amendments have
been made to the documents and

he sections ... have

been removed as they do not materially add to the
primary purpose of the review which is to determine
whether the solution, as designed, would protect data
integrity.

"Version 3 has been sent to Dave Smith, Post
Office."

So this seems to record that the sentence about data

integrity affecting possibly past historic cases appears
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up -- and a bit more, thank you.
This is a discussion, you're not party to this

discussion, but I just want to know whether you knew
about it. This is a discussion about amendments being
made to that document we just looked at. You understand
Mr Jenkins?

A. Yes, I understand that. I can't remember if I was
copied in on this email or not. I think -- I may
possibly have been passed it before but I certainly
wouldn't have taken much notice of it.

Q. If we look at the bottom of the page, thank you, just
a bit further, I think we see it's signed off by "JP"?

A. Yes. JP gave me some advice and was in contact with me
at the time that I was at the Seema Misra trial. I also
think he phoned me up a couple of times to see how I was.
getting on, and so on, and he certainly never mentioned
to me anything about why I needed to think about the
problems such as this, which he was well aware of.

Q. Just focusing on this for a moment, he says to
Mr D'Alvarez:

"... please find below the two comments I had raised

A paragraph:
"First paragraph, page 2 -- the following section is

potentially problematic: ‘It would seriously undermine
50

to have been removed before it was sent to the Post
Office; do you agree?

A. Lagree that's what this says, yes.

Q. If we just go to the top of the page. I think we see
that exchange was sent on to you?

A. Yes.

Q. Do you know why you were being told that the report had
been edited to remove the section that said that this
discovery of the bug in Horizon Online might affect past
historic cases --

A. I don't think -- sorry --

Q. --was going to be removed in the version that was being
sent to the Post Office, why that chain was being sent
to you?

A. I would have taken that as just being sent the latest
version of the document, rather than taking any notice
of the -- of that particular discussion.

Q. Not because they knew that you were giving evidence
about past historic cases?

A. Not that I thought of at the time.

Q. No.

SIR WYN WILLIAMS: Mr Beer, have I got this right: this
seems to have been a period of, what is it, seven or
eight months, between the exchange about the contents of

the document and it actually being forwarded to Mr --
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MR BEER: No, this is one of those dates where it has been
Americanised. That's actually --

SIR WYN WILLIAMS: I see. It's actually the other way
round --

MR BEER: -- 11 March.

SIR WYN WILLIAMS: = -- 11 March, okay, fine.

MR BEER: Can we go forwards, please, to FUJ00142152.

This is a further report of yours, a few days later,
12 February 2010, ie a few days later than the Derby bug
issue report, okay?

A. The original one. I mean, the one you just showed me
was March but the original probably yes, yes.

Q. You wrote this report and, in summary, is this about
another bug which resulted in final balances for branch
trading statements being inaccurate?

A. Yes.

Q. This was first reported at the Post Office in Warwick;
is that right?

A. I believe so, yes.

Q. If we look at FUJ00094268, and the third page of that,
we'll see that you sign off an email there and, if we
scroll up, please, is this is an email discussion
between you and others about the issue that we've just
looked at in that report, ie a bug resulting in trading

statements being inaccurate?
53

fix this problem. We certainly could not leave that
problem unfixed for Horizon Online to move forward and
be rolled out, and so, therefore, it was important that
the problem did get fixed, which it did.

Q. Did you know at this time that, at least since the Lee
Castleton case, the Post Office relied on the implicit
accuracy of Branch Trading Statements when bringing
civil claims against subpostmasters?

A. I'm not sure that I was really -- had any distinction
between civil or non-civil claims but I knew that the
Branch Trading Statements, once that came about as part
of IMPACT, was the -- effectively the legal document
that was used to say that the accounts had been signed
off.

Q. When this bug arose, did you consider the possibility
that there may have been other bugs which affected the
accuracy of Branch Trading Statements?

A. I thought -- I could see that this bug was causing
a problem in the accuracy of that part of the Branch
Trading Statement report and felt that it was important
to actually get the bug fixed.

Q. Did you consider the possibility of other bugs which
affected the accuracy of Branch Trading Statements?

A. We would look for other bugs there and I'm not aware

that we actually ever found any other —
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I believe so, yes.
If we scroll down, can you see a passage that's
indented, which says:

"Given the legal status of these reports (they ‘the
final’ are often used in court proceedings when we are
trying to recovery monies from dismissed subpostmasters)
and the potential ‘integrity’ challenges that could be
levelled against the [Horizon] system as a result of any
differences; POL need assurance from Fujitsu that they
could/will explain the cause of the problem and prove
the system has integrity should we be challenged."

That's not you speaking; is that right?

No, that's Phil Norton, I think it was, who was sent the
email. So, again, I've got his questions indented and
my responses not indented.

You say:

“I understand this, though I would have thought most
legal proceedings would be based on the first part of
the report (which covers cash levels) rather than the
second part.”

Irrespective of that answer, you were being told by
Mr Norton and being left in no doubt as to the
importance of the accuracy of the Branch Trading
Statements for legal proceedings.
I was aware of that, and my approach was: we've got to

Did you look for other bugs there?
Yes, we were looking for all sorts of bugs that could be
happening during the pilot. That was the whole point of
the pilot.
Can we move forwards, please, to FUJ00094235, and in
sheet 1, and row 20, please, can you see -- first of
all, do you know what this document is; do you remember
what the document is?
I think this is some sort of tracker of issues during
the pilot of Horizon Online.
Number 20, "BTS reports incorrect", the narrative, if
you just read that to yourself. Can you see that, in -
Yes.
-- column I.

I'm so sorry, it’s the one above. Thank you. So
you should really read column B and column I. (Pause)
Right. I can't remember that problem.
Is this another problem, a separate one from the two
that we've just looked at?
Yes, this was a problem -- as part of the migration of
a branch from Legacy Horizon to Horizon Online, a report
was produced on the last day it was operating on Legacy
Horizon, which was giving effectively a snapshot of the
balance, and then another report was generated the

following morning showing, again, the snapshot of the
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balance, and these two reports were compared. And this
looks likely to be some sort of issue in that comparison
but I can't remember the details of that particular
problem.

It looks like it's a discrepancy bug where stock
movements weren't included in the receipts part of the
stock units balance report?

I -- sorry, I just can't remember the detail. I can see
that's what the words say but I cannot remember this
particular problem.

The words say that the data that was "included in
Horizon was incorrect", whereas the data shown in
Horizon Online is incorrect --

That --

-- sorry is correct.

That suggests to me that there was a problem in the
report that was produced on the Horizon side, on the
date before we migrated, but the data that was on the
Horizon Online version was actually accurate and,
therefore, there would be a mismatch between the two
reports, and the reason for the mismatch was because the
data had been calculated inaccurately on the Horizon
side, but it was correct on the Horizon Online side, is
what I think I'm reading from this.

I see.
57

assuming that, as part of the migration process, some
sort of alert would have been raised if the reports

didn't match and so the purpose of the KEL was that if
those reports didn't match and it was down to this
particular reason, then it would then be known about,
and therefore understood. But --

You're assuming a lot there?

1am assuming a lot, but to say more than that I would
need to go back to the individual PEAKs.

Do you recall making any checks to see whether this bug
had affected the West Byfleet branch?

That wouldn't have had any impact. I wouldn't have made
any checks because this would have had no impact on the
West Byfleet branch because that was still running on
Legacy Horizon. This was purely a migration issue, this
one.

Did it affect the data that was moved over to Horizon
Online?

I don't believe so, no.

What was, on your understanding, the impact of the bug,
then?

It was purely to do with the contents of the report
produced before and after the migration.

A Branch Trading Statement report?

No, this was a migration report, so it wasn't a Branch
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But, as I say, I think I would need to do further
research to say anything more than that.

So it seems like it's a problem with Legacy Horizon,
rather than Horizon Online?

It's a problem with the reporting of the situation on
Legacy Horizon, so I don't think it's actually a problem
in Legacy Horizon, as such, it's purely in the way that
that report is being generated. There was a special
report that was produced as part of the migration
process, I believe.

You'll see that the recommendation on the right-hand
side, under "17 February 2010", is not to fix the

error --

Yes.

-- and, instead, to raise a KEL for coverage. What does
that mean, "KEL for coverage"?

I don't know, is the simple answer.

Was that an expression used, "raise a KEL for coverage"?
I've not heard of that expression before.

Then a KEL is issued and then it's closed.

Yes. As part of the migration process, there was

an automated check made of the electronic versions of
these reports because they're printed in the branch, but
there was a -- it was stored away. So there was

a comparison, a before and after report. So I'm
58

Trading Statement -- you didn't -- it was decided that

it was not sensible to actually get branches to actually
produce a Branch Trading Statement on the day they
migrated, because that would restrict very much the rate
at which migration could take place. So there was just

a snapshot that was produced at the time that the
branches migrated from Legacy Horizon to Horizon Online.
Thank you. That can come down.

So when, in early March 2010, you signed your third
witness statement in Seema Misra’s case, you knew about
a bug in Horizon Online that had affected system
created, system generated discrepancies. You knew about
the so-called Warwick bug, which resulted in inaccurate
Branch Trading Statements in Horizon Online, and that
there was a stock unit discrepancy bug in which affected
migration reports. You didn't reveal any of those three
things in your witness statement, did you?

But as I said before because I thought they were totally
irrelevant.

But you, in that paragraph we looked at, were you trying

to answer Mr Tatford's general question about known bugs
in Horizon?

I was trying to address problems -- I assumed he was
referring to Legacy Horizon, as it operated at the time

that Mrs Misra was operating the branch in West Byfleet.
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I didn't see that a problem in Horizon Online in 2010
was relevant to something that had taken place in
2006/2007, which is what I had been looking at.

Q. Why did you assume that his question, which I think you
agreed first thing this morning, was broadly drawn and
did not have the caveats that you've introduced into it?

A. I didn't see any relevance of the -- Horizon Online to
the situation we had there.

Q. So you inserted the limitations to the question in the
way that you chose to answer it?

A. I think that's putting it slightly strongly but
I just -- it never occurred to me that there was any
relevance of that whatsoever.

MR BEER: Thank you.

Sir, that's a good time for the morning break. Can

we take ten minutes, please, until 11.25.

‘SIR WYN WILLIAMS: All right.

MR BEER: Thank you.

(11.15 am)

(A short break)

(11.26 am)

MR BEER: Mr Jenkins, can we finish off the topic we were
just looking at by examining an email that you wrote in
September 2010 concerning, essentially, these three

Horizon Online bugs that emerged in testing in the early
61

an ARQ.

"We're going to need to tread fairly carefully for
ARQs in this area."

Can you explain what you meant, please?

A. Part of the process of extracting ARQ data was to check
any NT events that were associated with it, and what
I believe had happened here is that there had been
a request for ARQ data for this particular branch, and
some NT events had come back in the search that looked
abit odd. And so, therefore, what I was suggesting is,
yes, we could pass the information to Post Office, but
we needed to actually put on a caveat saying that, in
this particular case, there was potentially going to be
some sort of problem with that.

Q. You don't say, "We're going to need to put on a caveat
when we pass the ARQ data to the Post Office"?

A. I think I was implying that with what I was saying, and
I believe that is what actually happened.

Q._Isit, in fact, what happened: you put caveats on when
the ARQ data --

A. I think there was a subsequent email exchange where
I believe Tom Lillywhite told Post Office, “Sorry, we
can't guarantee the ARQ data for this particular case
because we've come up with these events”.

Q. What about the passage that says, "We need to be wary
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part of 2010, and look at FUJ00156217.
If we go to the last page, please, and then if we
just scroll up. You're talking here about a PEAK and is
it SYSMAN or SYSMAN3 Events?
SYSMAN is how I'd call it, it's short for "system
management".
What was this, the System management 3 events?
Basically NT events. So Legacy Horizon used a subsystem
called SYSMAN2, whilst Horizon Online had a slightly
different version of the technology which was called
SYSMAN3.
Thank you. If we scroll up, please, and if we keep
going -- and keep going. Thank you, just stop there.
You're emailing Penny Thomas and others, saying:
"Steve Porter has had a look at these events ... and
his responses are below.”
I'm not going to go to those responses. You say:
"Unfortunately they are a bit inconclusive, but
there is nothing that is obviously suspicious.
"Given that this relates to [Horizon Online] in
March, [then you say this] then we do know that there
were a number of potentially serious issues around at
that time, so we would need to be wary about making any
witness statements associated with such data. However

it should be fine to pass the data to [Post Office] with
62

about making witness statements associated with such
data", the potentially serious issues around that time,

do those include the three bugs that I've drawn to your
attention this morning?

Yes, I would certainly not have been happy about any of
that data from that pilot period being used in any

sort -- anywhere near a prosecution because the system
was not stable at that time.

So "wary about making witness statements", means what:
"we should not make a witness statement relying on such
data"?

Yes, basically.

"We should tell the Post Office that you should not
confidently prosecute anyone in reliance on such data"?
That was my feeling at the time, yes.

Thank you. Did you consider whether that kind of
sentiment or view ought to have been revealed when you
were making your witness statements in the Misra case,
"look, it can happen in the operation of the Horizon
system that data is produced upon which reliance by

a court should not be placed"?

No, because this was a totally different circumstance.
Here we were talking about a pilot of Horizon Online
whilst, by the time -- the time period we're talking

about for Mrs Misra's case, then we actually had what
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I felt was a stable system.
Thank you. Can we turn to a separate issue: the
duplication of transaction records contained in ARQ

data?

Yes.

Can we start by looking at FUJ00097058. This is

a document, I think you know, authored by Penny Thomas?
Yes.

Its date is 22 June 2010 and it records duplicate record
issues in ARQ returns. Can you explain, in layman's
terms, what the problem was?

Yes, when ARQ data was being collected from Legacy
Horizon, there were certain circumstances in which we
might record the same transaction more than once into

the audit server. So there could be multiple copies of

the same message recorded in the audit server. And the
way in which ARQ data was extracted from that, in terms
of producing the spreadsheets, on Legacy Horizon
discarded these duplicates.

It was supposed to discard it?

On Legacy Horizon, it did.

Yes.

What we had here was, when we moved to Horizon Online,
from the same raw data, we had a different mechanism for

extracting the ARQ spreadsheets and it was found that
65

So that's an additional problem on top of the problem?

No, this isn't for a problem at all.

Right.

What this is all to do with is if you actually look at

the data without taking account of the NUM, you may have
things that look like they're identical data but they

aren't actually genuine duplicates -- sorry, they are

not duplicates, they are actually two real records that

look almost identical.

If we go to point 6, please -- if we just go back up:

"We need to identify which cases provided with ARQ
returns since the [Horizon Online] application has been
live have progressed to prosecution and identify whether
duplicate records were included. We will need [Post
Office] involvement to ensure all instances are covered.
Avery quick review identifies that both West Byfleet
and Porters Avenue are included here, to what extent is
not yet known."

Do you know why West Byfleet was analysed?
I think Penny had been going through all the ARQ returns.
and clearly we had produced ARQ data for West Byfleet,
using the Horizon Online extraction mechanism back in
March, as we discussed earlier this morning.

So was it -- it was relevant, this problem, to the

prosecution of Mrs Misra?
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the mechanism that was used for generating the ARQ
spreadsheets that was now in use with Horizon Online did
not detect and discard these duplicates that were in the
raw audit trail.

Thank you. If we just scroll down, please, numbered
point 4 identifies the issue as urgent in "CS prayers";
what were they?

It was a regular meeting. So "CS" stands for Customer
Services.

Okay, so a morning type meeting?

Yes. They used to be referred to as "prayers", I'm not
quite sure why, but it was really a case of

a get-together first thing in the morning to work out

what the agenda of the urgent issues for the day was.

I think we see in numbered paragraph 4, a separate issue
was identified where a seemingly duplicated transaction
had a different NUM. That's some form of identifier; is
that right?

Yes, each record should have a unique identifier which
was actually in three parts. So there was the FAD code
for the branch, the counter position, and then a serial
number, which started at 1 when the branch was first
installed and, by this time, was up into the millions
probably, relating to the number of records that had

been produced for each counter.
66

Yes, it was, which is why I produced a separate witness
statement explaining the problem.

Why was the Post Office involvement necessary to ensure
that all instances were covered?

I think it was a case of doing a double check that we

knew exactly which ARQ returns were involved in
prosecutions because sometimes Post Office would ask for
ARQ data that wasn't relevant to prosecutions. So

I think it was -- Penny had done an analysis of all the

ARC returns that she'd done using this mechanism but she
wanted to get Post Office involved to make sure that she
hadn't missed any and understood which ones were the
high priority ones to sort out, so as to get some sort

of workload scheduling.

So it wasn't the case Fujitsu could not identify all
incidents?

No. Penny had, as I understand it -- as I say, I don't

have personal knowledge of that, but my understanding
was that she had good records of every ARQ that she had
ever extracted and when she produced it, and so on, and
she could go through those records. I think there is

an email a day or two later where she actually produces
some statistics.

Can we look at FUJ00097047, and start at page 5, please.

We see that she sends her report we've just looked at --
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yes --
Yes.
-- through to you and others on 23 June. Then if we
scroll up, please, Penny says, "Here's some analysis".
This, I think, is a day later.
Yes, so these are the statistics that I mentioned a few
minutes ago.
Yes: number of ARQs affected; number of ARQs where one
or two instances highlighted which indicates bona fide
activity -- do you know what that means?
Sorry, I don't.
Number of ARQs work in progress, presumably?
Yes.
12 ARQs where court action is known, number of cases is
two. Did that include West Byfleet?
I'm assuming that's Porters Avenue and West Byfleet that
were mentioned in the previous note but I'm not 100 per
cent of that.
8 ARQs returned where witness statement requested but
not yet provided, number of cases was three; and ARQs
where no court activity is known is 76.

Then scroll down:

"Audit development are currently working on a fix
which is expected to be available by [the 29th]."

Then you're said to have suggested "the following
69

"Cash on hand analysis would also be out.

"Gareth -- is there anything else I need to add?"

Scroll up. You say that covers it:

"... there is no guarantee that the duplicates are
even complete sessions in which case the sum of all
transactions may even be out.

"In summary, any detailed analysis of the finances
of a branch which is done with duplicate transactions
without realising that there are duplicates (and so
removing them) will give incorrect results.”

That would be a serious issue, wouldn't it?

Oh, yes.
Then scroll up -- and then keep going, and keep going.

Geoff Butts says:

"... do not make any communication with [Post
Office]. We've been looking ... and are waiting [for
a workaround]."

Scroll up, and scroll up, Penny says that she's not
going to communicate with Post Office:

"I do have questions ...

"My assumption that any records which have been
duplicated and presented to court will need to be
replaced. The 2 forthcoming, high profile cases, West
Byfleet and Porters Avenue, immediately spring to mind.

"We have only been presenting duplicate records
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explanation" for the Post Office.

Yes.

Did you suggest that explanation?

I believe so and, hopefully, that is pretty well what

I just said a few minutes ago.

If we scroll on. She says she wanted to speak with her
counterpart in the Post Office, presumably --

Yes.

-- comments please. Then if we scroll back up, please,
to the next page, Guy Wilkerson asks:

"Would the additional transactions make any
difference to the charges for a subpostmaster?"

Then keep scrolling. She replies:

"These are original records which have been
duplicated when copying to audit server. We are not
suggesting that original records have been duplicated."

That, of course, is correct, isn't it?

Correct, yes.

"If analysis was undertaken on the audit data some
transactions would be duplicated; both plus and minus
(we hope!). Analysis on stock units could be out as TI
would show duplicated transfers and equally would TO."

What do both of those mean?

Transfer in and transfer out, so it's to do with

transferring cash between stock units.
70

since the beginning of the year and, although not

an impossibility, it is unlikely that we would have
provided records for any cases heard in such a short
time frame. I can find no record of any witness
statement provided, apart from those listed ... we need
confirmation ... from POL; and guidance from Legal.

"All of the returns listed may not end up in court,
but we need to be aware that a significant amount may
need replacing."

If we go back down to your explanation, I don't
think that includes the point that was made originally,
that you had spotted, the problem with a duplicate with
a different NUM. Instead, it refers to the NUM as being
a reliable way to identify a duplicate, doesn't it?
I think you may have misunderstood what the other issue
was.

Okay.

The other issue was that you should get --

That's completely possible, by the way.

Sorry?

That's completely possible.

Sorry. What the other issue was, where you would
actually get two transactions that were identical, apart
from their NUM, and therefore if you tried filtering

things out without looking at the NUM, you might be
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filtering out things that weren't actually genuine
duplicates.
see. So is that why that is not mentioned in this
section?
Yes. So, therefore, what it's saying there: the
reliable way of identifying the duplicate is to use the
NUM for the filtering, rather than by looking at the
text of what was presented in the ARQ.
Thank you. So, overall, would you agree this was
a serious problem?
Oh, yes.
Can we turn to things that you were saying at this time,
as a separate issue -- that can come down -- as perhaps
a way of understanding what was operative upon you at
the time. FUJ00152888.

Look at page 2, please. Can you see that you have
been reading through a report; can you see that?
Yes, I can see that.
Is that about Shoeburyness and Leigh-on-Sea?
I can't -- I thought this was to do with Porters Avenue
but I'm not -- I -- I don't recall this particularly.
All can go by is the email that you showed me.
If we just scroll down, and again, please -- thank you:

"I have received a copy of an accountant's report

and attach."
73

difficult to progress. The cost of such an analysis is

likely to be high. We did some similar analysis over

a two-month period for a defence accountant about a year
ago and were paid for it (Pete Sewell set it up -- Anne

did most of the hard work and I presented it to the
accountant). I think we need some management guidance
on this."

You say that this is "highly politic:
Basically, what I meant it's not a technical issue; this
is something that management need to think about.
Then you would say this is a management issue?
Yes, so that's basically saying that -- repeating my
point.

In what respect was it political?

It was to do in the way in which -- I'm not using
"political" in terms of party politics, I just saw

that - when you --

It means --

sommercial" might have been a better term to use.
It's to do with how Fujitsu interacts with Post Office.
Okay, so it obviously doesn't mean high politics?

Oh, no, it's to do with the higher level communication
between the companies, which was not the sort of thing
I liked to get involved in, if I could help it.

Why was it political in that sense?
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Yes.
"... and a statement from Phil Budd ...

“Please could you read the report and decide how to
continue; the request from the accountant, Charles
McLachlan ... suggests a telephone call ..."

Does that help or not?

Not really. As I say, I do remember looking at
something to do with Porters Avenue and I do remember
that Phil Budd had something to do with it. So that's
why I'm assuming this is to do with that but I can't
remember the context and I've certainly no recollection
of what the report said and why I was concerned about
it.

If we go up to page 2, then, where we were -- thank

you -- you say:

"Penny,

“I've now read through this report. I agree that
there probably needs to be some further investigation
here. However I'm also aware that this is probably
highly political. Therefore I'm not sure how best to
address this. We don't really want to be seen to be
undermining a [Post Office] prosecution!

"I think the report does raise a number of questions
without a detailed analysis of the various transactions

over the period described (it's 6 to 9 months) it is
74

Because I think we needed guidance as to how to approach
this. As I say, I can't remember any of the details of
what the details were in this particular case but

I think this was another thing that caused Penny to get
David Thomas involved because I think -- not David
Thomas, David Jones -- because that occurred about
a week after this and, certainly, he was asked about
Porters Avenue as well as West Byfleet, and that's why
I think this is to do with Porters Avenue.

Political in the sense that we've been asked to give
evidence about the reliability of the system that we're
supplying to the Post Office?

I'm not sure what the issue was to do in this case.

You continue, and I want to ask whether this gives us
an understanding of what you meant:

"We don't really want to be seen to be undermining
a [Post Office] prosecution!"

Firstly, did that represent your state of mind, that
Fujitsu should not be seen to be undermining Post Office
prosecutions?

Well, I'm not sure that that's -- I think I needed to

get some guidance on that but there was certainly
an example email I've been shown, as part of this
Inquiry, where I have actually said, in response to

a report that I'd been asked, that I agreed with the
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defence expert and Post Office decided to ignore what
I'd said.

Can we just focus on the question, please, Mr Jenkins?
Yeah.

Was it your state of mind at the time that you believed
that Fujitsu should not be seen to be undermining a Post
Office prosecution?

Well, I was wanting guidance as to what exactly we
should be doing.

Why did you need guidance on whether or not Fujitsu
should just present the facts, irrespective of whether
they supported or undermined a Post Office prosecution?
I just wanted to get some sort of guidance from senior
management as to any communication I had in this area
with Post Office and the guidance I got was to just tell

the truth, which is what I would like to have done

anyway.

Did you need guidance from management --

I wanted to make sure that I didn't undermine anything.
Did you need guidance from management on whether you
should just tell the truth or not?

No, I didn't need guidance. I would just tell the truth

but I just wanted to make sure that I had -- I was being
covered by my management for any actions that I took.

You needed top cover for telling the truth?
77

stage. It for just a case of comments on a report.

Okay, so comments on a report --

Yeah.

a defence expert report.

Yeah.

If your evidence wasn't influenced by the fact that you
were a Fujitsu man, why were you seeking management
guidance on what should be done if your answers might
undermine a Post Office prosecution?

It was a case of whether my answers should be sent -- my
comments on the report should be sent through or not,

I suppose. As I say, I just cannot remember what the
issue was that I was concerned about in this case.
When you gave witness statements and then subsequently
were asked questions and answered them in court, was.
a factor operative on your mind the fact that you, on
behalf of Fujitsu, should not be seen to undermine

a Post Office prosecution?

No.

Because that's what the politics of the situation
demanded?

No, certainly when it came to court, then that didn't --
that didn't come into it. I just wanted to understand
what I needed to do about my thoughts on this particular

report, which was not at that stage anywhere near
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I don't know what to say to that.
Why did you need management guidance on whether or not
Fujitsu should be seen to be undermining a Post Office
prosecution?
I just wanted to get some sort of feeling as to how to
approach the response to the report.
When you subsequently came to give evidence in the Misra
trial, very limited questions were asked about your --
the status in which you were giving evidence and the
duties of an expert witness, agreed?
Agreed.
One of the only things that was asked was, in fact, by
the judge -- I'm not going to turn it up, I'm going to
read it.
No, I know what you --
You know the question.
Yes.
“Is there any question of your evidence having been
influenced by the fact that you're a Fujitsu man?"

You said no.
And I stand by that.
If that's the case, why were you asking for management
guidance on whether or not the evidence that should be
given in response to a defence expert report --

I don't think we were talking about evidence at this
78

a court, as I understood it.

So are you saying that there's a material difference
between providing comments on a report in an email
chain, on the one hand, where you wouldn't wish to be
seen to undermining a prosecution, and then ultimately
providing a witness statement, when such impure motives
would have evaporated?

Yeah, I was just looking for guidance as to what

I should be doing in this particular circumstance.

Did you get guidance as to whether or not you should
simply set out the facts, irrespective of whether or not
they supported or undermined a Post Office prosecution?
Yeah, I think that would have affected the guidance

I got from David Jones the following week.

Can we go forwards, please, to FUJ00156122 and look at
page 12, please. We're dealing with a different branch
here, “Alresford large debt outstanding", and there's

a reference to an email trail below. I'm not going to

turn to that. You say:

"This I another example of postmasters trying to get
away with 'Horizon has taken my money’. Dave Smith
seems to have put me forward as the expert to help on
this.

"How should I respond to his request?"

Does that reveal what your mindset was in February
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2010 when you were conducting investigations into Seema
Misra's case and providing witness statements?

No, that is me very poorly trying to summarise what
was -- what I thought was being laid out in the email

trail below and I apologise for the wording that I used
there. But it was me trying to do a crude summarisation
of the email trail for management. I don't think I had
anything further to do with that particular case.

A lot of people have said that they've used poor words
in their emails when they say that what is recorded does
not reflect truly what they believed. Did you believe

that there were many examples of postmasters trying to
get away with "Horizon has taken my money"?

I can't remember what I believed.

Presumably --

What I was trying to do was summarise the email trail
below.

Yes, but you say it's another example of it.

Presumably, it does reflect your mind at the time that
postmasters were trying to get away with "Horizon has
taken my money"?

Well, I didn't believe that there were any problems with
Horizon that was causing Horizon to lose money.

So you did believe that postmasters were blaming Horizon

by saying, “i's taken my money" falsely?
81

Computer Weekly indicating that Horizon was unreliable
and decided to jump on the bandwagon."

Again, that's totally inappropriate wording on my part
and for which I apologise.

It seems that, rather than Mr Singh being the originator
of the "bandwagon" phrase, it appears to be you, doesn't
it?

No, I was reflecting that from conversations I'd had
with other people. It's not a term I would have used
myself. The only reason I would have used it here was
because I'd heard it being used by others.

Who had --

I can't remember now who it would have been, possibly
Mr Singh but I can't say definitively.

So back to Mr Singh, perhaps?

Possibly. But, like I say, it's not a term I would --

I would have used off the top of my head. I was clearly
reflecting it, that I'd heard it from someone else.

Were you able to approach the task of conducting
investigations for the purposes of giving evidence in
court, compiling witness statements and then giving
evidence dispassionately, or --

Yes.

-- were you afflicted by this belief that these were

subpostmasters jumping on a bandwagon which blamed
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I just wasn't thinking things through properly.
Hold on. I think you said that you believed that
Horizon was operating correctly, so this would
accurately reflect your belief. Postmasters were trying
to get away with it by blaming on it Horizon.
I don't think -- I think the issues are actually much
broader than that. I think the issues are as much to do
with the way that they were -- the Post Office was
treating the postmasters and the support and the
training they were getting, rather than actually
problems with Horizon, as such.
Can we move on to POL00175839, and look -- if we scroll
down, please -- an email from you to Jarnail Singh on
1 March in the Seema Misra case:

"Thanks for the information, which I've now read
[it] through.

"... Lean summarise ...

"Ms Misra ... initially identified that the sub post
office was short of cash by about £80-£90,000.

"She tried to cover this up while she repaid the
losses which she thought was due to staff theft.

"By the time of the audit in January 2008 she was
£73,000 short suggesting she had made good about £10,000
of the losses.

"When she went to court, she saw an article in
82

Horizon?

No, I did the analysis conscientiously all the way
throughout.

Did you see your role, as a Fujitsu man, to be to help
prove that Mrs Misra had jumped on the bandwagon and
that, to use the phrase from the other email, was trying
to get away with "Horizon has taken my money"?

As I say, I didn't think the problem was within Horizon;

I thought there were other reasons as to what had
happened and so my focus was looking at seeing whether
there were any problems with Horizon at that point,
rather than the broader focus of what the prosecutions
were about.

Can we look lastly on this topic, just to see whether we
find another tell as to what your state of mind was by
looking at FUJ00153115. This is an email of 15 June
about the Misra case, saying that you had had a call
from Professor McLachlan. I'm going to skip over the
first three or four paragraphs. In the penultimate
paragraph, you say to Penny Thomas:

"The good news is that he [Professor McLachlan] is.
looking for problems in people's use of Horizon and not
bugs in Horizon as such."

Why was it good news that the defence expert was

looking at people's use of Horizon and not looking at
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bugs.
Because that's where I thought the genuine problems
were.

Were you pleased that his attention was not on bugs?
Because I didn't think that there were relevant bugs at
the time.

Were you worried that, if he did divert his attention to
the existence of bugs, he may have found some?

No. I was concerned that I would be wasting time
looking at other bugs that didn't actually apply, in the
same way as we'd already discussed with Callendar
Square.

You thought that it was a waste of time looking for
other bugs?

Because I didn't think there were relevant bugs to be
looked at because, as far as I was aware, the bugs that
had occurred within Horizon had been fixed.

That was all based, I think we established yesterday, on
assumption and chat?

Yes, but that was still my true belief at the time and

still is.

I think that's because you reject some of the judge's
findings in the Horizon Issues trial?

Yes.

Can we turn to the receipts and payments mismatch bug
85

"Jon is easily able to reproduce the problem in
a development environment . is probably worth
starting on the data extraction to ascertain the full
scope of the issue ASAP since it has probably been
around since day one..."
By that, I meant day 1 of Horizon Online.
Yes, ie since January 2010?
Yes.

'... and data more than 6 months old is being dropped
from BRSS ..."

Remind us, BRSS?
I can't remember exactly what the acronym stands for but
it was basically a copy of the live transaction database
that was used for support purposes.
So this was a relatively time critical task because the
relevant data was being dropped off?
It was being dropped off there, it wasn't being lost
altogether. It could still be retrieved using ARQ data
or that, but it was available online through the BRSS.
You say:

"... $0 the sooner we run the queries, the better."
Yes.
If data more than six months old was being dropped off,
would that mean that there would be no way of knowing

how many branches were affected?
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and your treatment of it, by looking at POL00029084. If
we scroll down, please, there. I'm afraid it's cut off
on the left-hand side of the page. I think we can
establish from other evidence that this is 28 September
2010. You say to Mark Wright -- what role did Mark
Wright perform?
He was in the SSC.
"The attached note summarises the problem ..."

The problem is in the title, "Receipts payments
mismatch issue".
Yes.
"... and describes what we need to do to identify the
full scope of the problem and discuss with POL iffhow we
fix the problem."

So you're attaching your lost discrepancies note --
Yes.
-- which we're going to look at in a moment?
Yes.
You ask for feedback. You say:

"We probably need to formally raise this as
a problem with [the Post Office]. I'm not sure how this
is done ... We should then plan to do the initial
analysis [with Post Office] with a view as to scope and
then agree how to progress it."

Skipping a paragraph:
86

No. And, in fact, the way that we eventually decided

was the simplest way of identifying it was through

events that were being picked up from SYSMAN and from
the databases, and events were being held longer.

So there was still a facility?

Yes.

But, in any event, you thought this had probably been
around since January 2010?

Yes.

Can we turn please to POL00028838, a document which

I think you'll be familiar with --

Yes.

-- and with which the Inquiry has been familiar for

a number of months now. There appears to have been some
meetings between Post Office and Fujitsu about the
receipts and payments mismatch bug and this is about one
of them, this note was compiled. You, in your witness
statements, try to date this meeting, don't you?

Yes, I can see there were a number of meetings during
the week and I'm not sure exactly which or whether this
was just a summary of the problem based on all of the
meetings. I don't think I saw this note until 2018.

You were present at this meeting; can you see that?

I was present at some of the calls that we had during

that week, whether this is a note of a meeting or not,
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is not 100 per cent clear.
You, if we look at page 3, please, top paragraph:

"The Receipts and Payments mismatch will result in
an error code being generated which will allow Fujitsu
to isolate branches affected by this problem, although
this is not seen by the branches. We have asked Fujitsu
why it has taken so long to react to and escalate
an issue which began in May.”

Did you tell them that the problem began in May?
I can't remember what exactly what I said in the
meeting. I doubt I would have scoped it in that way.
Because you thought that the problem had been around
probably from day 1, ie January 2010.
Yes, there was a fairly obscure set of circumstances
which caused this problem, which is why it only occurred
about 60-odd times across what was by then a whole
estate of 12,000 branches. So it is quite possible that
the first occurrence of the problem was in May, in that
none of the branches had actually gone through that
particular set of interactions earlier. But, if they
had gone through that set of interactions before May,
then they could have hit the problem. As I say, I can't
remember now exactly when the first occurrence was but
that's maybe where May comes from, I don't know.

It's said that they ~ that's Fujitsu ~ will provide
89

Ah, that's right. Most of the other versions that I've
seen have been dated 28 September, so whether it's --
how that differs, I'm not sure.

Okay.

Probably not materially.

Under the heading "Introduction", you discuss some
PEAKs, 765 and 263, and also 864, which is a duplicate
of 263. You ask the question:

“Are these really duplicates? I'm a bit confused as
to which one to refer to. Can one be closed as
a duplicate of the other?”

Was that an issue that happened frequently, namely
multiple or duplicate PEAKs and some were closed in
order to keep only one open if possible?
I am not an expert on the process. You would need to
talk to the SSC people about that but my understanding
was that, if the same problem was raised for more than
‘one branch, then the approach was just to have one PEAK
that actually controlled the issue, and there was
a mechanism within that PEAK of listing all the branches
that were affected by that issue and then closing other
PEAKs that are duplicates, so there was just one PEAK
which could actually sort out the result of the problem.

In the paragraph underneath, just two lines from the

bottom of it, you say:
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feedback on that issue in due course, ie "We are in
October now, why is it that we are being told about this
now?"

Yes, and I can't remember the circumstances as to why it
was only at this point that the problem had actually
been discovered. My first involvement with it, as far

as I can remember, was at the end of September, so about
a week before these calls with Post Office.

The code fix is mentioned in the next paragraph.

Yes.

Was it the case that, at this meeting, or as a result of
these communications, Post Office was told that Fujitsu
had data from which it was possible to ascertain all of
the branches that had been affected?

That is my understanding. We certainly did have that --
we certainly worked out that information at some point.
Exactly how that fits in with this meeting or not,

I can't remember the exact chronology.

Now, we've seen that you authored a document about
correcting accounts for loss discrepancies. If we can
look at that, please, it's part of this package of

material, it's at page 6. We'll see this is your
document, correct --

Yes, I believe so.

-- dated 29 September.
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PEAK [765] is a Master PEAK to record all
affected branches ..."
That is really what I was trying to say, yes.
There should be a master --
There should be a master PEAK, yes, because there is no
point in investigating the same problem more than once,
once it has been established that it is the same
problem.
Was that something that was always done, ie when
a problem or issue or bug was reported, there was
a system in place to consolidate reports across Fujitsu
to collect together all reports relating to that problem
into a master PEAK?
That is what I understood was the way that things should
be working. I'm not sure that it always did work in
exactly that way but that was how the process was.
supposed to work, as I understand it. This wasn't my
process.
Over the page to page 7. If we just scroll down,
please. At the foot of the page, you say in the box
immediately at the bottom of the page:

“Mark Wright has produced a list of 16 occurrences
of event 903 in the last 30 days. This needs to be
extended."

What was event 903; can you remember?
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Itwas the primary symptom of this particular problem.
I can't remember the details more than that, I'm afraid,
now.

Mr Wright, had found 16 occurrences of that problem, or
symptom, in the last 30 days, and that needed to be
extended. Do you mean --

So therefore I was saying you need to look back more
than 30 days ago, you need to look back at all
‘occurrences of this event going back to January 2010.
Was that done?

Yes.

How many were eventually detected?

I think at the end we found there were 64 occurrences in
62 branches but they hadn't necessarily all happened at
this point because some of them -- the problem continued
to occur until the code fix went in about two or three
weeks after this time.

In the report overall there was an acknowledgement that
subpostmasters may be unaware of the problem because
there wasn't essentially a prompt to them to make them
aware of it. Is that right?

There wasn't an explicit prompt. If they had looked in
detail at the branch trading statement, they would have
seen that there was a problem there but there wasn't

a message that actually popped up and said, "Yes, you've
93

the branch to report the problem. Also, if we do amend
the data to re-introduce the discrepancy, this will need
to be carefully communicated to the branches to avoid
questions about the system integrity.”

We never did amend the data in the --

Yes, just before you get that answer in too quickly, why
would you, if you did amend the data, need carefully to
communicate that to the branches, in order to avoid
questions about system integrity?

Well, I can see that this was an important problem.

I didn't want to be amending the data in the branches,
and we didn't amend the data in the branches --

No, no, that's a different issue.

If it was --

it~

If it was badly communicated, it could show that there
were serious problems within the ongoing operation of
Horizon Online, and we clearly didn't want to do that,
so it wasn't a case of covering up; we just didn't want
to have bad publicity for what was actually a very
isolated problem.

That's not what this says. You wanted to avoid
questions about system integrity, didn't you?

That was behind what I was trying to say at the time.

Well, on this document, that's all that was behind what
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got a problem".
So they would need to examine, very carefully, a branch
trading statement -- to --

There was one figure in there which should always be

zero and, in this particular case, it wasn't.

If we go over to page 8, please. At the bottom of the

page, please, under "Communication with the Post

Office", you say:

"Once we have the information [above] which will
enable us to identify the full scope ... we need to
communicate this to the Post Office Limited through the
problem management mechanisms. We will then need to get
Post Office to agree if and how we should be correcting
the data."

Why did you think there was a possibility that you
might not correct the data?

We didn't correct the data in the branches. What we
actually did was we corrected the data in the Post
Office's back-end systems.

"Post Office should also be able to check up on POLSAP
to confirm these discrepancies are still visible even
though they have been lost in the branch.

“It should be noted that as discrepancies are
normally losses, then a lost discrepancy would [need to]

work in the branch's favour so there is no incentive for
94

you wanted to say. You wanted to avoid questions being
raised about the system's integrity, didn't you?

I didn't think -- I didn't think there was anything
fundamentally wrong and I wanted to ensure that things
were actually communicated accurately.

This isn't about the accurate or inaccurate

communication of information to branches, it's about
avoiding questions concerning the system's integrity.
That's your motive, isn't it?

No, my motive was to make sure the communications were
done accurately.

Why didn't you say, "If we do amend the data, we must
communicate that to the branches accuratel

Perhaps that's what I should have said at the time.
But, as I say, I wasn't exploring every word that

I wrote in an internal document expecting it to be
picked apart in the way that it's being picked apart
now.

Apologies for picking it apart, I'm just trying to work
out what was operative on your mind at the time.
Operative on my mind was that we didn't want to blow
this out of proportion. This was a relatively small
problem that was affecting a very small number of
branches and we didn't want to actually undermine the

overall system, which was working perfectly correctly in
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many, many branches, and this was a problem that was
going to get fixed, and it was easily scoped and
identifiable.

Q. But you didn't know any of that at this time. You told
us that there had only been a backward look for 30 days.
You thought this went back to January, rather than May.
You didn't know the extent of the problem at all --

A. But I knew that --

Q. --alimited problem affecting a small number of
branches that was easily fixed -- when you were writing
this sentence, did you?

A. I was aware that -- I had a fairly good idea what the
sort of scope was going to be. At this point, we'd
identified 16 branches, I could see that we would
identify a few further branches and, as I say, the
eventual figure was about 60-something.

Q. I'm going to continue the picking apart, ifI may. The
reason that you used these words was because that's what
you were thinking at the time, isn't it? It's not
a poor choice of words, it's not a choice of words that
was in error, it's not a choice of words that reflects
something that you didn't think. You wanted to avoid
questions about the Horizon system's integrity, didn't
you?

A. I don't think that’s true but ...

97

mismatch bug] could cause a loss of confidence in the
Horizon system by branches."
You were at this meeting; did you say that?

A. I don't know, is the simple answer. I don't think so
but I don't know.

Q. Do you recall who did say that?

A. Ihave no recollection of -- whether this was one
meeting or a consolidated report of all the meetings,
have no idea. I remember being on conference calls
about the issue but what was said in detail on the
conference calls I've no recollection, I'm afraid.

‘SIR WYN WILLIAMS: Was there any face-to-face meeting, as
far as you can remember or were they all conference
calls?

A. There were face-to-face meetings internally within
Fujitsu but, in terms of communication with Post Office,
I think it was all conference calls.

SIR WYN WILLIAMS: So this list of people we see at the
start of this document, which is both Post Office and
Fujitsu, was there ever an occasion when you were all in
the same room together discussing it?

A. I don't believe so.

SIR WYN WILLIAMS: Right, fine.

MR BEER: Was there ever an occasion when you were all on

the same call?
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MR BEER: Sir, it's just gone 12.20.

SIR WYN WILLIAMS: Yes.

MR BEER: Can we break until 12.35, please?

SIR WYN WILLIAMS: Yes.

MR BEER: Thank you.

(12.22 pm)

(A short break)

(12.35 pm)

MR BEER: Good afternoon, Mr Jenkins, can we continue your
evidence by finishing off the receipts and payments
mismatch issue, and go back to POL00028838, please. Can
we look, please, at page 2.

Can you see, in respect of this meeting, in relation
to which you're recorded as an attendee, under the
heading "Impact" at the bottom -- if that can be blown
up, please. Thank you.

"Impact

"The branch appeared to have balanced, whereas in
fact they could have had a loss or gain.

"Our accounting systems will be out of syne with
what is recorded at the branch.

“If widely known, could cause a loss of confidence
in the Horizon system by branches.”

Just stopping there, at the third bullet point:

“if widely known it [the receipts and payments
98

A. I can't remember exact -- as I say, I thought it was
just one call. I've since seen suggestions that there
were two or three calls and I just can't remember the
details, I'm afraid.

Q. Was the outcome of the calls an agreement that, if the
problem was widely known, it could cause a loss of
confidence in the Horizon system by branches, as
recorded here?

A. IIdon't know. My role in these calls was explaining
what the issue was technically, not in terms of -- and
understanding what it was that was going to be decided
in terms of how we fixed it moving forward. That was my
main focus.

Q._ If a view was expressed in the call or calls, whether by
Fujitsu, including you, or by the Post Office, that if
the receipts and payments mismatch bug was widely known,
it could cause loose of confidence by branches in the
Horizon system, did that fact, did that view, as
expressed, affect your willingness to mention it in
court in the following weeks when you gave evidence?

A. No, it never occurred to me that it was relevant
because, as I said earlier, this was an issue with
Horizon Online, and where I was giving evidence was to
do with Legacy Horizon.

Q. The next bullet point, therefore, becomes relevant:
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"Potential impact upon ongoing legal cases where
branches are disputing the integrity of Horizon data."

By this time, I think only two branches had been
identified in respect of which there were ongoing court
cases, correct?

I've no idea.

We looked at the report earlier, didn't we? One of them
was --

That was in a different context. That was when we were
looking back at ARQ data back in June.

By this time, had any court cases been identified?

I don't know. I don't recall any mention of legal cases

as part of this discussion. That wasn't where I was
focused on. What I was concerned with at this point was
the technical aspects of this issue. I have no
recollection of discussion of legal implications of

this.

What, to your knowledge, ongoing legal cases were there?
I wasn't aware of any legal cases involved with Horizon
Online by that time.

No, it doesn't say Horizon Online, does it? It simply
says, "ongoing legal cases". You knew about one, didn't
you, a big one: Seema Misra's case?

Yes, but I didn't see it as being relevant to that and

I would not have taken it as being relevant in -- that
101

subsequently seen, as part of the work with the Inquiry,
that there was discussion along those lines but, at the
time, I am not sure that I'd have even noticed that sort
of thing being mentioned. I was concerned about the
technical aspects of this problem.
So if it was discussed at a call or calls that the bug
had an impact or potential impact on ongoing legal
cases, that wouldn't have affected your willingness or
otherwise to mention it in the Seema Misra case?
No, because, so far as I was concerned, it was totally
irrelevant. Now, if someone had then come and said
I should mention it, I would probably have argued
against it. But if they said "No, you've got to do it
for legal reasons", then, obviously, I would have done.
We know, in fairness to you, that you had disclosed it
in your note of 28/29 September 2010, and we know that
that was forwarded to Post Office Legal, Jarnail Singh?
Yes, I have learnt that as part of the work I've done
for the Inquiry, yes.
The last bullet point:

"It could provide branches with ammunition to blame
Horizon for future discrepancies."

Do you recall who said that?
No, I don't, I'm afraid.

Whether that was somebody from Post Office or Fujitsu?
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that statement was referring to that at all.

What ongoing legal cases were there concerning Horizon
Online?

I don't know. I wasn't aware of any.

Were there, were there any at all?

I don't know. I don't understand the context of that.

I mean, I understand now what the context of that is
but, at the time, I wouldn't have known what that was
about and I'm not sure if I'd even have noticed if
anyone said anything along those lines.

Did you say that: that the bug has a potential impact on
‘ongoing legal cases?

No.

Who said that?

I've no idea. As I say, I don't even remember hearing
that being said. It's clearly recorded there in the
minutes.

You agree that it's a record in this document of the
receipts and payments mismatch bug, having a potential
impact upon ongoing cases. Given the start date of
Horizon Online, you would have known at this time that
the likelihood of there being any ongoing legal cases
involving Horizon Online was minimal or even zero?
I've no recollection of there being a discussion about

legal cases as part of the ~- these exchanges. I've
102

I've no idea I'm afraid, sorry.

Do you agree these three bullet points taken together
seem to reflect a concern about the disclosure of the
receipts and payments mismatch bug, in that it would
have undesirable consequences?

I can understand that now but, as I say, I don't think

I was conscious of that sort of discussion as part of

the meeting at the time.

Can we go forward, please, to page 3. We can see the
solutions, and I think you'll be familiar with these?

Yes.

If we scroll down -- thank you -- which one did you
support?

Where it was sorted out in the back end. So I think
that's Solution Two, isn't it --

Two.

-- where it gets journalled in POLSAP. And that was the
‘one, I believe, that was eventually done.

The first and the third solution are said to have moral
implications, the first because it would involve
changing branch data without informing the branch and
the third, moral implications to the integrity of the
business; can you see that?

Yes, I don't remember the term "moral implications”

being used there but, certainly, it was -- I was always
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favouring the second option, doing things in the back
end. I felt that was the right way of doing things and,
as I say, that was what was eventually done.

The first solution was said to have significant data
integrity concerns and could lead to questions of
tampering with the branch system and could generate
questions about or around how the discrepancy was
caused. Is that because this would involve Fujitsu
manually writing values into branch accounts?

That is how that would have been done and I was against
doing that.

Why were you against doing it?

Because I think it was the wrong thing to do. It was
much better to actually sort things out through

a business process that was there in the back end of
journalising the entries in POLSAP.

That discussion revealed, of course, that the facility
was available to Fujitsu, a form of remote access?

I wouldn't call that a form of remote access, as such.

I think I -- because what we would have had to do is we
would have had to develop a specific bit of code to
actually make those sort of changes to those affected
branches and so it wouldn't have been using any of the
regular remote access type facilities that we had. So

it would have been a special bit of code that would have
105

"Most problems manifest themselves so they can be
visible. So, for example, if there was some problem
with balancing and so on, then that -- that I would
expect to be investigated to see whether there was
an underlying problem as a result of it.”

The question that you were asked, "Are there
problems that a subpostmaster at the Post Office is
going to be unaware of?", you say, "Most problems
manifest themselves so they can be visible".

Yes.

Amonth earlier, you'd been dealing with a problem that
didn't manifest itself in an obvious way to the
subpostmaster.

It did manifest itself, it was visible. If you actually

read thorough the BTS, there was a non-zero entry in the
BTS where there should be a zero entry.

I think you had said already that that's if you examine
them carefully --

Yes.

-- ora similar phrase?

Yes.

Was your reason for not mentioning that here because
that was to do with Horizon Online and you thought you
were answering questions only about Legacy Horizon?

I was certainly thinking I was only talking about Legacy
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been developed and tested specifically for that purpose.
But, again, that wasn't the way that we went.

Was consensus reached on that in the meeting?

I can't remember the actual discussion but it was

certainly Solution Two that was done, going forward, in
terms of actually sorting things out at the back end.

I can't remember the discussions behind it and how long
those discussions were.

Thank you. Can we move on, please, to the evidence that
you gave at trial, by looking at POL00029406. Can you
see this 14 October 2010 at the Crown Court at

Guildford. If we scroll down, it's a transcript of the
proceedings --

Yes.

-- and it's a transcript of your evidence.

If we go forward to page 123, please, and just go
down at H. At the foot of the page, thank you.
Re-examination, so that's questions at the end of your
evidence session, being asked by the prosecution
barrister, Mr Tatford. He says:

“Are there problems that the subpostmaster at the
Post Office is going to be unaware of?"

Can you see that?

Yes.

You say:
106

Horizon.

Does that answer apply across the transcript --

Yes.

-- that, even if questions are asked of you in a broad
way, like that one was, which wasn't specifically about
Legacy Horizon, you thought you were talking and only
talking about Legacy Horizon?

Yes.

Can I turn to the extent to which you were asked to
consider wider issues when you were providing your
witness statements and giving evidence, and just start
by looking at your witness statement, your third witness
statement, at page 125. This is just what you say at
the end of paragraph 369, the last four lines. You're
dealing here with the event timeout locking issues and
you say, in the last four lines:

"Nor have I seen any emails that suggest my raising
these event timeout/locking issues prompted anyone
within [Post Office] or Fujitsu to ask me to provide
a witness statement about any other past problems that
had affected Horizon."

Yes.
By that, are you saying that you don't more generally
recall being asked to provide a witness statement about

any past problems that had affected Horizon?
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A. Yes, I think that's what I was saying. What I thought
I was being asked to look at and what I think I was
looking at was specific problems at the specific branch,
and I found no evidence of any specific problems at the
branch. I had raised with people within Post Office the
fact that I was aware of problems that didn't affect
that branch, and no one said, "Oh, in that case, you
need to talk about it and put it in your witness
statement".

Q. You say, therefore, that you don't think you were being
asked to provide witness statements or a witness
statement about any past problems that had affected
Horizon. Can we look back, please, at FUJ00122794.
FUJ00122794, and page 2, please -- and scroll down.

We looked at this email first thing this morning.
Jarnail Singh, and we see that you're copied, and
Mr Singh has said that points 2 to 4 haven't been
answered, and 3:

"When Gareth completes his statement could he also
mention whether there are any known problems with the
Horizon system that Fujitsu are aware of."

So you had been asked that very question.

A. And I'd responded to it at the time saying that until
I looked at the logs, I wasn't able to make a clear

statement, and then nothing further was actually done
109

route, rather than the lawyer's route:

"At a pre-court hearing today the judge has ordered
that all defence requests [be answered].”

Then:

"Gareth's statement needs to cover the following
four points."

Then do you see (3):

"When Gareth completes his statement he should also
mention whether there are any known problems with
Horizon system that Fujitsu are aware of. If none could
this be clarified in the statement."

So, in fact, far from what you say in your witness
statement that "Nobody had asked me to provide
a statement about any other past problems that had
affected Horizon", you were asked that very question
twice, weren't you?

A. Well, I didn't respond to that either way.

Q. Well, let's just agree: you were asked the question
twice, weren't you, once through the lawyer's route and
once through the investigator's route?

A. I'd not considered it in that way.

Q._ I know you say that you hadn't but the fact of the
matter is, rather than you not being asked a question
about broader issues or problems with Horizon at all,

you'd in fact been asked it twice: once by a lawyer and
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about that. So I thought that that had been addressed.
Well, let's break that down. In your witness statement,
you said, "Nobody asked me to provide a statement about
any other past problems that had affected Horizon".
This is a request to do exactly that, isn't it?
I'd not considered it that way when I was putting
together the witness statement.
No, but looking at it now, it's a request to do exactly
that, isn't it?
I'd not seen it that way, but possibly.
So you'd been asked that question, the broad question of
known problems with Horizon, through the lawyer's route,
I'm going to call it, seen to you. Yes?
Yes.
Can we look, please, at FUJ00152902, page 2, please.
Can you see an email, Jon Longman to Penny Thomas --
yes --
Yes.
-- on 1 February. If we just scroll up, just the bottom
of the page there, Penny Thomas to you:

"Please see ... below; this is now extremely
urgent.”

So you get forwarded this chain.

Go back to where we were, top of page 2, so Longman

to Thomas. I'm going to call this the investigator's
110

once through an investigator's email, hadn't you?
It looks like it.
Can we scroll up to what you replied:

"I've finally managed to go through the witness
statements [et cetera].

"I don't know anything [presently] about Falkirk."

Then:

“I'm not aware of issues in Horizon other than the
event timeouts. Not sure how to cover that in the
witness statement."

Which is basically the same thing as I said to David
Jones later in the week.

Well, firstly, do you agree that answer there in that
third paragraph is your response to the question, or the
request, to cover whether there were any known problems
with the Horizon system that Fujitsu are aware of?

I think it probably was, yes.

So that's a direct response to the broad question. You
were aware of issues in Horizon, other than the event
timeouts, weren't you?

Not ones that were still outstanding.

Is that what you say?

I had assumed that as part of the context but I accept
that I didn't spell it out.

The context is framed by the question that you were
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asked, "Are there any known problems with the Horizon
system that Fujitsu are aware of?" That's talking about
the operation of Legacy Horizon at the very least, isn't
it?

I wasn't understanding the question that way but I can
understand that that may have been what was meant.
You say that this answer is supposed to read, "I'm not
aware of any outstanding issues in Horizon, other than
the event timeouts which have not been resolved". Why
would you not say that, if that's the meaning that you
now attribute to those words?

I don't know, is the simple answer.

That statement there is not true, is it, "I am not aware
of issues in Horizon other than the event timeouts"?

I was thinking of outstanding issues but I can accept
that I have not qualified it correctly.

So you were asked twice, once by Jon Longman and once by

Jarnail Singh, explicitly to mention any known problems
with the Horizon system. Why on both occasions have you
applied a restrictive approach, rather than simply
mentioning all of the problems that you were aware of?
That was not how I'd understood the question but

I accept now that I'd misunderstood the question.

Or was it an unwillingness to reveal known problems with

Horizon system?
113

be authorised by a user of the Horizon system who is
taking responsibility for the impact that such
a transaction has on the branch's accounts."

Then this:

"There are no cases where external systems can
manipulate the branch's account without the users in
branch being aware of what is happening and authorising
the transactions."

That's not correct, is it?
I was referring to the transaction corrections and
external systems.

You don't say that, do you?

I do say that external systems cannot manipulate the
branch accounts, and the context of the question that

I was referring to was to do with transaction

corrections, and that's how I was understanding the
scope of it.

The month previously, you had been present on a call or
calls where, when discussing the receipts and payments
mismatch bug, a solution was alteration of figures at
accounts, at branch level, the local branch accounts.
That was rejected because it would be done without the
subpostmaster knowing about it and it therefore lacked
integrity.

I don't think that was the only reason it was rejected.
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I think it was a case of me misunderstanding the
question.

Can I turn to the topic of your knowledge of remote
access before Seema Misra's trial by looking at
FUJ00083737.

This is, I think, your fifth witness statement,
dated 8 October 2010. If we go forwards, please, to
page 8, and if we scroll down, please. Thank you. Just
back up again, so we get the whole of that paragraph.
Thank you. You say:

"... in section 1.2.3 [that's of Professor
McLachlan's report] there is the hypothesis that
‘External systems across the wider Post Office operating
environment provide incorrect externally entered
information to the Horizon accounts through system or
operator error outside Horizon’.”

You say:

"I was not quite clear what Professor McLachlan was
referring to here. In the updated version of the report
[he] has clarified this by adding ‘For example,
incorrect transaction corrections are submitted from the
central systems for acceptance by the subpostmaster’."

You continue:

"However in my view this is not really relevant

since any transaction that is recorded on Horizon must
114

I think it was rejected because it was a complicated way
of doing things and it was much simpler to do things at
the back end system.

But didn't that make it clear that external systems

could manipulate the branch's accounts without the user
being aware?

I wouldn't have called that external systems and
manipulating accounts. That would have been a specific
code change made to actually change the accounts, and it
was not something that I would have been in favour of,
and that didn't happen.

So wouldn't a full answer here have been, "There are
facilities for remote access that I've known about since

[I think you said yesterday] 2000 which are, in my view,
theoretically available to alter branches’ accounts. My
understanding is they are used infrequently but that
facility is there"?

I'd not understood that as being part of the question.

I thought we were talking about business as usual --

I think, in my fourth witness statement, I talk about
business remote access, and that was the context that

I was taking this discussion to be in.

Did you, in any of your witness statements, disclose the
other forms of remote access that were possible?

I didn't think they were relevant.
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Q. Why did you think they were not relevant?

A. Because I did not think that those had taken place in
West Byfleet.

Q. Therefore, there was no necessity to tell the defence or
the court about the facility for Fujitsu remotely to
alter branch accounts without a subpostmaster's
knowledge?

A. That was where I was coming from.

MR BEER: Thank you.

Sir, I wonder if we could take the break there.
We're about to change topic.

SIR WYN WILLIAMS: Yes.

MR BEER: Until 1.55, please. Thank you very much.

(1.07 pm)

(The Short Adjournment)

(1.55 pm)

MR BEER: Thank you, sir.

Mr Jenkins, good afternoon.

A. Good afternoon.

Q. Can we turn to the issue of hardware failures at the
West Byfleet branch. Can we start by looking at
FUJ00083737. This is your witness statement of
8 October 2010. Can we turn to page 4, please. At the
top of the page you say:

“I understand there is a suggestion that the
117

Q. What was Mr Dunks’ job?

He was part of the Security Team.

Q. Had he got any expertise in the functioning of equipment
within branches, to your knowledge?

A. I thought that he was experienced in analysing Helpdesk
calls.

>

Q. Experienced in - what, good at reading?
Yes.

oP

Can we turn to some of the Helpdesk calls then, please.

POL00061793. Do you recognise these as being the logs

from the Helpdesk for the branch?

I recognise them as being that now, yes.

Did you examine them at the time?

No, I did not.

You've said in your witness statement, "I am not aware

of any fundamental issues", ie with equipment in the

branch. How were you able to say that you were not
aware of any fundamental issues?

A. Because I'd read Mr Dunks’ witness statement.

Q. Did anyone suggest that that was an appropriate thing to
do, in answer to a question or a suggestion that there
was faulty equipment in the branch, you would read
somebody else's witness statement who said they'd read
the logs, and therefore you form a qualitative

conclusion that there weren't fundamental issues?
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equipment in the branch might be faulty. I am not aware
of any fundamental issues though this being covered by
Mr Dunks. Specifically, in his witness statement he
states that ‘All the calls are of a routine nature and

do not fall outside the normal working parameters of the
system or would affect the working order of the
counters'.”

By saying that, are you saying that you agreed with
him that all of the calls were of a routine nature, that
they didn't fall outside the normal working parameters
of the system or they wouldn't affect the working order
of the counters?

No, just quoting what he had said.

What was the purpose of quoting him?

I was really referring that to his level of expertise
rather than mine.

What expertise did he have in the malfunctioning of
equipment within branches?

Well, he had been examining the Helpdesk calls.
What --

And that's really what I -- that's really what -- he --

I believed that he had an understanding of what were
routine calls and, therefore, I was believing -- if he
said that they were of a routine nature, I was believing

what he said.
118

No one has suggested to me that that was inappropriate.
You just did that yourself?

Yes.

Did it occur to you that, in order to give evidence to

a court as to whether or not there were fundamental
issues with equipment in the branch, you should actually
look to see whether there was evidence of fundamental
issues with equipment in the branch?

That was outside my area of expertise.

Why didn't you answer the question, "I understand
there's an issue with or a suggestion that the equipment
in the branch is faulty, or might be faulty. That's

outside my area of expertise”, full stop?

I was just referring to Mr Dunks, who I thought had done
that sort of analysis.

Yes, but you allied with it, didn't you, by mentioning

it, by quoting from it and saying, "I'm not aware of any
fundamental issues"?

I'd not seen it that way at the time.

Do you see it that way now?

Potentially.

If we look at some of these Helpdesk records, then
please. Can we look at page 37, please, at the bottom.
If we just go to the bottom of the page, thank you,

I think this is a record of a report on 2 May. Do you
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see "Opened and closed", 2 May on the middle of the
page, that's it. Thank you.

Yes.

The "Problem" text is:

"Critical Alert Received ... at [then there's a date
and a time]. Event description: A fatal error has
occurred. A corrupt storage unit was detected on volume
%1 with LPN %2. Unit type %3 ... The message store will
be shut down abnormally."

Can you see that?

I can.

Can you help us as to what that is?

That is sounding like a hardware problem on the disk at
that time but that was out of hours but I don't think
that would have caused any problem to the branch
accounts because that would mean that Riposte just
wouldn't be able to function. So the counter would
effectively be dead, until either the message store was
deleted and recreated or the base unit swapped.

So a corrupt storage unit at the branch being detected
and the message store was going to be shut down
abnormally?

Yes.

If we go to the top of page 40, please, do you see the

entry at the very top:
121

system?
I believe so.
Can we look at page 40 --
Again, I'm not aware of what was normal. I was relying
‘on Mr Dunks knowing what was normal.
Did you know how he knew or not knew what was normal?
No, but the fact that he was saying it was normal,
I took his word for it.
Thank you. If we scroll down the page, please, and look
for the entry at, thank you. It looks, at 13.03, as if
an engineer arrived, and then the third entry of 13.03,
the one above that, please, "Engineer swapped ADSL
cable"; can you see that?
Yes.
Then if we look, please, at page 41, the same day, can
we see a further record of a call:

"Critical NT event [this is under ‘Problem Text']
Riposte Error ... The ... server is unavailable.”

Can you see that?
Yes, I can see that.
Then, under the call activity log, "New call taken by
David Sweetlove", and then the substance of the message
again. So it looks like, continuing on the same day,
there is still a problem, doesn't there?

Yes, whether it's the same problem or a different one.
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"BASE UNIT SWAPS 'Warning!! Do not change the
mirror disk and PC together -- if you are in doubt
contact SMC or HIT’. ‘Please can engineer print balance
snapshot and contact SMC to synchronise message store
before swapping out the base unit'."

Can you help us, what does that mean?
The simple answer is I don't know. That looks like some
sort of instruction to the engineers as to what they
need to do.
To print a balance snapshot and then synchronise the
message store: why would that be necessary?
I think it is to do with the case of where there's
a single-counter branch, where there is only one counter
with what's called a mirror disk, removable hardware
drive, and what's supposed to happen in those cases is
that the removable drive is supposed to put into the new
counter --
This was a multiple counter branch though?
So, therefore, I don't think that's relevant to a branch
like West Byfleet, which had more than one counter.
Do you know why it would be recorded on a Helpdesk call
log?
No idea.
Is what we've read so far evidence that nothing happened

that fell outside the normal working parameters of the
122

The other one was to do with a comms cable. This is to
do with the a problem with the background process.

Are they unrelated?

I don't think so but I don't know.

‘Again, would you be able to say whether this is evidence
of something falling within or outside the normal

working parameters of the system?

From my experience, I wouldn't be able to tell one way

or the other.

It seems, over the next few pages -- I'm not going to

read them all in the interests of time -- but the base

unit was replaced because Mrs Misra's screen had frozen
on an error message which said, "Please wait whilst the
desktop connects to Riposte" and successive reboots had
failed to rectify the problem. Would that be the system
working within or outside its normal parameters?
Certainly, base units did fail occasionally and

therefore I would see that as being a normal sort of
‘occurrence.

Would you want to check data that happened at about that
time to see whether it was affect by the failure of the
base unit?

I didn't have data for that period. I was focusing my
attention on the time that I'd been asked to look at,

which was December 2006 to December 2007, and this was
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before that time.

Do you know why you didn't have data for the period of
the indictment, which was about two and a half years,
for the theft count?

The Post Office had -- I know now that Post Office had
decided that on the grounds of costs but, at the time
then, I just knew that I'd been asked to look at data

for that period of 13 months.

One thing you'd want to do if you were examining these
records is correlate the problems that are shown in the
Helpdesk to the transaction data to see whether there
was any connection between the two?

I realise now that that is something that I should have
done. At the time, I was not aware that I needed to
look at the Helpdesk calls and correlate them against
the message store.

In your witness statement, you had said, we saw,

"I understand there is a suggestion that equipment in
the branch might be faulty, I'm not aware of any
fundamental issues, it's being covered by Mr Dunks".
Did I not occur to you, “I need, on the one hand, the
Helpdesk data or the logs and, on the other, the
underlying data to correlate them and I've got neither"?
I realise that now but I didn't at the time.

Are you aware of any discussion within Fujitsu as to
125

including where a base unit replacement was necessary
because the counter kept turning itself off in the

course of transactions, your answer would be the same:
you were relying on Mr Dunks; is that right?

I think so, yes.

Did you consider the possibility that, on any one of the
‘occasions where the engineer was replacing hardware,
they may have failed to take necessary steps to
synchronise the message store?

I didn't consider that.

That would be problematic, if they failed to do that,
wouldn't it?

But it would also probably have been very obvious at the
time.

On the data that you didn't have and therefore couldn't
analyse?

Yes.

So, in answer to the question, what did you do to
respond to the suggestion that hardware faults at branch
were persistent and affected balancing, is that you
relied on reading Mr Dunks' statement?

Yes.

Thank you. Can I turn the investigations into

shortfalls at West Byfleet by looking at the transcript

POL00029406. Again, this is the transcript we looked at
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whether that would have been the appropriate response to
the suggestion of faulty hardware on a continuing basis
within the West Byfleet branch: you need to do both of
those two things?

I'm not aware of any such discussion.

Can we turn to page 45 a few weeks later. This 17 June
2006, page 45. If we scroll down. 17 June, new call
taken, this is under the "Call Activity Log". Thank

you:

"... the online services are down, PM has
Do you know what that abbreviation means?
No, is the simple answer.
It looks like she was being told to reboot; is that sort
of turning on and off again?
Yes.
If this was the same error messages as Mrs Misra had
previously received, would that be evidence of the
system working within or outside its normal parameters?
I think it was expected to be normal that you would get
occasional hardware failures in branches. I have had no
experience of the -- of how often they occurred, and
I was happy to rely on the fact that Andy Dunks had said
that the hardware failures in this branch were normal.
If I carried on pointing out reports of hardware:

failures in the branch going right up to December 2006,
126

earlier. Can we look at page 58, please, at D, thank
you. This is Mr Tatford asking you questions. He asks
you:
... have you -- in your analysis of these just
under half a million transactions, have you seen any
sign, even the slightest symptom of any computer fault?
“Answer: No, but then I've been doing very sort of
high level rough analysis on the stuff. But to find --
to do any detailed investigation you need to have some
sort of idea about a fault happened at that particular
time."
That was a reference to the ARQ data, the half
a million transactions, wasn't it?
Yes.
I think you knew and you realised that the Post Office
had only authorised the extraction of ARQ data for the
period of the 1 December 2006 until 31 December 2007, so
13 months?
Yes.
The indictment period, did you understand, was the
29 June 2005 until 14 January 2008, in relation to the
theft count, so a period of about two and half a years?
I think I may have seen that sometime but, as far as
I was concerned, the only data I had to analyse was for

the limited period.
128

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Did you clock, did you realise, I've got data for only
about half the relevant period for the theft?

That was the data I was given and that was the data
I was asked to look at.

But did you at the time realise --

And I think I made that clear that that was the period
I had -- I thought it was well known that that was the
data that I had to look at and, therefore, the only data
I could comment on.

Did it strike you as incomplete, in the sense that it
didn't match the period of the theft charge?

That was what I'd been asked to look at.

You say here:

".., I've been doing very sort of high level rough
analysis on the stuff ... to do any detailed
investigation, you need to have some sort of idea about
a fault happened at that particular time.”

So do I understand this to be what you were saying:
although you say that there would be evidence of faults
in the data, you did not conduct any analysis to try and
locate such faults in the data because you didn't have
a data range to narrow down the search.

The data that I had was -- it wasn't really possible to
do that because I was trying to correlate the cash

movements against the cash declarations, and they just
129

might have been happening at a particular time?

“Answer: Other than the Callendar Square problem,
no."

Would you agree that that approach really throws the
burden onto the defence for coming up with suggestions
as to what to look for, and then only then would you be
able to search through the 500,000 transactions.

Yes, and I think I'd indicated that in some of the

emails that I exchanged with Jarnail Singh earlier in

the year.

"We need the defendant to identify where the particular
fault is before I can look for the particular fault";

that's what you were saying?

I suppose so, yes.

But Fujitsu did keep PinlICLs, PEAKs and KELs, didn't it?
Yes.

Could you not have used those in the indictment period
for two-and-a-half years to find out what other known
faults were in play during the relevant time?

I think I did look for whether there were PinICLs
associated with that branch.

Yes, not PinICLs associated with that branch, PinICLs or
PEAKs or KELs that identified known faults that were in
play, which were in evidence, during the time that the

theft was alleged to have taken place? You could use
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didn't correlate and, therefore, I wasn't able to track
down where losses had actually happened to investigate
in detail.
So the answer --
And that's really what I was trying to say there.
Sorry?
And that's what I was trying to say with that answer
there.
So the "No, but", the "but" is very important, because
you're saying, "I actually haven't been able to do any
real investigation because I need to know when the fault
is supposed to have occurred, so that I can use that
information to narrow of the search down and look in
this half a million transactions"?
Yes, yes.
Had Fujitsu developed any sort of knowledge bank about
the kind of events or patterns that you could do
searches on in order to identify evidence of known
faults?
I don't know.
None to your knowledge?
I can't think of any at the moment.
The questioning continues:

"Have you been given any information at all from

Professor McLachlan as to any particular fault that
130

that as a narrowing tool, couldn't you?

I realise that now. I didn't think of it at the time.

Isn't that a straightforward or an obvious approach,
rather than saying, "It's up to you, defendant, to tell

me where to look in my system for faults, I've got,

a Knowledge Base which identifies faults, I'll use that

to look in the data"?

When you put it that way, I realise that now, but that
was not the way I was thinking at the time.

That would have given you, even on the limited 13 months
that you were given, a clue or ideas as to what to look
for in the ARQ data, wouldn't it?

I understand that now.

But what you were saying is that there was too much data
to do any detailed investigation, the only thing that's
been suggested is Callendar Square, which they knew
about because of Lee Castleton's case, "That's the only
thing that I've got to go on"?

That's what I am saying, yes.

Those things, the PinICLs, PEAKs and KELs, they would
have given you an idea what to look for in the ARQ data
but the defence couldn't do that, could they, because
they didn't have the PinICLs, PEAKs or KELs, did they?
That's true.

Do you know that Professor McLachlan repeatedly asked
132

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for disclosure of what he called Fujitsu's records of
known faults?

I'm aware that he asked for that, yes.

That had been repeatedly denied him, that request,
hadn't it?

Post Office had decided not to meet that -- respond to
that request.

So the very tool, if the burden was going to be thrust
‘on to the defence, that might have enabled the defence
expert to carry out the task that didn't occur to you,
that was denied them, as well, wasn't it, by the Post
Office?

Yes.

Was there any prohibition or nervousness or ban on
revealing the existence of the Known Error Log in legal
proceedings, that you're aware of?

Not that I'm aware of. I certainly discussed the
existence of it with Professor McLachlan.

Is that why he was asking for it, do you think?

It could well be. After we had a -- I think it was

shortly after a meeting I had with him that he actually
requested that sort of information from Post Office.

Did you form a view about the denial of that material to
him?

I didn't think that it would actually help him a lot but
133

forwards, please, and look at the bottom of the page,
a call on 20 February 2006 at 10.42. It's opened at
10.42 and closed two minutes later. If you look at the
text, the caller, on the left, is Mrs Misra --
Yes.
It says "Mrs Seema" but it's Mrs Misra.
Yes.
The problem is recorded as:

"[Postmistress] states that showing £6,000 down from
balance ..."

Yes?
I see that, yes.
Then text underneath it, "Call closed". So two minutes
after the call, after Mrs Misra says that the system is
showing £6,000 down from balance, she's told it's
an NBSC issue.
I see that, yes.
Then if we scroll down, please. 10.45, can you see
that, the next call record?
Yes.
Mrs Misra again, this one is closed down in three
minutes:

"[Postmistress] states that showing £6,000 down from
balance. Advised [it's an] NBSC issue. [Postmistress]

stated she was talking to the NBSC and got cut off ..."
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I was prepared to sort of -- if Post Office had come
back and said to give that material for him, then it

wasn't something that I would have been concerned about.
Can we go forward in the transcript to page 59, please.

Mr Tatford asked you, at A:

... if a computer problem led to a problem with the
actual figures on the accounts, would you -- would that
problem manifest itself to the staff at the post
office?"

"Answer: Clearly, if there's a problem in the
accounts then -- and there were losses and things like
that showing, I would expect the staff to be complaining
to the Helpdesk to investigate what's gone on and that
could -- that might trigger an investigation by
ourselves."

That was my understanding of how things were supposed to
work. I now realise that the Post Office Helpdesk

wasn't actually very good at passing things on when they
should have been.

The trouble with the answer, therefore, is that it

assumed that the Helpdesk handled calls as they should,
rather than batting them off?

Yes, that was the assumption I had.

Can we look at some call records, please. At

POL00061793. Page 22, please, and if we scroll
134

Then the fuller text in the next box down:

"call close ... I advised [postmistress] I would put
her through. [Postmistress] was happy with this."

Then scroll down, please -- and keep going. 3.40,
same day, call opened and closed within two minutes.
Seema Misra, the call.

"[Postmistress] states that her system is showing
different values for certain products."

Then if we scroll down, just stop there:

"Call close by Matthew Fry: [postmistress] states
that her system is showing incorrect values.
[Postmistress] transferred."

Next day, the 21:
last couple of weeks they have had problems
with Horizon kit and it is always showing that they are

down in money."

Carrying on:

"Call closed ... she has been advised by the NBSC,
advised [postmistress] to follow this ..."

Just stopping there, I'm not going to go through all
of these, there's a lot of them. Did you access these
call records as part of your work preparing to give
evidence in witness statements and then orally in Seema
Misra's case?

No, I did not.
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Did you therefore not correlate any of this information

with the data in the limited period of the 13 months

that you had?

No, I did not.

I think from your earlier answers, I took that you

didn't know that the Helpdesk was perhaps not as

effective as it should have been, that people were, for

example, continually rerouted to the NBSC?

Yes, well, it was the NBSC, I think, that was

responsible to handle that sort of call but I now

understand that they didn't do it very well.

Does any of this help or hinder us with assessing

Mr Dunks’ statement that all calls are of a routine

nature and don't fall outside the normal working

parameters of the system?

I didn't do that sort of analysis of the calls at the

time. I just took his word for what he had actually said

as the summary.

Do you think you probably should have looked at it

before allying yourself with what Mr Dunks was saying?

With hindsight, I can see that, yes.

I think once the trial started and Mr Dunks was

testifying about the calls, you started make some

enquiries then, didn't you?

I did indeed. He referred to one call that had been
137

"Home", I think that's supposed to say.
if you want to ring me."
Why did the PEAK look interesting?
Because it was one that had been raised to do with

a discrepancy in the branch that had been investigated
by her. So I can't remember now exactly what the PEAK
said. I think she said she did a full investigation and
couldn't find any problem but I was just wondering if
she had anything to add to that.

The "you're still in the clear", presumably, do you mean
by that that she was keen not to give evidence again?

I think that's what that's referring to, yes.

Therefore, you hadn't been asked to get this officially

so there wasn't a prospect of her being dragged into
these proceedings?

Correct, yeah.

The defence didn't have access to the PEAKs, did they?
No, they didn't.

So you had a privileged position in relation to

Fujitsu's records?

Yes.

Did you think at the time that that may give the Post
Office an unfair advantage over the defence?

I don't think I thought it through at the time but

I understand now why you're asking the question and,
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referred through to SSC and Anne Chambers had actually
examined the data for the branch at a particular time.
I think that was sometime in 2006 and I did contact her
to ask if she had any more useful information, and I did
look at the PinICL that was associated with that.
Let's just look at that briefly, FUJ00153395. So this
is in the course of the trial.
Yes.
You're emailing Anne Chambers on 13 October 2010 at
3.15:

“Anne,

“In court today Andy Dunks was asked about all sorts
of Helpdesk calls.

"One of them looked interesting ..."

Then I think that should read "so":

"... [so] I searched PEAK for more info."
Yes.
I think that's the PEAK you attached. There's a pdf at
the top --
I believe so.
-- ending in 673:

"Do you remember anything about it?"

"NB I've not been asked to get this info officially
so you're in the clear still!

"I'm at..."
138

yes, I accept that that wasn't right.

That aside, do you think that whatever had piqued your
interest in the PEAK, you should have discussed it with
Professor McLachlan or at least shown him the document,
together with any information that Anne Chambers gave
you in response to your request to ring her if she
wants.

Again, I realise now that that's what I should have done
but I wasn't aware then that that was something that

I needed to do. I'd not been asked to look into this at
all. I just happened to have picked up listening to

Andy Dunks' evidence that there was this software call
that had come through and, therefore, I thought that

I would do a little bit of digging myself into it, and

no one had asked me to do that, so that's what was.
behind this, to see if it would actually shed any light

of what had been going on.

I think when you came to give evidence, you were
actually asked about Mr Dunks' oral evidence when you
were giving evidence?

I can't remember that at the moment, sorry.

Let's have look. POL00029426, at page 7. If we scroll
down, please, at H:

you are aware, are you, of the witness

statements of Mr Dunks --
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“Answer: Yes, I am."

Then this is Mr Tatford:

"-- who provided a rather exhaustive list of all the
calls to the helpline. Do any of those calls to the
helpline -- I do not know if you heard his evidence
yesterday?

“Answer: Yes, I did indeed.

"Question: Did any of what you have read or of what
you heard yesterday from Mr Dunks, did that cause you
any concern as to your view that there is no evidence of
any computer fault?

“Answer: No, I -- I've not -- I haven't got
Mr Dunks’ experience in examining call logs and things
like that but I was quite happy with his comment that
the level of calls from the branch were typical for
other branches."

Do you think, on reflection, that reply obscured
more than it revealed?
I didn't at the time. I understand now that maybe that
would have been an opportunity to talk about the
conversation -- well, I'm not sure whether I spoke to
Anne or not but, certainly when I looked at the PEAK,
there was nothing there to show that there was actually
a problem at the time and I believe the PEAK showed that

she'd done some examination and not found any faults.
141

Can we look, please, at FUJ00153390, 11 October, which
I think is the second day of trial?
The first day, I think.
The first day?
The first day, yeah.
First day of trial at 7.00 at night.
Yes.
You're sending, essentially, is this right, the NT event
logs?
Yes.
That's because of his requests or focus on Callendar
Square; is that right?
Yes. I think during the trial we'd actually gone
through the event logs on my laptop and he'd asked me
could I send him a copy, so I did so.
You answered some questions about these logs -- if we
look at those in the trial -- as you just said,
POL00029406, at page 67 at C. This is you being asked
questions by Mr Hadrill.

Just scroll up a little bit, so we can see the
question before. Thank you. So at C:

"Questions are asked about Callendar Square and, lo
and behold, you summon up then a third log and it is
called an NT log. Yes?

"Answer: Yes.
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So, therefore, I didn't see the need to mention it in

that sort of context.

But the level or the number of calls, whether or not

that was typical of other branches, was beside the

point, wasn't it?

I thought that what I was saying there was -- I'm not
quite sure what you would have expecting me to say there
because, as I say, I was doing as I'd done in my witness
statement, saying that I thought that Mr Dunks knew
better how many calls would be typical in a branch such
as this.

Well, you say, you don't know what I would have expected
you to say -- and I'm not going to put words into your
mouth -- but something like "I know that hardware faults
can lead to accounting irregularities, one needs to go
through the Helpdesk call records very carefully to look
for those hardware irregularities and then cross-compare
them to the ARQ data, using that as a key to look for
errors. I haven't done that and, in any event, I've

only got 13 months’ of data which is about half the
relevant period”.

I'd not thought it through in that way but, with

hindsight, maybe I should have said something like that.
That would be the complete answer, wouldn't it?

Possibly.
142

"Question: Which you had not bothered looking at
before?

“Answer: I had looked at them before when I was --
produced my statement on what happened in Callendar
Square back in March.

"Question: You had never given Professor McLachlan
the benefit of looking at them?

“Answer: That's true.

“Question: You are compiling a --

“Answer: He hadn't asked me for them.

"Question: Sorry?

“Answer: He hadn't asked me for them. I had passed
on the information from Callendar Square", et cetera.
I think that's just an example of me not understanding
that I had a responsibility for doing any disclosure.

Aside from that, is it right to say that neither you nor
Professor McLachlan had time in the course of the trial

to analyse the data for anything other than the signs of
the Callendar Square bug.

I can't remember exactly what we had. I did give him

the full NT event logs for the full period that had been
provided to me back in February. Back in February, Anne
had done an analysis of the NT events and -- to see
whether there were any problems there, and we hadn't

seen anything that was startling about -- from the NT
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events and now I was sharing these logs with Professor
McLachlan.
You said that the pair of you sat in front of your
laptop in the course of the trial?
I believe so, yes.
Was that searching for, or analysing the data for, signs
of the Callendar Square bug?
That was the main reason that we were looking at things
then, yes.
You and he didn't have time to analyse all of the data
for any signs of bugs?
No, but he was -- as I say, having given him the things,
then he was free to look for anything he wanted and come
back to me with specific questions. I don't believe
that he did so but believe that Mr Hadrill did, as part
of the dialogue here.
Can we go back to page 58, please, just go down to D.
Would you agree this was an important part of your
evidence, between D and G? It's essentially the core of
what you were saying.
Yes, I think so.
The question:

[Has] your analysis of ... just under half
a million transactions ... seen any sign, even the

slightest symptom of any computer fault?
145

I understand that now. I hadn't at the time.
The testimony continues by Mr Tatford asking you:

"No. And, in relation to computer problems, you
have told us at the beginning of your evidence that
a computer problem displays symptoms?"

“Answer: In my experience, yes.

"Question: ... would a computer problem on the
Horizon system display symptoms for the people working
in the post office?

“Answer: Not necessarily for the people working in
the post office but if there were investigations carried
‘on, there would be symptoms in the logs.

“Question: And if a computer problem led with the
actual figures on the accounts ... would that problem
manifest itself to the staff at the post office?

"Answer: Clearly, if there's a problem in the
accounts then -- and there were losses and things like
that showing, I would expect the staff to be complaining
to the Helpdesk to investigate what's gone on and that
could -- that might trigger an investigation by
ourselves."

Do you accept that a complete answer would have
included, "Mrs Misra, I understand, did call the
Helpdesk about shortfalls in her accounts"?

I don't think, at that stage, I was -- yes, I probably
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“Answer: No, but then I've been doing very sort of
high level rough analysis ... to do any detailed

analysis you'd have to have some sort of idea about

a fault happened at that particular time."

"Question: Have you been given any information ...
from Professor McLachlan [about a particular fault]?

“Answer: Other than [Callendar Square], no.

Do you agree that a complete answer would have
included the following: however, Professor McLachlan
hasn't been provided with all of the records that are
available to me"?
I wasn't aware that I needed to say that and, by then,
he had had the information. But, as I say, I didn't
know that he needed -- I didn't know that he hadn't got
it until the Monday.

A complete answer would be, "He has asked for, but has
not been given Fujitsu's records of known errors"?

I didn't know that I needed to say that. I thought he
could have said that himself, if he thought it was
important.

“And that it's possible that if he or I or of both of us

had examined the records for all known faults operative
in the two and a half years of the alleged theft, we

would have had a better idea what to look for in the

500,000 transactions"?
146

would have heard Mr Dunks saying that but I didn't think
that I would have needed to have said that.

"I've investigated an investigation by a member of the
SSC staff and she, Anne Chambers, decided there was no
sign of a system problem and so the call wasn't taken
any further at that stage"; ought you to have disclosed
that?

Looking at that now, maybe. But, at the time, it didn't
occur to me that that was relevant.

A complete answer would be "Professor McLachlan and

I haven't been able to check whether that investigation

by Anne Chambers was adequate because the Horizon data
that we've got begins in December 2006 and, therefore,

it doesn't cover the period of those calls in February
2006"?

Again, I understand that now but I didn't at the time.

A complete answer would be, "I haven't examined the call
logs themselves but, even on what I know from Andrew
Dunks’ evidence, there were numerous calls regarding
hardware failures, which I know from my experience can
lead to accounting irregularities"?

Again, I understand that now but I didn't think of it at

the time.

And a complete answer would be, "I've given, a couple of

days ago, Professor McLachlan the NT event log which
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might help about this possibility but he’s only had it
since the first day of the trial, I've not myself looked
at it for any other signs other than the Callendar
Square bug"?
I think I had looked at the events for anything else
that was unusual back in February.
Okay. What do you mean, "unusual"?
There are some events that you get sort of on a fairly
regular basis, so I was looking for ones that I could
see that would have caused a problem.
Overall, were you untroubled by, and happy with, the
evidence you'd given at trial?
At the time I was. I clearly appreciate now that it
wasn't as good as it should have been but, at the time,
I felt happy with it.
Can we look at FUJ00225196. Look at the second email on
the page from you on 22 October, subject "Court told
postmistress had ‘her fingers in the till":

"Penny, I did a Google search last night and found
this from last week."

It's an article from Surrey Online, essentially
getsurrey.co.uk.
The reason I was interested in that was because it
referred to me as "Professor Jenkins", rather than

Mr Jenkins, and that was the reason I was expressing
149

This was about a couple of years later, yes.
Yes, in October 2012?
Yes.
Can we look, please, at POL00096978. This is from
Mr Singh to you, copied to others.

"Dear Mr Jenkins

"Welcome from your annual leave ..."

I'm going to read this, as I usually do, exactly how
it's written:

and your assistance advice in the past
prosecution cases and I understand you are assisting my
colleagues at present. I need your urgent assist judge
has this morning ordered the prosecution to have the
following report ready to be served within Seven days.
On advise Post Office Limited have appointed one of
their investigators, Helen Rose as Disclosure Officer
dealing with Horizon challenges. She has prepared
a document/spreadsheet detailing all such cases, past
and present, approximately 20 in total, although none
thus far successfully argued in court. Post Office
Limited have been advised to obtain, an experts report
from Fujitsu UK, the Horizon system developers,
confirming the system is robust. Post Office Limited
maintain the system is robust, but in light of adverse

publicity, from legal viewpoint is that defence should
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an interest in there. It was nothing to do with the
actual trial, as such, it was that I had magically
acquired this title of Professor in the article, as
obviously a typo.
You say:

"They don't seem to have updated it yet to add in
the guilty verdict.

"Looks like I've acquired a new title!"
Which is what that last comment was about.
Then if we scroll up:

"Nice one Gareth. Looks like you now have
a sideline of resident expert witness in future Post
Office fraud cases."

Which was indeed the case, wasn't it? You did have
a sideline as resident expert witness?
I did in a few cases.
Did you subsequently pass this on to anyone else, that
you had --
I probably sent it home, so that my wife could see the
article and, again, the reason for that was to do with
the fact that I'd been referred to as a professor.
Thank you. That can come down.

Following your evidence in the Seema Misra case and
the guilty verdict, you were asked to provide a series

of generic witness statements, weren't you?
150

be given opportunity to test the system, should they
still wish to do so, on consideration of our report.

"You will need to consider Disclosure Officers
document/spreadsheet (see attachments) and need to
address in your report the followed issues:

"1) A description of the Horizon system (in laymen's.
terms so that a jury can understand what it is and what
it does).

"2) A declaration that it is yet to be attacked
successfully.

"3) A summary of the basic attacks made on the
system concentrating on any expert reports served in
past cases. If there are none then state that no expert
has yet been found by any defence team civil or criminal
to attack the system (at the moment there seems to be
little more than [gripping] by defendants that the
system must be at fault without saying how).

"4) Plainly, like all accounting systems, there is
room for human error (keying in wrong amounts etc) are
you able to state that innocent human error is unlikely
to produce the types of discrepancies of many thousands
of pounds over many months.

"If you require any further information or wish to
discuss please do not hesitate to contact me."

As far as you're concerned, is this essentially the
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origin of the request for the generic witness statement?
Yes, it is.

You'll see from the top of the page that this was sent

to you on 1 October 2012, and you ended up signing the
generic witness statement on 5 October 2012?

Yes.

So, in a relatively short period of time, and the

message says that this was urgent?

Yes.

The request was framed in a way that the generic witness
statement, as perhaps is obvious from its title, was not
going to address the specifics of any particular case?
Yes.

Did you form a view at the time as to the adequacy of
the instructions that you were being given here?

Not really. It was -- I suppose, a better way to

describe it: it was a typical garbled email from Jarnail
Singh.

Given that it was a "typical garbled email" from Jarnail
Singh, didn't that cause you concern?

I tried to make the best sense of it that I could.

Can we look at your reply, please. POL00096983.
Alittle later that day -- can we just go back, please,

to POL00096978. Yes, that was at 11.04 in the morning.

Let's go back to POL00096983, your reply at 2.10,
153

point for the purposes of grabbing Legacy Horizon and
Horizon Online and the mechanics of their respective
audit trails. As I have explained in my second
statement to this Inquiry, these reports were not

a survey of bugs or other issues which had affected
Horizon and had not been prepared for that purpose."
Yes.

Mr Singh had asked you to prepare a witness statement,
essentially, that said, amongst other things, that the
Horizon system was robust, hadn't he?

I can't remember exactly what he was saying but what
I thought -- I thought this was a good start in terms of
trying to address the robustness of Horizon, yes.

If we just go back, it might not have been a witness
statement. I just want to check that.

He was asking for a report, I think.

A report?

There was a report I produced, which later got turned
into a witness statement.

Okay, so he was asking for a report that addressed,
amongst other things, to confirm that the system was
robust.

So what I -- so the next day I think I did produce

a Word document in the form of a report which covered

what I thought was the scope of what he was asking.
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you say:
"... here are the two existing reports I mentions

It looks like it may have been catching!

A. Yes, sorry. Typing is not one of my strong points.
Q._"... I [mentioned] regarding Horizon and Horizon Online
integrity.

"I'l try and produce a further short report
addressing your specific points below in the next few
days.

"Hopefully that will cover off your requirements.”

So you were sending back the Horizon data integrity
reports about Legacy Horizon and Horizon Online that we
looked at yesterday?

A. Yes.

Q. Why were you sending those back as the answer to his
question, essentially, or part of the answer?

A. Because I thought they were part of the answer to his
question, and they would give him something to be going
‘on with whilst I tried to frame a report addressing the
specifics that he raised.

Q. Can we look at your third witness statement, please, at
paragraph 541, at page 186. You say:

"I provided my two data integrity reports to

Mr Singh ... because I thought they were a good starting
154

Q. Confused as Mr Singh's request might have been, why
didn't you write back and say, "No, I can't just provide
a generic witness statement that's to be used in support
of a prosecution. I can only look at branch-specific
data to examine whether there's evidence of a specific
problem at a specific branch"?

A. I think I had sought guidance from my colleagues within
Fujitsu as to how I should address Mr Singh's request.

Q. Your approach in the past was, "It's all about the
branch, it's not about the system in general"?

A. Yes.

Q. Why wasn't that your reply to him immediately, "I can't
give you a genericised statement. You need to be
looking at individual data which is branch-specific

A. I'd not thought of it that way. I thought I was just
providing a high level overview of how Horizon was.
working in general.

MR BEER: Thank you. If we can stop there and take the
afternoon break until 3.15, please. Thank you very

much.
(2.58 pm)
(A short break)
(3.15 pm)
SIR WYN WILLIAMS: Have you had a sufficient break
Mr Jenkins?
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I think so. I'd like to just get the day over with,
please.

SIR WYN WILLIAMS: Fine.

MR BEER:

>

I'm aiming to finish by 4.00.

Can we look at your third witness statement, please,
at page 184. 534, you're referring to Mr Singh's email,
the one that we looked at before the break.

Yes.
You say:

"[It] didn't mention any specific prosecution, name
any [subpostmaster] defendant or provide any information
about any prosecution that my statement was required
for. I understood that what [Post Office] wanted was
a generic statement that did not go into the specifics
of any case and that responded to the four issues
Mr Singh had set out in his email."

Yes.
Then you say at 535:

"Mr Singh's email
documents ..."

described and attached two

Then you give the references, the second which was
an Excel spreadsheet list interesting number of previous
prosecutions, that's the one ending in 468 --

Yes.

~ sorry, ending in 089.
157

that, so I took it on face value and just didn't
consider it in that much detail.
Okay, and if we go down the page to 537, you say:

"Whilst I understood that Mr Singh wanted a generic
report that did not address the specifics of any given
case and that responded to the four issues he had
identified, I was concerned that I did not know exactly
I how to approach this task.”

I think that's a reference to -- that you made
earlier in your evidence before the break —-

Yes.

-- when you said, "Yes, and I went off to the Fujitsu
lawyers"?

Yes, actually looking at this, it wasn't the lawyers at
this point but it was certainly —

Managers?

-- managers and things, yes.

You say:

"That is why at 11.52 I emailed Peter Thompson (Head
of Customer Services), Howard Pritchard (Head of
Security) and lan Turner (Development Manager and my
boss) copying Pete Newsome and James Davidson, saying
‘help please’ and seeking ‘urgent guidance’."

Can we look at that please, FUJ00156645. Thank you.

This is the email you're referring to.
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Yes.

"[648] was a Word document describing five of those
prosecutions. These five prosecutions [including] two
which I knew about (Rinkfield and West Byfleet).

I didn't know about [any of] the others at the time."

I'm not going to take you to the underlying
documents, to the Excel, but the spreadsheet had 25 or
so branches listed in it where there had been
a prosecution and Horizon issues had been raised. On
that list, Hughie Thomas' branch was not listed.

I can't remember. I'm sorry.

Would you have gone through that list

I would have skimmed through looking for ones that

I recognised and I think I recognised about three or
four of them, something like that. I think I listed

them in the first draft of my report, the ones that

I did recognise.

So you didn't see that the list was incomplete because
it didn't list Hughie Thomas' branch in Wales?

I took it at face value.

I see. Therefore, there was nothing triggered in you
that this list that the Post Office are providing me

with doesn't provide a complete picture of all
prosecutions in which Horizon integrity had been raised?

No, I -- it was presented to me as a list of -- like
158

Yes.
So Jarnail Singh sent the email with the four requests
in it, and you say:

"Help please.

"I've looked through the attachments on Jarnail's
email and it isn't at all clear exactly what he wants.
I suspect he wants a further report explaining why
Horizon integrity is okay. I had hoped that somebody
would have sent him the report I produced ... for Dave
Smith 3 years ago while I was on leave.

"However before I contact Jarnail I need some
guidance as to how this fits into my priorities. Should
I drop everything else and concentrate on [keeping]
Jarnail happy (one extreme) or should I wait for ..."

Is that a change proposal?
Yes, because I could see that this could involve quite a
bit of my work and, therefore, it needed to be paid for
by Post Office.
A change proposal, ie a formal mechanism raising this
work?
Yes.
. to be raised and processed before I start (the
other extreme) or more likely, some in-between course.

"As a matter of courtesy, I would like to get some

kind of response to Jarnail today at least indicating
160

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what we (I) propose to do.

"I'd appreciate some urgent guidance. Until I get
some I shall do nothing further on this other than send
a holding email to Jarnail around 5.00 if I've heard
nothing by then."

So your concern appears to be to secure management
sign-off as to where this sits within your day-to-day
priority -~
Yes.

-- rather than concern with complying with the substance
of the request that was made to you?

At that stage it was really a case of, yes, is there
something I should be doing urgently or not, or should

I be doing at all, even.

You don't question in this, where you're seeking
guidance, the appropriateness of the requests that are
being made to you?

I'd not thought of that but, clearly, it was open for my
management to say that it was inappropriate.

Does that reflect the fact that you didn't see the task

as fundamentally inappropriate, namely providing

a generic witness statement that wasn't branch-specific,
and might be deployed without any reference to

an analysis of underlying data?

I've now realised that was totally inappropriate but
161

couple of days but I can't remember the exact details of
that.
Can we go forward in your witness statement, please, to
page 187. Third witness statement, page 187, and
paragraph 545. You say:

"I understand that the question is being asked in
this Inquiry of why I didn't, in my draft report, refer
to bugs, errors [and] defects which had affected
Horizon. Quite simply, I didn't think [Post Office]
wanted a report which did anything apart from addressing
the four issues Mr Singh had asked me to address. In
terms of Mr Singh's general reference to wanting
a report ‘confirming the system is robust’, my draft
report referred to the components of Horizon that
ensured that the writing and storage of data had
integrity. My belief was that if and when there were
problems in the system, that would be detectable and
leave traces and we would pick those up in any specific
case. My view (and I think this was the common.
understanding in Fujitsu) was that there would be
problems (there always are) but they were spottable and
there were mechanisms to spot and fix them, and all of
these components made the overall system robust."

If that was your state of mind, if that was your

appreciation, did you take any steps to check that all
163

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I didn't at the time.

That's why we don't see you raising that --

Yeah.

~ in this email; is that right?

Yes. I was assuming that he knew what he was doing and
was asking me to do something that was appropriate.
We saw, I think, at 3.10 that day, you sent over the two
Horizon integrity reports?

Yes.

Does that mean that that was essentially the holding
response that you are referring to in the last paragraph
here?

It could be. I can't remember the consequences of what
happened at that time but that was clearly a sort of
holding response.

What assistance, if any, did your managers provide you?
I can't remember. I may have had a conversation with
‘one of them or something in the meantime to agree that
that was something that should be done. I just can't
remember the details.

What about more generally, the plea for help that you
were making in this? I don't think we've got a --

I don't think that I've seen an email responding to that
but I think, later on, some of the Fujitsu lawyers got

involved in the report that I was drafting over the next
162

bugs were being picked up, handled and fixed?

Not at that particular time, no, but I thought that the
processes that we had in place were doing that sort of
thing and I still believe that they did.

You don't reply to Mr Singh by saying, "Look, the system
plainly has bugs but we hope that the system we have in
place works. It doesn't work 100 per cent of the time,

or at least I can't say it does. I can't say anything

more than that, ie that's how the system is designed to
work. I need to check underlying raw data to see
whether or not there is any evidence of a bug, known or
unknown, impacting on the data"?

I didn't think I needed to make a response along those
lines, though I clearly understand with hindsight that
perhaps I should have done.

If we go forward to page 548, please, which is over the
page, you say:

“It appears that there was legal oversight of the
provision of my report at Fujitsu. No one from [Post
Office] or Fujitsu suggested that my report needed to
detail any bugs, errors or defects which had arisen in
Legacy Horizon or Horizon Online. David Jones

That's the lawyer?

Yes.

"... had been involved in Mrs Misra's case, in which he
164

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The Post Office Horizon IT Inquiry

had passed on to [Post Office] my raising the Craigpark
issue (which lawyers in Fujitsu and [Post Office] knew
about anyway). The Callendar Square bug that featured
in Mr Castleton's case and Mrs Misra's case. Mr Singh
was well aware that my approach in Mrs Misra's case was
that the underlying data needed to be considered for any
evidence of a system issue at a particular branch.
I now know that [Post Office's] Criminal Law Team were
aware of the Receipts and Payments Mismatch bug.
Plainly, there was a far greater exchange of information
between Fujitsu and [Post Office] about the problems
that arose from time to time in Horizon than this. But
even in terms of just those individuals dealing with
this request for a report, there was clearly knowledge
within [Post Office] of a number of Horizon-related
problems. No one suggested that these should be
included in the report that [Post Office] had asked me
to produce.”

You say, "No one suggested this should be included
in the report"?
Yes.
Forgive me whilst I take a lozenge.

SIR WYN WILLIAMS: Yes.
MR BEER: This report was going to form the basis of

2

a witness statement that you were in due course to sign?
165

and, therefore, I think there were a number of
opportunities where others who were more knowledgeable
of these things than me to actually suggest that I added
further things in to there, and they didn't suggest that
tome.

Thank you. Now, I think it's right that you prepared

a draft report on 2 October 2012, and then a witness
statement on 5 October 2012, and between those two
events there had been some revisions. One of those
revisions was that somebody had inserted the words

"I understand that my role is to assist the court" in

the opening paragraph of the witness statement?
Correct.

Those words weren't in the draft report that you had
submitted originally back on 2 October?

Correct.

Do you know who inserted them?

I think I've recently understood that it was one of the
lawyers in Cartwright King but I'm not 100 per cent
certain of that.

Did you ask a question about why somebody had written
something into your witness statement that said,

“I understand my role is to assist the court"?

No, it didn’t seem to -- it didn't seem to contradict

anything that I'd said in the report, so I thought it
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I don't think I knew that at this time.

By the time that you signed the witness statement, you
knew that the report that you drafted formed the basis
of that witness statement?

Yes.

That witness statement was going to be backed by

a statement of truth?

And I believed that the report, as it was written, was
true.

Did you not know that the picture was more complex than
was presented in the final draft of your 5 October
generic statement?

I'm not sure what you mean by "more complex".

Well, for example, you didn't include a caveat linking
your limited information on any individual case, or
saying that Horizon was not fault free?

I accept that I did not include those caveats. I didn't
think I needed to, at the time.

This tends to suggest, this paragraph, that you thought
perhaps that it was the responsibility of others to tell
you what qualifications you needed to include in your
report and then witness statement. Is that what you
were intending to say here?

I think I would -- I was seeking guidance. I didn't

receive any guidance to do other than that which I did
166

was just something that needed to be included in it as

a legal document.

You, I think, had had some concerns about both Post
Office's and Fujitsu's management of the prosecution
cases and your requirement to give input into them?

I'm not quite sure --

Taking a step back, by October 2012, you said that their
management of the case was chaotic, the Post Office.
And certainly the subsequent events over the next few
months with this use of the generic statements was even
more chaotic, yes.

By this time, did that concern about their management of
the cases trigger anything in you in thinking why is
somebody adding "! understand my role is to assist the
court"?

No, it didn't. I just assumed everyone -- that others
knew what they were doing.

Did you ask yourself: are there any legal reasons for
including this?

I assumed that the reason it had been added in was it
needed to be done and I couldn't see any harm in it
being included in there.

If we can go back to your witness statement, please,
page 194, paragraph 571. You're dealing with the last

paragraph of your signed witness statement of 5 October
168

(42) Pages 165 - 168
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2012, the generic witness statement, and you say:
"The concluding paragraph of my witness statement
addressed the fourth and final issue."
That's the fourth and final issue in Jarnail Singh's
email of 1 October?
Yes.
"To recap, Mr Singh had asked me to confirm that
innocent human error was unlikely to produce large
discrepancies over a number of months. The wording
I used in response was ...
"In summary I would conclude by saying that I fully
believe that Horizon will accurately record all data
that is submitted to it and correctly account for it.
However, it cannot compensate for any data that is
incorrectly input into it as a result of human error,
lack of training or fraud (and nor can any other
system)'."
By this, were you seeking to imply that Horizon was
both robust and infallible?
I certainly wasn't saying it was infallible.
Were you seeking to imply that it was robust?
I was saying that it would accurately record what had
happened and I believed that it did.
You knew, I think, that the Post Office wanted

statement, to use this statement, to rely on it to show
169

statement, POL00097061. If we scroll down, please.
I should give you the context by looking still further
down. The case of Patel:

“Hi Gareth ..."

This is from Sharron Jennings in the Post Office:

"This is the one that you supplied the expert report
and witness statement for the week before last.
Apologies for not explaining that properly in the
previous email, it was a blanket email for all
witnesses! It is unclear at this stage who will be
required as witnesses and which evidence will be
accepted without the need for attendance. I just
thought if I let everyone know they can pencil it in and
then I can let you know nearer the time.”

Then scroll up.
Well, in fact, if you go further down there, then what
had happened was I'd had this email out of the blue
asking me to reserve some diaries for a court date for
something I'd never heard of before.
Yes.
And that was what I was flagging up here at this point.
Let's look at that, then, if you want to look at it.

I think you accurately summarised it. Keep going.
There's an email from Ms Jennings, saying that Patel is

up for trial at Peterborough Crown Court, yes?
171

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that Horizon was robust. That had been what was said in
Mr Singh's email to you?

I can't remember the exact wording but I'll take your
word for it.

What did you think, then, the purpose of your generic
statement was? What was it going to be used for?

To show that you could rely on the data that was found
in the audit trail from Horizon.

That limited purpose?

And that's what I was trying to say here, yes. And the
description in the statement is primarily about
describing how the audit trail worked and how it was
actually recording the data that had been input into the
system and how it was stored into the audit servers and
retrieved for ARQ data.

What this doesn't do is look at the other side of the

coin and look at instances where Horizon doesn't
accurately record all data because of bugs, errors and
defects in the system, does it?

I am not aware of bugs, errors and defects that stop it
recording things, other than the hardware issues that we
spoke about this morning, and that was already being
referred to in the integrity paper that was associated
with this statement.

Can I turn briefly to look at the use of the generic
170

Yes.
Then you reply further up, saying:
[I don't know anything] I'm not aware of this case

Yes?
Yeah, yeah.
Then she gives that explanation:

"This is the one you supplied the expert report
for", et cetera.
Yeah.
Then further up, please, which is where I want to look
here, your reply:

“Thanks for the clarification. I had not understood
that that related to a specific case."

There, the "that that related to a specific case" --
By that I meant the witness statements.
- ie, the generic witness statements?
The generic witness statements, yes.
So she was saying you supplied a witness statement for
the case of Patel and you're saying, "Well, hold on, I'd
understood that my generic witness statement was not in
relation to a specific case".
Correct. That was my understanding.
Continuing:

"... [thought that was a general statement. If
172

(43) Pages 169 - 172
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I am required to go to court for that, I think I need to
have some more background on the specific case and
exactly what is [required]. I appreciate that is not
covered by my statement, but if I need to be an expert
witness, I need to understand what is happening."

By this time, had you realised that you were
performing the function of an expert witness?
Yes, but without understanding what that really meant.
What did you understand it to mean?
Someone who had good knowledge of how Horizon operated.
This is a slightly different formulation from what we've
seen before, where you are referring to yourself as
an expert witness, isn't it?
A. Yes, because -- well, I knew people had been referring

to me as an expert witness in the past and I now realise

that I just didn't know what an expert witness actually

meant. But I assumed that what I'd -- the function I'd

prop

performed in the past was what was required of me again.
Q. By this time, were you aware that an expert witness had

a special status in legal proceedings?
A. I was aware that there were some differences but

I didn't understand all the legal niceties involved in

such things.
Q. What was the extent of your understanding of the "some

differences"?
173

A. No, I didn't realise there was any link between them.
I do now but I didn't then.

Q. Did you, when the line was inserted in your witness
statement, with you saying to the defence and to the
court that you understood that you owed a duty to the
court, ask anyone, "What duty do I owe to the court?"

A. I just assumed it meant to tell the truth, which is what
I'd do anyway.

Q. Did you question why somebody was inserting something

into your witness statement that was very obvious to you

already?

No, I didn't.

Did you ever ask, “What are these duties that I owe"?

No, I did not.

If you were completely oblivious to the status and

prop

responsibilities of an expert witness, why were you
describing yourself as one?
A. Because that's what other people were describing me as.
‘SIR WYN WILLIAMS: In Mrs Misra’s trial, were you present
throughout the whole time?
A. No, and, in particular, I was only present during the
first week. I never heard the evidence that she gave,
and the first time I saw that was about two or three
years ago, when preparing for ~

SIR WYN WILLIAMS: Yes. So it follows from that that you
175

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Well, for example, I think I was aware that I was
allowed to sit in court and listen to other witnesses,
which I understand a witness of fact was not allowed to
do.

From whom did you gain that understanding?

Because I was asked to do so during Mrs Misra's trial.
Who explained that the reason you were allowed to sit in
was --

I can't remember --

-- because you were being treated as an expert witness?
Yes, but that was all I knew that made it any different
from anyone else, but I didn't really understand the
legal niceties of it, I'm afraid.

Who explained that to you?

I can't remember. Possibly Mr Tatford, I'm not sure; or
it could be Mr Longman. I don't know. I don't think
Jarnail Singh was actually around very much during the
trial.

By this time, 19 October, did you understand that

an expert witness had particular responsibilities?

No, I did not.

Did you draw a link between describing yourself as

an expert witness and the line that had been inserted in
your generic witness statement that you had a duty to

the court?
174

weren't present when the judge summed up to the jury?
No, because that was the second week. I'd gone home
after --

SIR WYN WILLIAMS: That's all right.
MRBEER: You were expressing some concern, in this chain,

that your generic report was being used, was being
deployed, in a specific case?
Yes.
Can we turn forward, please, to POLO0097137 -- can we
scroll down, please, and again, please -- an email from
Rachael Panter to you, under the heading "Horizon expert
report":

"As you may already be aware, your expert report
detailing the reliability of the Horizon system ..."

First of all, did you understand that you had
produced an expert report?
I had produced a report which then got converted into
a generic witness statement.
Did you understand that it was the statement of somebody
who was being treated as an expert witness, or did you
still regard yourself as a witness of fact, or didn't
you make the distinction at all?
I didn't make the distinction. As I say, the first time
I became aware of the duties of an expert witness was in

about 2020/2021, something like that.
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". your expert report detailing the reliability of the
Horizon system ..."

Did you understand that the document you produced
was a document which detailed the reliability of the
Horizon system?
I took that as a description of the document I'd
produced, which I thought was more of a description of
the reliability of the audit data that came out of the
Horizon system, but I didn't quibble about the
difference between those two.

She continues:

"... has been served as evidence in a number of Post
Office cases that are at various stages of the court
process, most of which are listed for trial in the early
part of next year.

“It should be noted that most, if not all cases
raising the Horizon system as an issue, have been
unable/not willing to particularise what specific issues
they may have with the system, and how that shapes the
nature of their defence.

“As we already have your detailed report, I would
like to serve it in each case below ..."

Then six cases are set out:

"Your expert report has already been served in the

Nemesh Patel case. I would like to serve your report in
177

being deployed in individual cases when I've seen none
of the underlying data in any of those cases"?
I think it was -- I sort of took that as read, having
already made that point, admittedly to someone else, and
the pushback was really, "Well, why don't you just get
on with it? You've already got the signed statement,
why do I need to be involved?", because I'd been told
before that I didn't need to be involved. And I also
sought some guidance from management as to the fact that
this had been sprung on me out of the blue.
Can we scroll up, please. We see your reply:

"Can't you use the report I have already sent to
you? There is no mention of the case on the report.”

By that, are you meaning that you could just serve
it times six --
Yes.
-- because it's not a case-specific report; there's no
defendant name in it?
Correct.
Then you say:

"You need to be addressing such requests through
Post Office rather than to myself.”

Then:
there is no commercial cover in place", ie that

there isn't any allocated spend to this?
179

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the remaining cases, and have attached a case summary of
each case listed above so that you may familiarise
yourself with the facts of each case.
Please could you read the case summaries
attached and send 5 original signed and dated copies of
your report to me as soon as possible.”

Did you understand what you were being asked to do
here?
Not really. I think I was just being asked to actually
send her five copies -- signed copies of the statement
and -- as I responded, saying, "Well, why can't you use
the one you've already got?"
This was a month or so after your pushback on the use of
the generic statement in a single case --
Yes.

-- saying that you hadn't seen the underlying data.
No.

You're now being told that it's being used in six cases.
In fact, it had already been served in one.

I think that one was the one that I was already aware
of --

The same?

~yes.

What was your reaction? Did you not think, "Well, hold

on, I'm similarly unhappy that my generic statement is
178

Yes.

Is that right?

Yes, that's right. And I then copied the email to the
people who should have been involved in sorting out
those commercial niceties, and so on.

Penny Thomas and James Davidson?

Yes, and also Jane Owen, who I knew was Penny's
counterpart in Post Office.

So at this point, what was your state of mind, "I've
produced this expert report, as it's described, which is
generic; I've been told that it's been deployed in the
Patel case; I've pushed back against that, saying I've
seen none of the underlying data; and then I'm told it's
being deployed in five other cases, can I provide some
more copies of it"?

I was even more confused because it implied that it had
already been employed in an unspecified number of cases,
so -- in which case, why was I being asked to sign it

five times? So I was just generally confused.

What about the more fundamental issue that you'd raised
beforehand about the appropriateness of using a generic
statement without looking at underlying data?

I thought I'd already made that point and didn't feel

the need to repeat it at this point.

Thank you. That is all I want to ask you about the use
180

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of the generic statement.

Just one last topic before we conclude my questions,
and it concerns the decision not to continue to use you
as a witness in support of Post Office prosecutions.
Okay.

Can you recall what you were told about that?

I can't remember the exact detail. I've covered it in

my witness statement but, basically, it was along the
lines that I was been told that I couldn't be used any
more for some sort of legal reasons, and it was never
explained to me what those reasons were. I now
understand, I think, a bit more of the background but

I didn't find that out until 2020/2021.

I'm going to come to the email in a moment.

Yeah.

Were there any conversations with you explaining why the
Post Office didn't want to use you as an expert witness

in legal proceedings against subpostmasters in the
future?

Not that I can remember, other than the email which

I suspect is the one you're about to show me.

Yes. Can we look, then, at the email, FUJ00156923, and
look at the email at the bottom of the page. We're

a year and a bit on now, December 2013.

I think there had been some emails between myself and
181

But I think his role at this point was as a commercial
manager.

And Pete Newsome?

He was a liaison between Fujitsu and Post Office, and
particularly involved with the prosecution side of

things.

"... met with Post Office lawyers last Friday to discuss
the proposal Post Office have come forward with for

an Independent External Expert review of the integrity
of the Horizon system. In essence, the problem that
Post Office have is that they are being given legal
advice that the ‘rules of evidence’ mean that
submissions which in the past have sufficed to support
prosecutions (namely the input from Gareth Jenkins),
cannot be used in future prosecutions. They are
therefore seeking the view of an external expert who can
warrant that the data they are basing prosecutions upon
has integrity.

"In the meeting, we were successful in moving the
discussion away from a full 'system' review (which would
not achieve their aims and is unworkable in practice) to
focus it on what we are calling the 'Core Audit
Process’. This scope is aligned to the audit we were
intending to do in 2012 and for which we had already

agreed a terms of reference with KPMG."
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21
22
23
24
25

2

27 June 2024

Rachael Panter over the intervening months saying,
"Where are we in terms of are there any more cases
I need to worry about, and diary management?" And I'd
effectively been fobbed off on those.
Exactly so --
But there was nothing to say, "We can't use you
because"; it was just a case of "nothing for you to do".
I haven't gone to those because they don't say anything
of substance and whether or not you're to be used and,
if not, why not.
Yeah, yeah.
3 December 2013, James Davidson to a wide group of
people, including you --
Yes.
-- with the subject "Horizon Integrity Challenges":
"Folks,
"Mike, Pete and myself ..."
Just decoding who that is.
I assume that is Michael Harvey.
And Pete Newsome?
Pete Newsome, I would think, yes, as opposed to Peter
Thompson.
Remind us, Michael Harvey?
He was a lawyer. Well, I think he was a commercial

manager but I believe he was also a qualified lawyer.
182

That was the paper for which you had written some
terms of reference?
Indeed.
"The attached slides describe the Core Audit Process and
sets out a terms of reference for an audit that is
achievable and that we could support. We have made it
clear to Post Office that whilst we will cooperate and
provide access to our experts (in a controlled way) we
reserve the right to challenge any findings of
an external expert. The support will also be chargeable
anda CT..."

What's that?
Commercial Terms. So it's basically a contract between
Fujitsu and the Post Office.
"... is being drafted by myself in parallel. All
content has been reviewed by Mike, Pete, Gareth."

Scroll down:

"Can you review the terms of reference?"

I'm not going to read the rest of it.
Yes.
The first paragraph of that email explains that the
problem that the Post Office has is that they are being
given legal advice that the rules of evidence mean that
the input from you cannot be used in future

prosecutions?
184

(46) Pages 181 - 184
ONOaARWN

The Post Office Horizon IT Inquiry

A. And I took it at face value as that, and I thought that
meant okay, I was off the hook and didn't need to get
involved in any more legal proceedings.

Were you content with that?

Oh, yes.

You were happy not to be involved?

rPOoOPrP.D

Yes, because I preferred to be working on my day job,
which was designing changes to the system, rather than
being involved in prosecutions.

Q. Was that the extent of what you were told as to why you
were no longer the Post Office's expert witness of
choice in their prosecutions?

A. As far as I can remember, yes.

Q. Did they ever tell you about a legal advice that they
had received which concluded, in broad terms, that you
had broken your duties to the court and had given
evidence which was unreliable and, therefore, you could
not be relied on for those reasons?

A. No, I didn't understand any of that until 2020.

MR BEER: Thank you.

Sir, they are the only questions that I ask.

SIR WYN WILLIAMS: = Thank you.

Just on this, the only persons who communicated with
you in this email, they are your fellow employees of
Fujitsu?

185

INDEX
GARETH IDRIS JENKINS (continued) ..

Questioned by MR BEER (continued) ....

187

1
2
3
4
5
6
7
8

9
10
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25

27 June 2024

A. Well, they're more senior than me --

SIR WYN WILLIAMS: More senior, but Fujitsu people?

A. Yes.

SIR WYN WILLIAMS: So the explanation to you came from your
own employers, in effect?

A. Yes, I'm just checking that. As far as -- yes, all
those people there, I think, were Fujitsu people.

‘SIR WYN WILLIAMS: = Right. Did you ever have any direct
reason from Post Office employees as to why you were
going to not be a prosecution witness any more?

A. Not that I can recall.

SIR WYN WILLIAMS: = Right. Fine. Thank you.

MR BEER: Thank you very much indeed, sir. They are the
questions that I ask. I think we're going to start with
Core Participants tomorrow at 9.45.

SIR WYN WILLIAMS: All right. That's it for the day.

(3.57 pm)

(The hearing adjourned until 9.45 am the following day)

186

(47) Pages 185 - 187
MR BEER: [21] 1/7
53/1 53/5 53/7 61/14
61/18 61/22 98/1 98/3]
98/5 98/9 99/24 117/9
117/13 117/17 156/18
157/4 165/24 176/5
185/20 186/13

SIR WYN WILLIAMS:
[23] 1/5 52/22 53/3
53/6 61/17 98/2 98/4
99/12 99/18 99/23
117/12 156/24 157/3
165/23 175/19 175/25
176/4 185/22 186/2
186/4 186/8 186/12
186/16

%

%1 [1] 121/8
%2 [1] 121/8
%3 [1] 121/8

“All [1] 118/4
‘confirming [1]
163/13

"Core [1] 183/22
‘External [1] 114/13
"For [1] 114/20
"help [1] 159/23
"her [1] 149/18
"Horizon [1] 80/21
‘In [1] 169/11
‘integrity’ [1] 54/7
‘It [1] 50/25
‘Please [1] 122/3
"Problem [1] 123/17
‘Receipts [1] 36/9
"Riposte [1] 25/14
‘rules [1] 183/12
"see' [1] 36/5
‘sending’ [1] 36/6
"system' [1] 183/20
‘the [1] 54/4
"urgent [1] 159/23
‘Warning [1] 122/1

169/5

1.07 [1] 117/14
4.2.3 [1] 114/11

1.55 [2] 117/13
117/16

10,000 [1] 82/23
10.42 [2] 135/2 135/3
10.45 [1] 135/18
100 [5] 28/8 28/9
89/1 164/7 167/19
100 per [1] 69/17
11 [2] 53/5 53/6

11 October [1] 143/1
11.04 [1] 153/24
11.15 [1] 61/19
11.25 [4] 61/16
11.26 [1] 61/21
11.52 [1] 159/19

12 [3] 35/17 69/14
80/16

12 February [1] 53/9
12,000 [4] 89/17
12.20 [1] 98/1

12.22 [1] 98/6

12.35 [2] 98/3 98/8
123 [1] 106/16

125 [1] 108/13

13 [5] 125/8 128/18
132/10 137/2 142/20
13 October [1] 138/9
13.03 [2] 123/10
123/11

14 January [1]
128/21

14 October [1]
106/11

15 June [1] 84/16
16 [3] 92/22 93/4
97/14

16.06 [1] 12/21

17 [1] 126/6

17 February [1]
58/12

17 June [1] 126/7
184 [1] 157/6

186 [1] 154/23

187 [2] 163/4 163/4

19 [4] 22/6
"19 October [1]
= 14 [4] 53/5 174/19
~a [1] 97/9 194 [1] 168/24
0 2
04 [1] 38/9 2 May [2] 120/25
089 [1] 157/25 124/11
37. I 2 October [3] 38/2
1 4167/7 167/15

4 April [1] 1/15

1 December [3] 2/21
32/14 128/17

1 February [1]
110/19

1 March [1] 82/14

1 October [2] 153/4

2-4 [1] 10/22
2.10 [1] 153/25
2.46 [1] 20/21
2.58 [1] 156/21
20 [3] 56/6 56/11
151/19

20 February [1]

135/2

2000 [1] 116/14
2005 [2] 36/20
128/21

2006 [14] 24/9 25/20
32/14 33/20 36/23
37/1 124/25 126/7
126/25 128/17 135/2
138/3 148/13 148/15
2006/2007 [1] 61/3
2007 [6] 32/14 33/20
37/1 61/3 124/25
128/17

2008 [3] 1/15 82/22
128/21

2009 [4] 2/2 5/24
36/20 38/2

2010 [23] 10/11 22/8
28/17 30/25 47/7 53/9
58/12 60/9 61/1 61/24
62/1 65/9 81/1 86/5
87/7 88/8 89/13 93/9
103/16 106/11 114/7
117/23 138/9

2012 [8] 151/2 153/4
153/5 167/7 167/8
168/7 169/1 183/24
2013 [2] 181/24
182/12

2018 [1] 88/22

2020 [1] 185/19
2020/2021 [2] 176/25
181/13

2021 [2] 176/25
181/13

2024 [1] 1/1

24 [2] 22/9 136/13
22 [1] 134/25

22 June [1] 65/9

22 October [1]
149/17

23 June [1] 69/3

25 [1] 158/7

25 February [2]
29/23 30/15

26 February [1]
30/25

26 November [1] 2/2
263 [2] 91/7 91/8
26th [1] 32/20

27th June 2024 [1]
1/1

28 September [2]
86/4 91/2

28/29 September [1]
103/16

29 January [2] 36/13
41/14

29 June [1] 128/21
29 September [1]
90/25

29th [1] 69/24

3 December [1]

182/12

3 March [1] 33/14
3.10 [1] 162/7

3.15 [3] 138/10
156/19 156/23

3.40 [1] 136/4

3.50 [1] 10/16

3.57 [1] 186/17

30 [4] 92/23 93/5
93/8 97/5
30/06/2005 [1] 36/20
31 December [2]
32/14 128/17
31/12/2009 [1] 36/20
326 [1] 1/12

369 [1] 108/14

37 [1] 120/23

4

4 March [1] 25/20

4.00 [4] 157/4
40 [2] 121/24 123/3
41 [1] 123/15

45 [2] 126/6 126/7

468 [1] 157/23

5 February [2] 10/16

20/21

5 October [4] 153/5
166/11 167/8 168/25
5.00 [1] 161/4

5.10 [14] 21/13
500,000 [2] 131/7
146/25

521 [1] 1/12

534 [1] 157/6

535 [1] 157/18

537 [4] 159/3

541 [1] 154/23

545 [1] 163/5

548 [1] 164/16

571 [4] 168/24

58 [2] 128/1 145/17

soft] 1344

6

6,000 [3] 135/9

135/15 135/23
60-odd [1] 89/16
60-something [1]
97/16

62 [1] 93/14

64 [1] 93/13
648 [1] 158/2
67 [4] 143/18

673 [1] 138/21

7

7.00 [1] 143/6

73,000 [1] 82/23

76 [1] 69/21
765 [2] 91/7 92/1

8 February [4] 22/7
24/12 43/11 43/14
8 October [2] 114/7
117/23

80 [1] 82/19

864 [1] 91/7

9

9 February [1] 44/9
9.45 [3] 1/2 186/15
186/18

90,000 [1] 82/19
903 [2] 92/23 92/25

AU
abbreviation [1]
126/11

ability [1] 6/10

able [18] 15/10 18/6
29/11 36/5 41/2 83/19I
87/1 94/20 109/24
119/17 121/17 124/5
124/8 130/1 130/10
131/7 148/11 152/20
abnormally [2] 121/9
121/22

about [186] 2/23 3/24
4/4 4/15 5/9 6/2 6/7
6/19 9/6 9/10 9/22
10/2 13/8 14/10 14/10)
16/11 16/23 16/25
17/1 18/17 23/21 24/9)
24/21 24/22 24/25
26/9 28/18 28/19
28/23 28/25 29/8
29/11 29/13 29/15
29/16 31/8 31/23 33/9I
33/12 34/19 35/4 38/2I
38/3 39/18 40/19
41/20 42/4 42/5 42/14
45/6 47/10 47/13
47/19 48/7 49/12
49/15 50/4 50/4 50/17,
50/17 51/24 52/19
52/24 53/13 53/23
55/11 59/5 60/10
60/12 60/21 62/3
62/23 63/25 64/1 64/5
64/9 64/23 64/25
73/19 74/12 75/3
75/10 76/6 76/7 76/11
78/8 78/25 79/13
79/24 82/19 82/23
84/13 84/17 88/15
88/16 89/16 90/2 90/7I
90/19 91/16 93/16
95/4 95/9 95/23 96/2
96/6 96/7 97/16 97/23}
99/10 101/22 102/9
102/24 103/4 104/3

(48) MR BEER: - aboutO
A

about... [71] 105/7
107/24 107/25 108/5
108/7 108/20 108/24
109/8 109/12 110/1
110/3 111/14 111/24
112/6 113/2 115/23
116/13 116/19 116/20
117/5 117/11 124/20
125/3 128/10 128/22
129/2 129/16 130/16
132/17 133/23 134/3
137/23 138/12 138/22)
140/19 141/20 142/20)
143/16 143/22 144/25)
146/3 146/6 147/24
149/1 150/9 151/1
154/13 156/9 156/10
157/12 158/4 158/5
158/14 162/21 165/3
165/11 167/21 168/3
168/12 170/11 170/22)
175/23 176/25 177/9
180/20 180/21 180/25)
181/6 181/21 182/3
185/14
above [5] 32/13
56/15 94/9 123/12
178/2
accept [6] 112/23
113/15 113/23 140/1
147/22 166/17
acceptance [1]
114/22
accepted [1] 171/12
access [11] 22/19
105/18 105/19 105/24
114/4 116/13 116/21
116/24 136/21 139/17)
184/8
according [1] 25/20
account [4] 3/9 67/5
115/6 169/13
accountant [3] 74/4
75/3 75/6
accountant's [1]
73/24
accounting [8] 16/11
22/23 33/8 46/18
98/20 142/15 148/21
152/18
accounts [24] 27/12
44/5 44/6 45/12 45/13
55/13 90/20 105/9
114/15 115/3 115/14
115/21 115/21 116/5
116/8 116/9 116/15
117/6 121/16 134/7
134/11 147/14 147/17)
147/24
accuracy [5] 54/23
55/7 55/17 55/19
55/23

accurate [3] 51/7
57/19 96/6
accurately [11] 19/20)
20/1 20/5 82/4 96/5
96/11 96/13 169/12
169/22 170/18 171/23)
achievable [1] 184/6
achieve [1] 183/21
acknowledgement
[1] 93/18
acquired [2] 150/3
150/8
acronym [1] 87/12
across [4] 89/16
92/11 108/2 114/13
action [5] 45/2 46/24
51/3 51/12 69/14
actions [1] 77/24
activity [6] 3/19 4/16
69/10 69/21 123/21
126/8
actual [7] 19/9 22/16
29/2 106/4 134/7
147/14 150/2
actually [74] 4/18
5/22 8/12 8/25 12/14
17/2 19/17 19/22
27/25 39/17 39/20
42/9 43/9 44/15 45/21
46/5 47/2 49/7 52/25
53/2 53/3 55/21 55/25
57/19 58/6 60/2 60/2
63/12 63/18 64/25
66/20 67/4 67/7 67/8
68/22 72/23 73/1
76/24 82/6 82/10
85/10 89/19 90/5
91/19 91/23 93/25
94/18 95/20 96/5
96/24 105/14 105/22
106/6 107/14 109/25
116/9 120/6 130/2
130/10 133/21 133/25)
134/18 137/17 138/1
140/16 140/19 141/23)
143/13 159/14 167/3
170/13 173/16 174/17)
178/9
add [4] 51/18 71/2
139/9 150/6
added [3] 33/17
167/3 168/20
adding [2] 114/20
168/14
addition [1] 2/15
additional [2] 67/1
70/11
address [8] 60/23
74/21 152/5 153/12
155/13 156/8 159/5
163/11
addressed [7] 3/20
10/19 35/7 35/9 110/1
155/20 169/3

addressing [5] 39/11
154/9 154/20 163/10
179/21

adequacy [1] 153/14

adequate [1] 148/12

adjourned [1] 186/18

Adjournment [1]
117/15

admittedly [1] 179/4

ADSL [1] 123/12

advantage [1] 139/23}

adverse [1] 151/24

advice [10] 13/4 48/9
49/10 49/11 49/13
50/13 151/10 183/12
184/23 185/14

advise [2] 31/10
151/15

advised [9] 1/15 3/17
32/15 48/7 135/24
136/2 136/18 136/19
151/21

affect [9] 25/21 46/16)
52/9 59/17 100/19
109/6 118/6 118/11
124/21

affected [27] 11/18
25/24 29/11 44/5 44/6
55/16 55/23 59/11
60/11 60/15 69/8
80/13 87/25 89/5
90/14 91/21 92/2
103/8 105/22 108/21
108/25 109/12 110/4
111/15 127/20 155/5
163/8

affecting [4] 45/18
51/25 96/23 97/9

afflicted [2] 29/9
83/24

afraid [7] 86/2 93/2
99/11 100/4 103/24
104/1 174/13

after [11] 51/16 58/25)
59/23 76/7 93/17
133/20 133/21 135/14]
135/14 176/3 178/13

afternoon [4] 98/9
117/18 117/19 156/19}

afterwards [1] 6/14

again [29] 1/17 5/3
6/15 7/9 13/15 23/4
31/2 32/4 34/14 49/9
54/14 56/25 73/23
83/3 106/2 114/9
123/4 123/23 124/5
126/14 127/25 135/21
139/11 140/8 148/16
148/22 150/20 173/18
176/10

against [12] 6/8 16/1
31/20 54/8 55/8
103/13 105/10 105/12)
125/15 129/25 180/12)

181/18
agenda [1] 66/14
ago [8] 18/9 69/7
70/5 75/4 93/8 148/25
160/10 175/24
agree [30] 7/3 11/15
15/9 16/22 18/20
19/10 20/7 21/9 27/5
28/3 29/6 35/11 37/2
40/4 45/24 46/7 52/2
52/3 73/9 74/17 86/24)
94/13 102/18 104/2
111/18 112/13 131/4
145/18 146/8 162/18
agreed [10] 12/4 22/2!
22/3 47/1 61/5 76/25
78/10 78/11 118/8
183/25
agreement [1] 100/5
Ah [2] 44/1 91/1
aiming [1] 157/4
aims [1] 183/21
alarmist [1] 51/8
alert [2] 59/2 121/5
aligned [1] 183/23
all [86] 4/4 5/7 7/19
9/19 9/20 9/20 10/1
10/1 12/12 23/15 24/8}
28/19 28/20 34/17
38/8 40/24 42/9 42/15
45/7 49/19 56/2 56/7
61/17 67/2 67/4 67/15)
67/20 68/4 68/9 68/15)
71/5 72/7 73/22 84/2
85/18 88/21 90/13
91/20 92/1 92/12 93/8)
93/14 95/25 97/7 99/8
99/13 99/17 99/20
99/24 102/1 102/5
111/3 111/24 113/21
118/9 124/11 130/24
136/20 137/13 138/12
140/11 141/3 145/10
146/10 146/22 151/18}
152/18 156/9 158/23
160/6 161/14 163/22
163/25 169/12 170/18}
171/9 173/22 174/11
176/4 176/15 176/22
177/16 180/25 184/15}
186/6 186/16
allegation [1] 31/22
allegations [1] 31/20
alleged [8] 19/4
19/15 23/11 31/6
31/10 34/16 131/25
146/23
allied [1] 120/16
allocated [1] 179/25
allow [1] 89/4
allowed [4] 35/3
174/2 174/3 174/7
allying [1] 137/20
almost [1] 67/9

alone [1] 7/23
along [4] 102/10
103/2 164/13 181/8
already [18] 11/1
14/7 85/11 107/17
170/22 175/11 176/13)
177/21 177/24 178/12)
178/19 178/20 179/4
179/6 179/12 180/17
180/23 183/24
Alresford [1] 80/17
alright [1] 10/1
also [31] 2/15 6/24
8/14 11/4 14/21 16/1
25/11 26/15 30/6 30/8
33/19 34/1 34/10 35/4
35/9 36/14 36/18 37/5I
50/14 71/1 74/19 91/7I
94/20 95/1 109/19
1411/8 127/13 179/8
180/7 182/25 184/10
alter [2] 116/15 117/6
alteration [1] 115/20
although [5] 31/15
72/1 89/5 129/19
151/19
altogether [1] 87/18
always [6] 92/9 92/15)
94/4 104/25 136/15
163/21
am [18] 1/2 15/1
32/25 39/2 48/2 59/8
61/19 61/21 91/15
103/3 113/13 118/1
119/15 132/19 141/1
170/20 173/1 186/18
amend [5] 95/1 95/5
95/7 95/12 96/12
amending [1] 95/11
amendments [2]
50/4 51/16
Americanised [1]
53/2
ammunition [1]
103/21
amongst [2] 155/9
155/21
amount [3] 32/2
33/20 72/8
amounts [1] 152/19
analyse [5] 31/17
127/16 128/24 144/18)
145/10
analysed [3] 12/8
12/9 67/19
analysing [2] 119/5
145/6
analysis [29] 12/10
17/11 30/16 33/13
34/2 34/4 37/6 68/9
69/4 70/19 70/21 71/1
71/7 74/24 75/1 75/2
84/2 86/23 120/15
128/4 128/8 129/15

(49) about... - analysisO
A

analysis... [7] 129/20
137/16 144/23 145/23)
146/2 146/3 161/24
Andrew [1] 148/18
Andy [5] 27/25 36/12
126/22 138/12 140/12)
Anne [14] 24/8 24/13
25/4 35/4 37/3 75/4
138/1 138/9 138/11
140/5 141/22 144/22
148/4 148/12

annual [1] 151/7
another [7] 53/14
56/18 56/24 76/4
80/20 81/18 84/15
answer [50] 5/8 5/12
7/11 14/19 15/14
17/16 18/11 18/21
19/10 19/18 19/20
19/23 20/1 20/2 20/4
28/3 28/22 29/4 39/12
40/4 54/21 58/17
60/21 61/10 95/6 99/4
108/2 112/13 113/7
113/12 116/12 119/21
120/10 122/7 126/12
127/3 127/18 130/4
130/7 134/20 142/24
146/8 146/16 147/22
148/10 148/17 148/24}
154/16 154/17 154/18)
answered [5] 10/22
79/15 109/18 111/3
143/16

answering [5] 19/17
39/8 40/10 40/14
107/24

answers [6] 5/1 5/3
12/2 79/8 79/10 137/5)
any [167] 6/1 9/14
10/5 11/5 14/21 15/6
15/7 16/10 18/12
18/22 19/13 19/13
21/21 22/25 23/1 23/6
28/20 30/12 32/19
36/15 38/23 38/25
39/2 39/9 39/12 39/17
40/15 40/19 40/21
40/21 41/4 44/6 45/8
46/2 47/7 52/16 54/8
55/9 55/25 59/10
59/12 59/13 60/16
61/7 61/12 62/23 63/6
64/5 64/6 68/12 70/11
71/7 71/15 71/21 72/3
72/4 76/2 77/14 77/24
78/18 81/22 84/11
88/7 97/4 99/12
101/11 101/12 101/19
102/4 102/5 102/22
105/23 108/17 108/20)
108/25 109/4 109/12

109/20 110/4 111/9
111/14 112/15 113/1
113/8 113/18 114/25
116/23 118/2 119/3
119/16 119/18 120/17,
121/15 125/12 125/19)
125/25 126/5 127/6
128/5 128/6 128/9
129/15 129/20 130/10)
130/16 130/22 130/24}
130/25 132/15 133/14)
137/1 137/12 138/4
139/8 140/5 140/16
141/4 141/8 141/10
141/11 141/25 142/19)
144/15 144/24 145/11
145/24 145/25 146/2
146/5 148/6 149/3
152/12 152/14 152/23)
153/12 157/10 157/11
157/11 157/12 157/15)
158/5 159/5 161/23
162/16 163/18 163/25)
164/11 164/21 165/6
166/15 166/25 168/18)
168/21 169/14 169/16)
174/11 175/1 179/2
179/25 181/9 181/16
182/2 184/9 185/3
185/19 186/8 186/10
anyone [10] 4/10
29/16 34/11 64/14
102/10 108/18 119/20)
150/17 174/12 175/6
anything [31] 2/23
3/24 6/18 7/16 24/22
34/20 40/19 46/9
47/13 47/19 48/16
50/17 58/2 71/2 77/19)
81/8 96/3 102/10
112/6 138/22 139/9
144/18 144/25 145/13)
149/5 163/10 164/8
167/25 168/13 172/3
182/8

anyway [4] 25/19
7717 165/3 175/8
anywhere [3] 45/19
64/7 79/25

apart [7] 72/5 72/23
96/17 96/17 96/19
97/17 163/10
Apologies [2] 96/19
171/18

apologise [3] 29/25
81/5 83/4

apparently [1] 21/1
appeared [1] 98/18
appears [6] 37/13
51/25 83/6 88/14
161/6 164/18
application [2] 27/7
67/12

applied [2] 8/21

113/20
apply [4] 42/13 42/15
85/10 108/2
appointed [1] 151/15
appreciate [5] 37/19
37/20 149/13 161/2
173/3
appreciation [1]
163/25
approach [12] 46/1
54/25 76/1 78/6 83/19)
91/18 113/20 131/4
132/3 156/9 159/8
165/5
approached [1] 3/25
approaches [1] 19/7
appropriate [3]
119/20 126/1 162/6
appropriately [4]
39/2 39/14 40/22
40/25
appropriateness [2]
161/16 180/21
approximately [1]
151/19
April [1] 1/15
ARC [1] 68/10
are [111] 2/12 5/2 5/3
5/5 7/12 11/5 11/6
14/21 14/22 18/13
18/23 19/8 19/12
25/16 26/22 29/22
31/16 36/12 36/15
37/24 38/3 39/10 40/5
42/17 43/13 43/15
43/21 48/10 49/16
54/5 54/5 62/16 62/18
67/7 67/8 67/15 67/17
69/6 69/23 70/14
70/15 71/4 71/9 71/16
80/2 82/6 82/7 90/1
90/2 91/9 91/22 94/21
94/23 101/2 104/19
106/21 107/6 108/4
108/23 109/20 109/21
111/9 111/10 112/16
113/1 113/2 114/21
115/5 116/12 116/14
116/16 118/4 118/8
122/2 124/3 125/10
125/25 126/10 136/15}
137/13 140/24 140/24
143/22 144/9 146/10
149/8 151/11 152/13
152/19 154/2 158/22
161/16 162/11 163/21
168/18 173/12 175/13}
177/13 177/14 177/23
179/14 182/2 182/2
183/11 183/15 183/17
183/22 184/22 185/21
185/24 186/13
area [4] 63/3 77/14
120/9 120/13

aren't [3] 28/9 47/21
67/7

argued [2] 103/12
151/20

arisen [1] 164/21
arising [1] 27/9
arose [2] 55/15
165/12

around [9] 25/20
62/22 64/2 87/5 88/8
89/12 105/7 161/4
174/17

ARQ [40] 15/11 15/19)
15/24 16/8 18/7 18/10}
20/3 28/6 28/11 33/24
34/2 34/5 35/2 63/1
63/5 63/8 63/16 63/20)
63/23 65/3 65/10
65/12 65/17 65/25
66/1 67/11 67/20
67/21 68/6 68/8 68/19)
73/8 87/18 101/10
128/12 128/16 132/12)
132/21 142/18 170/15}
ARQs [7] 63/3 69/8
69/8 69/12 69/14
69/19 69/20

arrived [1] 123/11
article [4] 82/25
149/21 150/3 150/20
as [242]

ASAP [1] 87/4
ascertain [2] 87/3
90/13

aside [3] 12/9 140/2
144/16

ask [22] 3/18 3/25
4/22 11/17 11/20
12/17 42/14 48/21
49/9 68/7 76/14 86/19)
91/8 108/19 138/4
167/21 168/18 175/6
175/13 180/25 185/21
186/14

asked [81] 2/10 5/17
6/16 6/20 7/9 7/12
7/18 7/21 8/11 9/3
9/19 11/1 16/24 18/19)
21/20 24/18 24/21
24/24 26/2 26/9 26/21
26/24 28/4 28/17
28/21 28/24 29/3
40/19 76/7 76/10
76/25 78/8 78/12
79/15 89/6 106/19
107/6 108/4 108/9
108/24 109/2 109/11
109/22 110/3 110/11
111/13 111/15 111/18}
111/23 111/25 113/1
113/17 124/24 125/7
129/4 129/12 132/25
133/3 134/5 138/12
138/23 139/13 140/10

140/15 140/19 143/14I
143/18 143/22 144/10)
144/12 146/16 150/24)
155/8 163/6 163/11
165/17 169/7 174/6
178/7 178/9 180/18
asking [16] 5/16 14/8
19/20 26/5 32/5 32/6
78/22 128/2 133/19
139/25 147/2 155/16
155/20 155/25 162/6
171/18

asks [4] 11/21 25/8
70/10 128/2

aspects [2] 101/15
103/5

assert [1] 41/3
asserting [1] 37/16
assertions [1] 37/3
assessing [1] 137/12
assist [4] 151/12
167/11 167/23 168/14)
assistance [3] 5/18
151/10 162/16
assisting [1] 151/11
associated [8] 36/19
62/24 63/6 64/1
131/21 131/22 138/5
170/23

assume [3] 49/2 61/4
182/19

assumed [8] 23/15
60/23 112/23 134/21
168/16 168/20 173/17)
175/7

assuming [7] 5/12
59/1 59/7 59/8 69/16
74/10 162/5
assumption [3]

71/21 85/19 134/23
assumptions [1]

7N9

assurance [1] 54/9
at [392]

at page 2 [1] 73/16
at page 3 [1] 32/8

at page 41 [1] 123/15
at page 7 [1] 140/22
attach [2] 2/8 73/25
attached [6] 86/8
138/18 157/19 178/1
178/5 184/4

attaches [1] 3/23
attaching [1] 86/15
attachments [3] 2/22
152/4 160/5

attack [1] 152/15
attacked [1] 152/9
attacks [1] 152/11
attempting [1] 36/7
attendance [1]
171/12

attendee [1] 98/14
attention [4] 64/4

(60) analysis... - attentionO
A

attention... [3] 85/4
85/7 124/24
attribute [1] 113/11
audit [17] 44/13
65/15 65/16 66/4
69/23 70/15 70/19
82/22 155/3 170/8
170/12 170/14 177/8
183/22 183/23 184/4
184/5
auditors [1] 44/16
authored [2] 65/7
90/19
authorised [2] 115/1
128/16
authorising [1] 115/7
automated [1] 58/22
available [6] 36/16
69/24 87/19 105/18
116/15 146/11
Avenue [7] 67/17
69/16 71/24 73/20
74/8 76/8 76/9
avoid [5] 95/3 95/8
95/22 96/1 97/22
avoiding [1] 96/8
aware [70] 11/6
11/25 13/7 14/22 15/1
15/17 16/10 17/11
17/13 17/14 17/22
18/13 18/23 19/12
27/24 30/11 31/21
31/23 35/14 38/8 39/2
39/10 42/9 50/18
54/25 55/24 72/8
74/19 85/16 93/21
97/12 101/19 102/4
109/6 109/21 111/10
112/8 112/16 112/19
113/2 113/8 113/13
113/21 115/7 116/6
118/1 119/15 119/18
120/17 123/4 125/14
125/19 125/25 126/5
133/3 133/16 133/17
140/9 140/24 146/12
165/5 165/9 170/20
172/3 173/19 173/21
174/1 176/13 176/24
178/20
away [7] 58/24 80/21
81/13 81/20 82/5 84/7
183/20
awful [1] 49/7

B

back [47] 1/14 24/11
24/19 27/19 30/2 37/7
37/19 59/9 63/9 67/10
67/22 70/9 72/10
83/15 93/7 93/8 93/9
94/19 97/6 98/11

101/10 101/10 104/14)
105/1 105/15 106/6
109/13 110/24 114/9
116/3 134/2 144/5
144/22 144/22 145/14)
145/17 149/6 153/23
153/25 154/12 154/16)
155/14 156/2 167/15
168/7 168/23 180/12
back-end [1] 94/19
backed [1] 166/6
background [6] 5/14
6/2 6/7 124/2 173/2
181/12
backward [1] 97/5
bad [3] 17/1 17/2
95/20
badly [2] 25/24 95/16
balance [9] 36/15
56/24 57/1 57/7 122/3
122/10 135/10 135/15)
135/24
balanced [2] 36/11
98/18
balances [1] 53/14
balancing [2] 107/3
127/20
ban [1] 133/14
bandwagon [4] 83/2
83/6 83/25 84/5
bank [1] 130/16
barrister [3] 2/10
12/20 106/20
base [8] 121/19
122/1 122/5 124/11
124/17 124/22 127/1
132/6
based [4] 37/3 54/18
85/18 88/21
basic [1] 152/11
basically [10] 15/12
48/1 62/8 64/12 75/9
75/12 87/13 112/11
181/8 184/13
basing [1] 183/17
basis [5] 23/10 126/2
149/9 165/24 166/3
batting [1] 134/22
be [228]
became [3] 1/14
17/14 176/24
because [94] 4/2
6/16 8/5 8/17 16/14
17/23 18/2 19/7 24/18
26/13 29/17 34/6
34/18 35/14 38/19
39/19 44/5 44/16
45/19 46/10 46/17
46/21 47/3 47/9 47/10
47/22 52/18 57/21
58/23 59/13 59/14
60/4 60/18 63/24 64/7
64/22 68/7 76/1 76/5
76/6 79/20 83/11 85/2

85/5 85/15 85/16
85/22 87/15 89/12
92/5 93/15 93/19
97/18 100/22 103/10
104/20 105/8 105/13
105/20 107/22 115/22
116/1 117/2 119/19
121/16 124/12 127/2
129/21 129/24 130/9
130/11 132/17 132/22
139/4 142/8 143/11
148/12 149/23 154/18
154/25 158/18 160/16
170/18 173/14 174/6
174/10 175/18 176/2
179/7 179/17 180/16
182/7 182/8 185/7
becomes [1] 100/25
been [166] 8/5 10/22
11/1 15/2 16/13 16/14]
16/15 16/17 17/9
18/18 18/25 21/6
21/20 22/25 23/6
24/24 26/6 26/13 28/4
30/11 30/12 31/17
32/5 32/5 32/20 33/7
33/9 33/25 34/6 34/17
35/3 35/13 35/21
36/21 36/22 36/24
39/3 39/21 40/24
45/10 47/3 49/6 50/9
51/17 51/18 51/22
52/1 52/8 52/23 53/1
55/13 55/16 57/22
59/2 61/3 63/7 64/5
64/17 66/25 67/12
67/20 70/14 70/16
71/16 71/21 71/25
73/17 75/19 76/10
76/23 76/25 78/18
83/13 85/17 87/4 88/7
88/13 88/14 89/12
90/6 90/14 91/2 92/7
94/22 97/5 101/3
101/11 105/10 105/23
105/25 106/1 107/11
109/17 109/22 110/1
110/11 111/25 113/6
113/9 115/18 116/8
116/10 116/12 118/19}
124/24 125/7 126/1
127/13 128/7 129/12
129/14 130/10 130/24]
131/1 132/16 133/4
134/3 134/19 136/18
137/7 137/25 138/23
139/4 139/5 139/13
140/10 140/17 141/20
144/21 146/1 146/5
146/10 146/17 148/11
149/14 150/21 151/21
152/14 154/4 155/6
155/14 156/1 158/8
158/9 158/24 164/25

167/9 168/20 170/1
170/13 173/14 174/23}
177/12 177/17 177/24}
178/19 179/7 179/10
180/4 180/11 180/11
180/17 181/9 181/25
182/4 184/16
BEER [3] 1/4 52/22
187/4
before [37] 1/14 4/14
4/15 7/12 27/11 41/12)
41/13 42/9 43/3 45/8
50/9 52/1 57/18 58/19)
58/25 59/23 60/18
89/21 90/8 95/6 114/4
122/5 125/1 131/12
137/20 143/21 144/2
144/3 157/7 159/10
160/11 160/22 171/7
171/19 173/12 179/8
181/2
beforehand [1]
180/21
began [2] 89/8 89/9
beginning [5] 9/16
10/4 24/7 72/1 147/4
begins [1] 148/13
behalf [2] 10/16
79/17
behind [5] 19/8 95/24
95/25 106/7 140/16
behold [1] 143/23
being [96] 6/12 6/16
6/20 7/5 7/18 7/20 8/9
8/11 9/3 9/7 9/7 9/19
29/3 31/10 32/1 33/2
36/5 36/5 43/20 50/4
51/7 51/8 52/7 52/12
52/13 52/15 52/25
53/15 53/25 54/21
54/22 58/8 64/6 65/12
72/13 77/23 81/4 83/5
83/11 87/9 87/16
87/17 87/17 87/23
88/3 88/4 89/4 90/2
96/1 96/17 99/9
101/24 101/25 102/16}
102/22 102/24 103/4
104/25 106/19 108/24,
109/2 109/10 111/23
115/7 116/6 116/18
118/2 119/10 119/12
121/20 124/18 125/20
126/13 139/14 143/18}
153/15 161/17 163/6
164/1 168/22 170/22
174/10 176/6 176/6
176/20 178/7 178/9
178/18 178/18 179/1
180/14 180/18 183/11
184/15 184/22 185/9
belief [7] 39/15 40/23
47/24 82/4 83/24
85/20 163/16

believe [32] 6/3 6/6
18/25 22/13 34/10
34/17 34/18 45/14
48/2 53/19 54/1 58/10)
59/19 63/7 63/18
63/22 70/4 81/11
81/22 81/24 90/24
99/22 104/18 123/2
138/20 141/24 145/5
145/14 145/15 164/4
169/12 182/25
believed [9] 39/19
40/24 77/5 81/11
81/14 82/2 118/22
166/8 169/23
believing [2] 118/23
118/24
below [13] 5/8 10/23
13/13 25/20 33/18
50/21 62/16 80/18
81/5 81/17 110/21
154/9 177/22
benefit [2] 43/7 144/7I
beside [1] 142/4
best [3] 8/10 74/20
153/21
better [6] 75/19
87/21 105/14 142/10
146/24 153/16
between [22] 33/6
36/2 36/25 52/24
53/23 55/10 57/20
70/25 75/23 80/3
88/15 125/12 145/19
160/23 165/11 167/8
174/22 175/1 177/10
181/25 183/4 184/13
big [1] 101/23
bigger [1] 27/9
bit [19] 1/24 3/5 7/7
23/4 28/2 42/2 48/9
50/1 50/12 62/18
63/10 91/9 105/21
105/25 140/14 143/20)
160/17 181/12 181/24)
blame [1] 103/21
blamed [1] 83/25
blaming [2] 81/24
82/5
blanket [1] 1714/9
blocks [2] 17/1 17/2
blow [1] 96/21
blown [1] 98/15
blue [2] 171/17
179/10
body [1] 10/19
bona [1] 69/9
boss [1] 159/22
both [10] 35/7 67/16
70/20 70/23 99/19
113/19 126/3 146/21
168/3 169/19
bothered [1] 144/1
bottom [12] 12/21

(61) attention... - bottomO
B

bottom... [11] 24/11
50/11 91/25 92/21
94/6 98/15 110/19
120/23 120/24 135/1
181/23

box [2] 92/20 136/1
branch [95] 11/18

17/20 19/5 20/17 23/1
23/6 23/11 25/18

29/12 36/11 36/16
36/20 40/2 44/21
44/23 53/14 54/23
55/7 55/11 55/17
55/19 55/23 56/21
58/23 59/11 59/14
59/24 59/25 60/3
60/14 60/25 63/8
66/21 66/22 71/8
80/16 91/18 93/23
94/2 94/22 95/1 98/18
98/21 104/21 104/21
105/6 105/9 109/3
109/5 109/7 115/7
115/14 115/21 115/21
117/6 117/21 118/1
119/11 119/17 119/22)
120/6 120/8 120/12
121/15 121/20 122/13}
122/18 122/19 125/19)
126/3 126/23 126/25
127/19 131/21 131/22
138/2 139/5 141/15
142/10 156/4 156/6
156/10 156/14 158/10
158/19 161/22 165/7
branch's [4] 94/25
115/3 115/6 116/5
branch-specific [3]
156/4 156/14 161/22
branches [40] 25/21
42/6 43/9 60/2 60/7
87/25 89/5 89/6 89/17
89/19 90/14 91/20
92/2 93/14 94/17 95/3,
95/8 95/11 95/12 96/7
96/13 96/24 97/1
97/10 97/14 97/15
98/23 99/2 100/7
100/17 101/2 101/3
103/21 105/23 118/18}
119/4 126/20 141/16
142/4 158/8
branches’ [1] 116/15
break [11] 61/15
61/20 98/3 98/7 110/2
117/10 156/19 156/22
156/24 157/7 159/10
Brief [1] 13/13
briefing [2] 6/1 6/7
briefly [2] 138/6

12/5 12/13 12/15 16/9)

26/16 26/25 27/4 29/9

170/25

bring [1] 42/12
bringing [1] 55/7
broad [8] 11/15 12/4
27/17 39/8 108/4

broader [6] 27/18
29/13 49/15 82/7
84/12 111/24
broadly [1] 61/5
broken [1] 185/16
BRSS [3] 87/10
87/11 87/19
BTS [3] 56/11 107/15
107/16
Budd [2] 74/2 74/9
bug [56] 15/15 24/25
26/2 26/7 26/11 26/15)
26/15 27/6 27/10
28/17 29/3 29/7 29/11
29/13 43/17 43/19
43/25 44/3 44/12
44/20 45/6 45/24 46/1
46/2 46/7 46/14 47/6
52/9 53/9 53/14 53/24)
55/15 55/18 55/21
57/5 59/10 59/20
60/11 60/13 60/15
85/25 88/16 92/10
99/1 100/16 102/11
102/19 103/6 104/4
115/20 144/19 145/7
149/4 164/11 165/3
165/9
bugs [34] 41/9 45/7
46/5 47/2 47/4 47/20
48/14 49/16 49/16
55/16 55/22 55/24
56/1 56/2 60/21 61/25)
64/3 84/23 85/1 85/4
85/5 85/8 85/10 85/14
85/15 85/16 145/11
155/5 163/8 164/1
164/6 164/21 170/18
170/20
bullet [4] 98/24
100/25 103/20 104/2
burden [2] 131/5
133/8
business [5] 4/2
104/23 105/15 116/19)
116/21
but [189]
Butts [1] 71/14
Byfleet [32] 11/18
15/7 17/17 19/4 19/16
20/16 21/1 21/20 27/4
36/2 36/14 36/21
36/25 37/25 39/3 40/2
59/11 59/14 60/25
67/16 67/19 67/21
69/15 69/16 71/24
76/8 117/3 117/21
122/20 126/3 127/24

110/114 112/18 185/15)

158/4

c

cable [2] 123/13
124/1

calculated [1] 57/22
call [39] 30/17 36/12

99/25 100/2 100/14
103/6 105/19 110/13
110/25 115/18 122/21
123/16 123/21 123/21
126/7 126/8 134/24
135/2 135/13 135/14
135/19 136/2 136/5
136/6 136/10 136/18

140/12 141/13 142/16
147/23 148/5 148/17
called [12] 35/23
40/6 43/24 45/4 51/5
60/13 62/9 62/10
116/7 122/14 133/1
143/24
Callendar [27] 15/15
15/17 24/9 24/21
24/25 25/23 27/10
28/17 35/4 35/18
35/23 37/24 38/24
39/18 40/16 85/11
131/2 132/16 143/11
143/22 144/4 144/13
144/19 145/7 146/7
149/3 165/3
caller [1] 135/4
calling [1] 183/22
calls [38] 9/5 17/9
17/12 17/19 28/1
36/12 36/14 88/24
90/8 99/9 99/11 99/14
99/17 100/3 100/5
100/9 100/14 103/6
115/19 118/4 118/9
118/19 118/23 119/6
119/9 125/15 134/21
137/13 137/16 137/23
138/13 141/4 141/4
141/15 142/3 142/10
148/14 148/19
came [9] 7/7 17/3
39/7 55/11 78/7 79/22
140/18 177/8 186/4
can [164] 1/10 1/19
1/23 2/1 2/20 4/10
4/25 5/9 5/17 6/20 9/4
9/4 10/10 11/21 12/22
20/19 22/6 22/9 22/18
24/4 24/5 24/22 25/8
25/17 26/25 29/19
29/21 30/25 31/1 32/8
33/12 33/22 34/12
34/21 34/23 35/25
36/14 37/23 39/4 39/6
40/8 41/7 43/11 43/14

51/12 62/5 74/5 84/17

136/22 137/10 137/25)

44/8 49/24 53/7 54/2
56/5 56/6 56/12 57/8

68/24 72/4 73/12
73/13 73/16 73/17
73/18 73/22 77/3
80/15 82/12 82/17
84/14 85/25 86/3
88/10 88/19 88/23
90/7 90/20 91/10

98/11 98/13 98/15
99/13 104/6 104/9
104/9 104/23 106/9
106/10 106/23 107/1
107/9 108/9 109/13
110/15 110/16 112/3
113/5 113/15 114/3
115/5 117/20 117/21
117/23 119/9 120/23

122/3 122/6 123/3

123/20 126/6 127/23
128/1 130/12 131/12
134/4 134/24 135/18
137/21 142/15 143/1
143/20 145/17 148/20)
149/16 150/22 151/4
152/7 153/22 153/23
154/22 156/4 156/18
157/5 159/24 163/3
168/23 169/16 170/25
171/13 171/14 176/9
176/9 179/11 180/14
181/6 181/20 181/22
183/16 184/18 185/13
186/11

can't [51] 1/6 1/25
10/7 10/8 26/4 26/10
31/10 33/10 43/22
50/7 56/17 57/3 57/8
63/23 73/20 74/10
76/2 81/14 83/13
83/14 87/12 89/10
89/22 90/4 90/18 93/2,
100/1 100/3 106/4
106/7 130/22 139/6
140/21 144/20 155/11
156/2 156/12 158/11
162/13 162/17 162/19}
163/1 164/8 164/8
170/3 174/9 174/15
178/11 179/12 181/7
182/6

candid [1] 48/15
candidate [1] 3/22
cannot [8] 32/2 47/23}
57/9 79/12 115/13
169/14 183/15 184/24}
capacity [2] 4/4 9/22
carefully [6] 63/2
94/2 95/3 95/7 107/18

60/8 61/15 61/22 63/4
64/19 65/2 65/6 65/10)

92/25 95/10 98/3 98/9)

121/10 121/11 121/12}

123/13 123/15 123/19)

142/16
carried [2] 126/24
147/11
carry [4] 27/13 37/22
41/2 133/10
Carrying [1] 136/17
Cartwright [1]
167/19
case [92] 1/10 1/13
1/21 5/11 5/19 6/2 6/8)
6/8 6/19 6/25 7/5 7/17)
7/21 8/22 15/6 21/6
21/20 22/8 27/7 28/18I
30/14 31/6 34/22 35/2I
38/18 40/21 43/5 48/3
48/11 55/6 60/10
63/13 63/23 64/18
64/25 66/12 68/5
68/15 71/5 76/3 76/13
78/22 79/1 79/10
79/13 81/2 81/8 82/14)
84/17 90/11 94/5
95/19 101/23 103/9
109/7 114/1 122/12
132/17 136/24 150/14)
150/23 153/12 157/15}
159/6 161/12 163/19
164/25 165/4 165/4
165/5 166/15 168/8
171/3 172/3 172/14
172/15 172/20 172/22!
173/2 176/7 177/22
177/25 178/1 178/2
178/3 178/4 178/14
179/13 179/17 180/12!
180/18 182/7
cases [51] 7/8 21/3
23/15 38/8 44/25 46/8
46/9 46/15 46/16
49/23 51/1 51/25
52/10 52/19 67/11
69/14 69/20 71/23
72/3 101/1 101/5
101/11 101/12 101/18)
101/19 101/22 102/2
102/12 102/20 102/22!
102/25 103/8 115/5
122/15 150/13 150/16
151/11 151/18 152/13}
168/5 168/13 177/13
177/16 177/23 178/1
178/18 179/1 179/2
180/14 180/17 182/2
cash [7] 36/1 54/19
70/25 71/1 82/19
129/24 129/25
Castleton [2] 35/24
55/6
Castleton's [2]
132/17 165/4
catch [2] 25/17 26/23
catching [1] 154/4
cause [10] 29/17
38/21 48/13 54/10

(62) bottom... - causeO
Cc

cause... [6] 98/22
99/1 100/6 100/17
141/9 153/20
caused [13] 17/2
39/5 45/1 46/22 47/20
48/14 51/2 51/11 76/4
89/15 105/8 121/15
149/10

causing [2] 55/18
81/23

caveat [3] 63/12
63/15 166/14
caveats [3] 61/6
63/19 166/17

cent [6] 28/8 28/9
69/18 89/1 164/7
167/19

central [4] 45/3 51/4
51/13 114/22
certain [3] 65/13
136/8 167/20
certainly [26] 5/23
8/10 28/6 28/12 32/2
40/17 45/7 50/9 50/16)
55/1 64/5 74/11 76/7
76/22 79/22 90/15
90/16 104/25 106/5
107/25 124/17 133/17)
141/22 159/15 168/9
169/20

cetera [4] 39/13
112/5 144/13 172/9
chain [14] 4/18 5/1
5/22 5/22 13/1 13/3
24/7 24/14 24/17 25/6
52/13 80/4 110/23
176/5

challenge [1] 184/9
challenged [1] 54/11
challenges [3] 54/7
151/17 182/15
Chambers [10] 24/8
24/13 25/4 35/4 37/3
138/1 138/9 140/5
148/4 148/12
change [9] 42/22
42/22 43/3 116/9
116/9 117/11 122/1
160/15 160/19
changes [2] 105/22
185/8

changing [1] 104/21
chaotic [6] 7/2 7/6
7/17 7I17 168/8
168/11

charge [4] 23/18
23/23 24/3 129/11
chargeable [1]
184/10

charges [1] 70/12
Charles [1] 74/4
chat [1] 85/19

chatted [1] 2/22
check [12] 15/6 16/1
27/2 58/22 63/5 68/5
94/20 124/20 148/11
155/15 163/25 164/10)
checked [6] 12/1
15/18 15/20 27/3
36/14 36/21
checking [3] 25/16
26/22 186/6

checks [4] 15/8
21/22 59/10 59/13
choice [4] 97/20
97/20 97/21 185/12
chose [1] 61/10
Christmas [1] 3/21
chronology [1] 90/18
circular [1] 33/5
circulation [2] 44/10
44/16

circumstance [2]
64/22 80/9
circumstances [6]
15/2 24/16 38/6 65/13
89/14 90/4

civil [4] 55/8 55/10
55/10 152/14

claims [2] 55/8 55/10
clarification [2] 8/12
172/13

clarified [4] 11/7
14/23 111/11 114/20
clarity [1] 13/18
clear [19] 5/12 7/18
7/22 8/1 8/4 13/6
14/25 18/16 32/1
40/18 89/1 109/24
114/18 116/4 129/6
138/24 139/10 160/6
184/7

clearly [17] 8/19 8/24
26/13 30/22 36/9 47/4
67/21 83/17 95/18
102/16 134/10 147/16)
149/13 161/18 162/14)
164/14 165/14

clerk [4] 45/2 46/23
51/3 51/11

clock [1] 129/1
close [5] 23/12 23/20
39/7 136/2 136/10
closed [10] 37/12
58/20 91/10 91/13
121/1 135/3 135/13
135/21 136/5 136/18
closely [1] 3/9
closing [1] 91/21
clue [1] 132/11

code [8] 42/22 66/20
89/4 90/9 93/16
105/21 105/25 116/9
coin [1] 170/17
colleague [1] 1/5
colleagues [3] 20/13

151/12 156/7

collect [1] 92/12
collected [1] 65/12
column [3] 56/14
56/16 56/16

come [14] 12/2 28/2
60/8 63/9 63/24 73/13)
79/23 103/11 134/1
140/13 145/13 150/22)
181/14 183/8

comes [1] 89/24
coming [3] 46/4
117/8 131/5
comment [12] 6/13
6/20 24/20 24/24
28/18 28/21 35/18
35/21 37/13 129/9
141/14 150/9
commented [1] 6/21
commenting [1]
12/12

comments [8] 6/22
33/17 50/21 70/9 79/1
79/2 79/11 80/3
commercial [6]
75/19 179/24 180/5
182/24 183/1 184/13
commit [1] 32/2
common [1] 163/19
comms [1] 124/1
communicate [4]
71/19 94/11 95/8
96/13
communicated [4]
95/3 95/16 96/5
185/23
communication [7]
30/2 71/15 75/22
77/14 94/7 96/7 99/16
communications [2]
90/12 96/10
companies [1] 75/23
compare [1] 142/17
compared [1] 57/1
comparison [2] 57/2
58/25

compensate [1]
169/14

compiled [1] 88/17
compiling [2] 83/21
144/9

complaining [2]
134/12 147/18
complete [12] 18/11
18/21 40/4 71/5
142/24 146/8 146/16
147/22 148/10 148/17I
148/24 158/23
completely [7] 19/11
19/21 20/1 20/5 72/19}
72/21 175/15
completes [4] 10/25
11/4 109/19 111/8
complex [2] 166/10

166/13

complexion [1] 45/17I
complicated [1]
116/1

complying [1] 161/10)
components [2]
163/14 163/23
compounded [1]
36/6

computer [10] 48/4
83/1 128/6 134/6
141/11 145/25 147/3
147/5 147/7 147/13
concentrate [1]
160/13
concentrating [1]
152/12

concern [8] 20/25
104/3 141/10 153/20
161/6 161/10 168/12
176/5

concerned [11]
46/19 74/12 79/13
85/9 101/14 103/4
103/10 128/24 134/3
152/25 159/7
concerning [3] 61/24
96/8 102/2

concerns [3] 105/5
168/3 181/3
conclude [3] 37/23
169/11 181/2
concluded [1] 185/15)
concluding [1] 169/2
conclusion [1]
119/25

conditional [2] 39/12
39/16

conditionally [1]
40/14

conduct [1] 129/20
conducting [3] 30/15
81/1 83/19
conference [4] 99/9
99/11 99/13 99/17
confidence [4] 98/22
99/1 100/7 100/17
confident [1] 39/19
confidently [2] 41/3
64/14

confirm [4] 35/25
94/21 155/21 169/7
confirmation [1] 72/6
confirming [1]
151/23

conformed [1] 8/23
confused [4] 91/9
156/1 180/16 180/19
connection [1]
125/12

connects [1] 124/14
conscientiously [1]
84/2

conscious [1] 104/7

consensus [1] 106/3
consequence [1]
5/20

consequences [2]
104/5 162/13
consider [9] 21/7
55/15 55/22 64/16
108/10 127/6 127/10
152/3 159/2
consideration [1]
152/2

considered [4] 49/6
110/6 111/21 165/6
consolidate [1] 92/11
consolidated [1]
99/8

contact [6] 50/13
122/3 122/4 138/3
152/24 160/11
contained [1] 65/3
content [5] 14/10
14/11 14/16 184/16
185/4

contents [2] 52/24
59/22

context [14] 10/11
38/17 42/2 42/11
74/11 101/9 102/6
102/7 112/23 112/25
115/14 116/21 142/2
17112

continually [1] 137/8
continue [7] 38/22
74/4 76/14 97/17 98/9)
114/23 181/3
continued [5] 1/3 1/4
93/15 187/2 187/4
continues [3] 130/23
147/2 177/11
continuing [3]
123/23 126/2 172/24
contract [1] 184/13
contradict [1] 167/24
controlled [2] 91/19
184/8

conversation [8]
3/17 26/4 26/7 26/10
30/3 30/15 141/21
162/17
conversations [2]
83/8 181/16
converted [1] 176/17
cooperate [1] 184/7
copied [13] 2/3 2/5
10/16 20/22 21/14
29/22 31/2 32/10
33/15 50/8 109/16
151/5 180/3

copies [5] 65/15
178/5 178/10 178/10
180/15

copy [4] 6/9 73/24
87/13 143/15
copying [2] 70/15

(63) cause... - copyingO
Cc
copying... [1] 159/22
core [3] 145/19 184/4
186/15
correct [22] 3/4 11/9
16/4 21/24 23/7 24/1
30/18 41/13 57/15
57/23 70/17 70/18
90/23 94/16 94/17
101/5 115/9 139/16
167/13 167/16 172/23}
179/19
corrected [1] 94/18
correcting [2] 90/20
94/13
corrections [3]
114/21 115/10 115/16}
correctly [8] 45/11
45/13 45/22 45/23
82/3 96/25 113/16
169/13
correlate [6] 125/10
125/15 125/23 129/24
130/1 137/1
corresponding [1]
16/1
corrupt [2] 121/7
121/20
cost [1] 75/1
costs [1] 125/6
Coton [2] 43/21
43/25
could [84] 3/21 8/10
11/4 11/6 12/12 14/21
14/23 15/18 15/20
15/20 18/6 19/18 20/2)
26/9 34/11 36/3 37/10
38/5 38/20 38/21 45/1
45/1 45/8 46/14 46/16
46/22 46/22 51/2 51/2)
51/10 51/10 51/12
54/7 54/10 55/1 55/18
56/2 60/5 63/11 65/15)
68/15 68/21 70/21
74/3 75/24 87/18
89/22 91/23 95/16
97/14 98/19 98/22
99/1 100/6 100/17
103/21 105/5 105/6
109/19 111/10 116/5
117/10 129/9 130/17
131/17 131/25 132/22)
133/20 134/14 143/15}
146/19 147/20 149/9
150/19 153/21 160/16
160/16 162/13 170/7
174/16 178/4 179/14
184/6 185/17
could/will [1] 54/10
couldn't [8] 18/16
27/2 127/15 132/1
132/22 139/8 168/21
181/9

count [2] 125/4
128/22
counter [11] 42/23
43/2 66/21 66/25
121/17 122/13 122/13}
122/17 122/18 122/20)
127/2
counterpart [2] 70/7
180/8
counters [1] 118/12
counters’ [1] 118/7
couple [6] 42/5 50/15
136/14 148/24 151/1
163/1
course [9] 70/17 90/1
105/17 127/3 138/7
144/17 145/4 160/23
165/25
court [40] 28/25
34/18 47/19 47/23
48/5 48/15 54/5 64/21
69/14 69/21 71/22
72/7 79/15 79/22 80/1
82/25 83/21 100/20
101/4 101/11 106/11
111/2 117/5 120/5
138/12 149/17 151/20)
167/11 167/23 168/15)
171/18 171/25 173/1
174/2 174/25 175/5
175/6 175/6 177/13
185/16
courtesy [1] 160/24
cover [8] 77/25 82/20
1141/5 112/9 112/15
148/14 154/11 179/24)
coverage [3] 58/15
58/16 58/18
covered [11] 23/18
23/23 24/3 67/15 68/4
77/24 118/2 125/20
155/24 173/4 181/7
covering [3] 17/24
18/1 95/19
covers [2] 54/19 71/3
Craigpark [3] 15/16
15/18 165/1
created [1] 60/12
credibility [4] 44/25
45/25 49/23 51/1
criminal [2] 152/14
165/8
critical [3] 87/15
121/5 123/17
cross [2] 38/15
142/17
cross-compare [1]
142/17
Crown [2] 106/11
171/25
crude [1] 81/6
CS [2] 66/6 66/8
CT [1] 184/14
current [3] 25/18

26/25 48/10
currently [2] 47/22
69/23

Customer [2] 66/8
159/20

cut [4] 12/25 13/3
86/2 135/25
cutting [1] 22/11
cycle [1] 43/4

D

D'Alvarez [1] 50/20
darker [1] 5/4
data [138] 12/14
15/11 15/19 15/24
16/8 18/7 18/10 20/3
20/15 21/1 22/20
22/20 22/25 23/6
23/10 23/14 23/17
24/2 28/6 28/11 32/13
32/17 32/21 32/22
32/24 32/25 33/2 33/5
33/13 33/24 34/3 34/5
34/9 35/2 38/3 38/10
38/21 51/20 51/24
57/11 57/12 57/18
57/22 59/17 62/24
62/25 63/5 63/8 63/16)
63/20 63/23 64/2 64/6
64/11 64/14 64/20
65/4 65/12 65/17
65/24 67/5 67/6 67/21
68/8 70/19 87/3 87/9
87/16 87/18 87/23
90/13 94/14 94/16
94/17 94/18 95/2 95/5
95/7 95/11 95/12
96/12 101/2 101/10
104/21 105/4 124/20
124/23 125/2 125/7
125/11 125/22 125/23}
127/15 128/12 128/16
128/24 129/1 129/3
129/3 129/8 129/8
129/20 129/21 129/22)
129/23 132/7 132/12
132/14 132/21 137/2
138/2 142/18 142/20
144/18 145/6 145/10
148/12 154/12 154/24
156/5 156/14 161/24
163/15 164/10 164/12)
165/6 169/12 169/14
170/7 170/13 170/15
170/18 177/8 178/16
179/2 180/13 180/22
183/17
database [4] 45/3
51/4 51/13 87/13
databases [1] 88/4
date [8] 24/12 34/18
57/18 65/9 88/18
102/20 121/5 171/18
dated [4] 90/25 91/2

114/7 178/5

dates [1] 53/1

Dave [5] 5/2 5/13
51/22 80/21 160/9
David [17] 3/7 3/7
3/16 9/16 10/4 10/20
12/22 13/4 13/20
49/14 76/5 76/5 76/6
80/14 112/11 123/22
164/22

Davidson [3] 159/22
180/6 182/12

day [38] 4/14 9/20
21/12 22/4 24/5 29/18)
30/1 30/25 31/2 36/8
44/9 56/22 60/3 66/14)
68/22 69/5 87/5 87/6
89/13 123/15 123/23
136/5 136/13 143/2
143/3 143/4 143/5
143/6 149/2 153/23
155/23 157/1 161/7
161/7 162/7 185/7
186/16 186/18

day 1 [2] 87/6 89/13
day one [1] 87/5
days [12] 20/15 43/5
53/8 53/9 92/23 93/5
93/8 97/5 148/25
151/14 154/10 163/1
dead [1] 121/18

deal [2] 8/15 13/10
dealing [8] 35/18
39/24 80/16 107/11
108/15 151/17 165/13
168/24

Dear [2] 10/20 151/6
debt [1] 80/17
December [16] 2/21
5/24 32/14 32/14
33/20 33/20 37/1 37/1
124/25 124/25 126/25]
128/17 128/17 148/13}
181/24 182/12
decide [1] 74/3
decided [8] 60/1 77/1
83/2 88/1 100/11
125/6 133/6 148/4
decision [1] 181/3
declaration [1] 152/9
declarations [1]
129/25
decoding [1] 182/18
defect [1] 41/24
defects [4] 163/8
164/21 170/19 170/20}
defence [25] 2/8 2/15
5/10 30/15 31/5 31/12,
35/22 47/19 75/3 77/1
78/24 79/4 84/24
111/3 117/4 131/5
132/22 133/9 133/9
139/17 139/23 151/25
152/14 175/4 177/20

defendant [4] 131/11
132/4 157/11 179/18
defendants [1]
152/16
definitely [2] 7/21
21/10
definitively [1] 83/14
delay [1] 29/25
deleted [1] 121/19
demand [1] 21/24
demanded [1] 79/21
demands [1] 8/16
denial [1] 133/23
denied [2] 133/4
133/11
depended [1] 30/20
deployed [5] 161/23
176/7 179/1 180/11
180/14
Derby [9] 41/21
41/23 43/17 43/17
43/19 43/24 44/3
44/12 53/9
describe [5] 6/24
8/14 41/22 153/17
184/4
described [3] 74/25
157/19 180/10
describes [1] 86/12
describing [5] 158/2
170/12 174/22 175/17
175/18
description [5] 121/6
152/6 170/11 177/6
177/17
designed [2] 51/20
164/9
designing [1] 185/8
desktop [1] 124/14
detail [8] 30/23 57/8
93/23 99/10 130/3
159/2 164/21 181/7
detailed [12] 18/10
30/10 30/17 36/24
71/7 74/24 128/9
129/15 132/15 146/2
177/4 177/21
detailing [3] 151/18
176/14 177/41
details [10] 21/5
33/11 38/3 57/3 76/2
76/3 93/2 100/4
162/20 163/1
detect [1] 66/3
detectable [1] 163/17
detected [3] 93/12
121/7 121/20
determine [1] 51/19
develop [2] 49/17
105/21
developed [2] 106/1
130/16
developers [1]
151/22

(64) copying... - developersO
D

development [3]
69/23 87/2 159/21
dialogue [1] 145/16
diaries [1] 171/18
diary [1] 182/3
did [175] 6/3 6/10
6/18 6/22 7/4 7/20
7/25 8/3 8/8 8/10 8/12
8/21 9/1 9/6 9/13 10/5)
13/3 16/7 17/25 19/1
19/22 23/22 25/6
25/10 25/17 25/18
26/1 26/11 26/12
26/23 26/25 27/3
27/15 28/13 28/23
29/2 29/10 32/25 33/5)
34/2 40/10 40/11
40/17 41/2 41/4 42/7
44/12 47/8 48/9 55/4
55/4 55/5 55/15 55/22,
56/1 59/17 60/17 61/4)
61/6 64/16 65/21 66/2
69/15 70/3 75/2 75/5
76/18 77/10 77/18
77/20 78/2 80/10
81/11 81/24 84/2 84/4
85/7 86/5 89/9 90/15
92/15 94/15 94/18
95/5 95/7 97/11 99/3
99/6 100/18 100/18
102/11 104/12 107/14}
116/23 117/1 117/2
118/17 119/13 119/14
119/20 120/2 120/4
123/6 124/17 125/21
127/6 127/18 128/20
129/1 129/1 129/5
129/10 129/20 131/15}
131/20 132/23 133/23)
136/21 136/25 137/1
137/4 137/25 138/3
138/4 139/3 139/7
139/17 139/22 141/7
141/18 141/9 143/15
144/20 145/15 145/15}
147/23 149/19 150/14}
150/16 150/17 153/14
155/23 157/14 158/17
159/5 159/7 162/16
163/10 163/25 164/4
166/10 166/17 166/25
167/21 168/12 168/18)
169/23 170/5 173/9
174/5 174/19 174/21
174/22 175/3 175/9
175/13 175/14 176/15}
176/19 176/20 177/3
178/7 178/24 185/14
186/8
didn't [131] 7/22 8/5
13/24 14/4 19/18
19/24 20/17 23/16

23/24 23/25 28/20
37/18 40/13 44/6 45/9)
45/19 46/16 46/19
47/6 48/6 48/20 48/21
48/24 49/11 59/3 59/4
60/1 60/16 61/1 61/7
77/19 77/22 79/22
79/23 81/22 84/8 85/5
85/10 85/15 94/17
95/11 95/12 95/18
95/19 95/23 96/2 96/3
96/3 96/12 96/21
96/24 97/4 97/7 97/22
97/23 101/7 101/22
101/24 107/12 109/6
111/17 112/24 116/4
116/11 116/25 118/10)
120/10 120/16 124/23)
125/2 125/24 127/10
127/15 129/11 129/21
130/1 131/15 132/2
132/23 133/10 133/25)
137/6 137/11 137/16
137/24 139/17 139/18)
141/19 142/1 145/10
146/13 146/14 146/18)
148/1 148/8 148/16
148/22 153/20 156/2
157/10 158/5 158/18
158/19 159/1 161/20
162/1 163/7 163/9
164/13 166/14 166/17)
166/24 167/4 167/24
167/24 168/16 173/16)
173/22 174/12 175/1
175/2 175/12 176/21
176/23 177/9 179/8
180/23 181/13 181/17,
185/2 185/19
difference [6] 37/19
37/20 48/6 70/12 80/2
177/10

differences [3] 54/9
173/21 173/25
different [17] 8/3
37/16 41/7 46/17
47/25 62/10 64/22
65/24 66/17 72/13
80/16 95/13 101/9
123/25 136/8 173/11
174/11
differs [1] 91/3
difficult [1] 75/1
digging [1] 140/14
Dinsdale [1] 32/10
direct [2] 112/18
186/8
directly [2] 4/22
11/11
discard [2] 65/20
66/3
discarded [1] 65/19
disclose [2] 40/11
116/23

disclosed [3] 35/11
103/15 148/6
disclosure [5] 104/3
133/1 144/15 151/16
152/3

discover [1] 26/19

discovering [1]
48/12

discovery [1] 52/9
discrepancies [16]
16/11 22/23 26/3 26/8}
26/12 27/11 47/21
48/13 60/12 86/15
90/20 94/21 94/23
103/22 152/21 169/9
discrepancy [13]
25/10 26/2 26/13 45/1
46/22 51/2 51/10 57/5
60/15 94/24 95/2
105/7 139/5

discuss [5] 43/17
86/13 91/6 152/24
183/7

discussed [8] 29/18
43/20 51/5 67/23
85/11 103/6 133/17
140/3

discussing [2] 99/21
115/19

discussion [18] 9/15
30/21 50/2 50/3 50/4
52/17 53/22 101/13
101/16 102/24 103/2
104/7 105/17 106/4
116/22 125/25 126/5
183/20

discussions [2]
106/7 106/8

disk [3] 121/13 122/2
122/14

dismissed [1] 54/6
dispassionately [1]
83/22

display [2] 1/11
147/8

displayed [1] 1/18
plays [1] 147/5
puting [1] 101/2
distinction [4] 35/15
55/9 176/22 176/23
distribution [1] 21/13
divert [1] 85/7

do [172] 3/7 3/24
4/15 4/25 5/7 5/25
6/17 7/20 7/21 7/22
9/4 9/4 9/19 9/20
13/24 14/5 17/1 18/17,
18/20 18/25 19/21
19/25 20/7 20/10 24/9}
24/16 24/18 24/22
27/3 27/5 27/14 28/3
28/13 28/20 29/6
31/15 34/20 35/11

36/17 37/2 37/19 42/3
45/13 45/24 46/2 46/4
46/7 46/9 46/13 48/16)
49/4 49/9 51/18 52/2
52/7 56/7 56/7 58/1
59/10 59/22 62/21
64/3 67/4 67/19 69/10)
70/23 70/24 71/15
71/20 73/20 74/7 74/8
74/8 74/9 74/10 75/15)
75/20 75/22 76/9
76/13 79/24 81/6 81/8
81/16 82/7 86/12
86/22 93/6 95/1 95/18)
96/12 99/6 100/24
103/13 103/23 104/2
105/13 105/20 107/23}
110/5 110/8 111/7
112/13 115/12 115/13}
115/15 116/2 118/5
119/10 119/21 120/20}
120/25 121/24 122/1
122/9 122/12 122/21
124/1 124/2 125/2
125/9 126/3 126/11
127/11 127/18 128/9
129/15 129/18 129/24,
130/10 130/17 132/15}
132/22 132/25 133/19}
137/11 137/16 137/19}
138/22 139/4 139/10
140/2 140/10 140/14
140/15 141/4 141/5
141/17 146/2 146/8
147/22 149/7 150/1
150/20 151/8 152/2
152/24 161/1 161/3
162/6 166/25 167/17
170/16 174/4 174/6
175/2 175/6 175/8
178/7 179/7 182/7
183/24

document [26] 22/11
41/12 46/13 50/5
52/16 52/25 55/12
56/7 56/8 65/7 88/10
90/19 90/23 95/25
96/16 99/19 102/18
140/4 151/18 152/4
155/24 158/2 168/2
177/3 177/4 177/6
document/spreadsheI
et [1] 152/4
documents [4] 40/6
51/17 157/20 158/7
does [23] 4/22 9/20
41/17 11/18 12/16
36/3 43/1 44/2 58/15
74/6 74/23 80/25
81/10 81/19 101/21
108/2 122/6 137/12
152/8 161/20 162/10
164/8 170/19
doesn't [17] 4/18

11/20 11/22 12/16
12/17 40/16 49/7
72/14 75/21 83/6
101/21 123/24 148/14I
158/23 164/7 170/16
170/17
doing [24] 10/2 24/23]
43/7 68/5 77/9 80/9
105/14 105/2 105/11
105/12 116/2 128/7
129/14 142/8 144/15
146/1 161/13 161/14
162/5 164/3 168/17
don't [85] 5/12 6/3
6/6 6/18 8/25 14/18
17/2 19/22 20/8 20/9
24/22 29/1 29/5 29/16
34/11 39/12 39/14
40/8 41/12 44/9 46/9
48/12 49/3 52/11 58/6
58/17 59/19 63/15
68/17 69/11 72/10
73/21 74/21 76/16
78/1 78/25 81/7 82/6
88/18 88/22 89/24
97/25 99/4 99/4 99/5
99/22 100/9 101/12
101/12 102/4 102/6
102/6 102/15 103/24
104/6 104/24 108/23
109/10 112/6 113/12
115/12 115/25 121/14I
122/7 122/19 124/4
124/4 130/20 137/14
139/24 142/12 145/14I
147/25 150/6 161/15
162/2 162/22 162/23
164/5 166/1 172/3
174/16 174/16 179/5
182/8
done [42] 5/14 16/25
17/11 17/22 19/25
23/15 27/25 29/1 29/5I
34/9 35/13 35/13
35/16 37/6 37/14 68/9I
68/10 71/8 77/16 79/8
86/22 92/9 93/10
96/11 103/14 103/18
104/18 105/3 105/10
106/5 109/25 115/22
120/14 125/14 140/8
141/25 142/8 142/19
144/23 162/19 164/15I
168/21
double [1] 68/5
doubt [3] 54/22 89/11
122/2
down [50] 1/24 2/6
10/13 20/23 21/14
24/6 29/25 54/2 59/4
60/8 66/5 69/22 72/10]
73/13 73/23 82/13
86/2 92/19 104/12
106/12 106/17 109/14I

(55) development - downO
D

175/6

down... [28] 110/2
114/8 121/9 121/21
123/9 126/7 126/10
129/22 130/2 130/13
135/9 135/15 135/18
135/21 135/23 136/1
136/4 136/9 136/16
140/23 145/17 150/22)
159/3 171/1 171/3
171/16 176/10 184/17)
dozen [2] 42/5 42/6
draft [9] 22/7 22/24
24/13 158/16 163/7
163/13 166/11 167/7
167/14
drafted [2] 166/3
184/15
drafting [2] 51/9
162/25
dragged [1] 139/14
draw [1] 174/22
drawn [3] 44/2 61/5
64/3
drive [2] 122/15
122/16
drop [1] 160/13
dropped [4] 87/9
87/16 87/17 87/23
due [6] 15/2 16/11
22/19 82/21 90/1
165/25
Dunks [18] 2/1 2/2
2/3 2/6 27/25 118/3
120/14 123/5 125/20
126/22 127/4 137/20
137/22 138/12 140/25)
141/9 142/9 148/1
Dunks’ [9] 36/12
119/1 119/19 127/21
137/13 140/12 140/19
141/13 148/19
duplicate [13] 41/21
41/23 42/1 65/9 67/14
71/8 71/25 72/12
72/14 73/6 91/7 91/11
91/13
duplicated [6] 66/16
70/15 70/16 70/20
70/22 71/22
duplicates [9] 65/19
66/3 67/7 67/8 71/4
71/9 73/2 91/9 91/22
duplication [1] 65/3
during [15] 33/8
38/25 39/13 42/8
43/23 56/3 56/9 88/19
88/24 131/19 131/24
143/13 174/6 174/17
175/21
duties [4] 78/10
175/13 176/24 185/16)
duty [3] 174/24 175/5

E

each [5] 66/19 66/25
177/22 178/2 178/3
earlier [10] 27/16
67/23 89/20 100/22
101/7 107/11 128/1
131/9 137/5 159/10
early [3] 60/9 61/25
177/14
easily [3] 87/1 97/2
97/10
edited [1] 52/8
effect [2] 44/20 186/5
effective [1] 137/7
effectively [6] 17/3
21/15 55/12 56/23
121/18 182/4
effectiveness [1]
51/13
effects [2] 26/15 29/8
effort [1] 32/1
eight [1] 52/24
either [6] 5/21 6/14
31/11 42/17 111/17
121/18
electronic [2] 6/23
58/22
Eliasson [1] 1/6
else [15] 2/23 4/10
7/16 17/11 17/24 18/1
18/17 22/11 71/2
83/18 149/5 150/17
160/13 174/12 179/4
else's [1] 119/23
email [65] 1/24 2/1
2/22 3/6 4/13 5/20 7/8
10/14 10/19 11/8 27/9)
28/19 29/21 31/2 32/9
33/14 34/8 34/8 49/25
50/8 53/21 53/22
54/14 61/23 63/21
68/22 73/22 76/23
80/3 80/18 81/4 81/7
81/16 82/13 84/6
84/16 109/15 110/16
112/1 149/16 153/17
153/19 157/6 157/16
157/19 159/25 160/2
160/6 161/4 162/4
162/23 169/5 170/2
171/9 171/9 171/17
171/24 176/10 180/3
181/14 181/20 181/22)
181/23 184/21 185/24)
emailed [1] 159/19
emailing [2] 62/14
138/9
emails [7] 5/8 9/2
10/8 81/10 108/17
131/9 181/25
emerged [1] 61/25
employed [1] 180/17

employee [1] 2/13
employees [2]
185/24 186/9
employers [1] 186/5
enable [2] 21/4 94/10
enabled [1] 133/9
end [13] 22/21 22/21
72/7 90/7 93/13 94/19
104/14 105/2 105/15
106/6 106/18 108/14
116/3
ended [2] 7/10 153/4
ending [3] 138/21
157/23 157/25
engineer [4] 122/3
123/11 123/12 127/7
engineers [1] 122/8
enough [1] 29/16
enquiries [1] 137/24
ensure [3] 67/15 68/3}
96/4
ensured [1] 163/15
entered [1] 114/14
entries [1] 105/16
entry [5] 107/15
107/16 121/25 123/10
123/11
environment [2] 87/2
114/14
EPOSS [2] 22/18
38/4
equally [1] 70/22
equipment [11]
22/19 23/2 118/1
118/18 119/3 119/16
119/22 120/6 120/8
120/11 125/18
error [17] 45/2 46/23
51/3 51/11 58/13 89/4
97/21 114/16 121/6
123/18 124/13 126/16
133/15 152/19 152/20}
169/8 169/15
errors [7] 38/20
142/19 146/17 163/8
164/21 170/18 170/20}
escalate [2] 10/5
89/7
Escher [1] 29/18
especially [1] 32/1
essence [1] 183/10
essentially [15]
21/24 22/4 24/13 30/2
31/19 44/13 61/24
93/20 143/8 145/19
149/21 152/25 154/17]
155/9 162/10
establish [1] 86/4
established [2] 85/18)
92/7
estate [1] 89/17
et [4] 39/13 112/5
144/13 172/9
et cetera [4] 39/13

112/5 144/13 172/9
etc [1] 152/19
evaporated [1] 80/7
even [19] 4/18 17/16
44/24 71/5 71/6 94/21
102/9 102/15 102/23
103/3 108/4 128/6
132/10 145/24 148/18}
161/14 165/13 168/10
180/16
event [24] 15/21 16/5
17/6 20/3 32/19 39/20}
39/22 88/7 92/23
92/25 93/9 108/15
108/18 112/9 112/19
113/9 113/14 121/6
123/17 142/19 143/8
143/14 144/21 148/25)
eventing [2] 15/4
16/3

events [28] 15/3 15/6
16/1 25/14 25/17
26/23 27/3 27/15
27/20 36/19 36/20
36/21 62/4 62/7 62/8
62/15 63/6 63/9 63/24
88/3 88/4 130/17
144/23 145/1 149/5
149/8 167/9 168/9
events' [1] 25/14
eventual [1] 97/16
eventually [7] 28/15
32/23 32/24 88/1
93/12 104/18 105/3
ever [13] 1/14 6/6
6/18 19/22 34/12 39/7,
55/25 68/20 99/20
99/24 175/13 185/14
186/8

every [2] 68/19 96/15
everyone [2] 168/16
171/13

everything [2] 8/24
160/13

evidence [59] 1/16
7/2 8/22 9/23 9/24
27/16 29/8 29/15
31/11 39/22 52/18
76/11 78/7 78/9 78/18
78/23 78/25 79/6
83/20 83/22 86/4
98/10 100/20 100/23
106/9 106/15 106/19
108/11 109/4 120/4
120/7 122/24 124/5
126/17 129/19 130/18
131/24 136/23 139/11
140/12 140/18 140/19}
140/20 141/5 141/10
145/19 147/4 148/19
149/12 150/23 156/5
159/10 164/11 165/7
171/11 175/22 177/12}
184/23 185/17

evidence’ [1] 183/12
exact [7] 27/24 33/11
90/18 100/1 163/1
170/3 181/7
exactly [27] 7/9 7/22
10/9 13/5 13/19 23/20)
30/9 31/6 31/9 68/6
77/8 87/12 88/20
89/10 89/23 90/17
92/16 110/5 110/8
139/6 144/20 151/8
155/11 159/7 160/6
173/3 182/5
examination [2]
106/18 141/25
examine [5] 30/24
94/2 107/17 119/13
156/5
examined [5] 35/24
37/8 138/2 146/22
148/17
examining [4] 61/23
118/19 125/9 141/13
example [13] 9/15
10/4 17/20 37/10
76/23 80/20 81/18
107/2 114/20 137/8
144/14 166/14 174/1
examples [3] 7/13
10/8 81/12
Excel [2] 157/22
158/7
exchange [8] 26/6
28/19 35/4 49/25 52/5
52/24 63/21 165/10
exchanged [1] 131/9
exchanges [2] 7/13
102/25
exhaustive [1] 141/3
exhibit [1] 38/9
existed [1] 27/10
existence [9] 40/11
45/24 46/7 46/14 47/6
47/20 85/8 133/15
133/18
existing [1] 154/2
expect [3] 107/4
134/12 147/18
expectations [1]
8/23
expected [5] 39/21
42/7 69/24 126/19
142/12
expecting [3] 42/6
96/16 142/7
experience [6] 29/3
124/8 126/21 141/13
147/6 148/20
experienced [2]
119/5 119/7
expert [42] 2/8 3/21
4/19 5/11 30/16 77/1
78/10 78/24 79/4
80/22 84/24 91/15

(56) down... - expertO
E

expert... [30] 133/10
150/12 150/15 152/12)
152/13 171/6 172/8
173/4 173/7 173/13
173/15 173/16 173/19}
174/10 174/20 174/23}
175/16 176/11 176/13
176/16 176/20 176/24}
177/1 177/24 180/10
181/17 183/9 183/16
184/10 185/11
expert's [3] 3/23 4/20
4/21

expertise [6] 18/2
118/15 118/17 119/3
120/9 120/13

experts [2] 151/21
184/8

explain [4] 22/23
54/10 63/4 65/10
explained [5] 30/6
155/3 174/7 174/14
181/11

explaining [5] 68/2
100/9 160/7 171/8
181/16

explains [2] 46/21
184/21

explanation [7] 6/1
6/7 70/1 70/3 72/10
172/7 186/4

explicit [1] 93/22
explicitly [1] 113/18
exploring [1] 96/15
expressed [2] 100/14
100/19

expressing [2]
149/25 176/5
expression [2] 58/18
58/19

extended [2] 92/24
93/6

extent [7] 22/22
32/16 67/17 97/7
108/9 173/24 185/10
external [8] 115/5
115/11 115/13 116/4
116/7 183/9 183/16
184/10

externally [1] 114/14
extracted [2] 65/17
68/20

extracting [3] 21/4
63/5 65/25
extraction [3] 67/22
87/3 128/16

extreme [2] 160/14
160/23

extremely [1] 110/21

F
face [8] 35/12 99/12

99/12 99/15 99/15
158/20 159/1 185/1
facilities [2] 105/24
116/13

facility [4] 88/5
105/17 116/17 117/5
fact [31] 1/25 6/4
9/13 10/15 24/5 27/10
32/11 33/2 44/2 44/3
63/19 78/12 78/19
79/6 79/16 88/1 98/19)
100/18 109/6 111/12
111/22 111/25 123/7
126/22 150/21 161/20)
171/16 174/3 176/21
178/19 179/9

factor [1] 79/16
facts [4] 47/23 77/11
80/11 178/3

FAD [1] 66/20

fail [1] 124/17

failed [3] 124/15
127/8 127/11

failure [1] 124/21
failures [11] 16/12
16/16 22/19 23/2 38/6
38/24 117/20 126/20
126/23 126/25 148/20)
fairly [8] 7/2 7/5 7/17
16/15 63/2 89/14
97/12 149/8

fairness [1] 103/15
Falkirk [3] 35/23
38/25 112/6

fall [3] 118/5 118/10
137/14

falling [1] 124/6
false [1] 33/8

falsely [1] 81/25
familiar [4] 22/10
88/11 88/13 104/10
familiarise [1] 178/2
far [17] 4/4 4/6 30/11
42/8 46/18 85/16 90/6
99/13 103/10 111/12
122/24 128/23 151/20)
152/25 165/10 185/13}
186/6

fatal [1] 121/6

fault [14] 17/9 128/6
128/10 129/17 130/11
130/25 131/12 131/12)
141/11 145/25 146/4
146/6 152/17 166/16
faults [19] 38/25 39/3
39/13 39/22 40/15
40/21 40/24 127/19
129/19 129/21 130/19)
131/19 131/23 132/5
132/6 133/2 141/25
142/14 146/22

faulty [6] 118/1
119/22 120/12 120/12)
125/19 126/2

favour [2] 94/25
116/10

favouring [1] 105/1
featured [1] 165/3
February [22] 9/16
10/4 10/11 10/16
20/21 22/7 24/12
29/23 30/15 30/25
43/11 43/14 44/9 53/9
58/12 80/25 110/19
135/2 144/22 144/22
148/14 149/6
feedback [3] 39/1
86/19 90/1

feel [3] 8/21 9/6
180/23

feeling [2] 64/15 78/5
feels [1] 39/5

fell [1] 122/25
fellow [1] 185/24
felt [9] 9/11 9/13 10/1
27/23 37/21 55/20
65/1 105/2 149/15
few [11] 43/5 53/8
53/9 69/6 70/5 97/15
124/10 126/6 150/16
154/9 168/9

fide [1] 69/9

fifth [2] 33/17 114/6
figure [2] 94/4 97/16
figures [3] 115/20
134/7 147/14

files [1] 21/4
filtering [3] 72/24
73/1 73/7

final [4] 53/14 166/11
169/3 169/4

final’ [4] 54/5

finally [1] 112/4
finances [1] 71/7
financial [2] 47/20
48/13

find [10] 25/1 27/6
28/18 50/21 72/4
84/15 128/8 131/18
139/8 181/13
findings [2] 85/23
184/9

fine [5] 53/6 62/25
99/23 157/3 186/12
fingers [1] 149/18
finish [2] 61/22 157/4
finishing [1] 98/10
first [36] 1/19 1/20
5/17 6/5 6/9 10/22
35/10 38/10 39/24
43/8 50/24 53/17
54/18 56/6 61/5 66/13)
66/22 84/19 89/18
89/23 90/6 104/19
104/20 105/4 109/15
143/3 143/4 143/5
143/6 149/2 158/16
175/22 175/23 176/15}

176/23 184/21
firsthand [1] 29/6
firstly [2] 76/18

112/13
fits [2] 90/17 160/12
five [5] 158/2 158/3

178/10 180/14 180/19}
fix [10] 37/13 37/14
43/6 55/1 58/12 69/23)
86/14 90/9 93/16

163/22
fixed [17] 36/22
37/10 37/11 37/17
45/8 46/5 46/11 47/2
47/3 47/5 55/4 55/21
85/17 97/2 97/10

100/12 164/1
fixes [1] 42/17
fixing [3] 41/24 46/2
46/3
flagging [1] 171/21
flood [1] 25/14
fobbed [1] 182/4
focus [7] 47/1 77/3
84/10 84/12 100/13

143/11 183/22
focused [1] 101/14
focusing [4] 14/14
46/12 50/19 124/23
Folks [1] 182/16
follow [1] 136/19
followed [1] 152/5
following [14] 20/15
35/25 38/5 50/24 51/7
56/25 69/25 80/14
100/20 111/5 146/9
150/23 151/14 186/18
follows [1] 175/25
font [3] 5/4 5/5 22/15
foot [7] 29/20 42/16
42/20 44/18 49/24
92/20 106/17
Forgive [1] 165/22
forgotten [3] 25/10
26/1 26/7
form [12] 2/12 4/20
4/21 5/10 66/17
105/18 105/19 119/24)
133/23 153/14 155/24)
165/24
formal [3] 7/23 31/13
160/19
formality [1] 8/6
formally [2] 23/5
86/20
formed [1] 166/3
forms [1] 116/24
formulation [1]
173/11
forthcoming [1]
71/23
forward [16] 25/6
35/17 43/11 44/7
45/14 55/2 80/22

100/12 104/9 106/5
106/16 134/4 163/3
164/16 176/9 183/8
forwarded [5] 24/16
44/11 52/25 103/17
110/23

forwarding [1] 24/14
forwards [11] 22/8
24/5 28/15 29/19
33/12 44/8 53/7 56/5
80/15 114/7 135/1
found [17] 25/23
28/10 36/22 38/24
39/13 41/21 41/23
55/25 65/25 85/8 93/4
93/13 109/4 141/25
149/19 152/14 170/7
four [9] 84/19 108/14
108/16 111/6 157/15
158/15 159/6 160/2
163/11

four paragraphs [1]
84/19

fourth [4] 30/5
116/20 169/3 169/4
frame [2] 72/4 154/20]
framed [2] 112/25
153/10

fraud [3] 44/24
150/13 169/16
fraudulent [1] 31/9
free [2] 145/13
166/16

frequently [1] 91/12
Friday [1] 183/7
front [1] 145/3
frozen [1] 124/12
Fry [1] 136/10
FUJ00080526 [1]
38/16

FUJ00083722 [1]
24/6

FUJ00083737 [2]
114/5 117/22
FUJ00092922 [1]
43/12

FUJ00093031 [1]
44/8

FUJ00094235 [1]
56/5

FUJ00094268 [1]
53/20

FUJ00094392 [1]
49/24

FUJ00097047 [1]
68/24

FUJ00097058 [1]
65/6

FUJ00117478 [1]
41/11

FUJ00122713 [1]
20/20

FUJ00122794 [3]
10/10 109/13 109/14

(57)

expert... - FUJ001227940
F

53/7
FUJ00152866 [1]
1123
FUJ00152888 [1]
73/15
FUJ00152902 [1]
110/15
FUJ00152930 [1]
2112
FUJ00152992 [1]
31/1
FUJ00153115 [1]
84/16
FUJ00153390 [1]
143/1
FUJ00153395 [1]
138/6
FUJ00156122 [1]
80/15
FUJ00156128 [1]
33/13
FUJ00156217 [1]
62/1
FUJ00156645 [1]
159/24
FUJ00156923 [1]
181/22
FUJ00225196 [1]
149/16
Fujitsu [68] 2/13 2/21
3/12 5/9 11/6 11/9
11/22 13/9 14/22
18/13 18/22 19/12
20/13 21/4 22/25
23/14 31/17 32/5
39/10 39/17 40/5
44/12 54/9 68/15
75/20 76/19 77/6
77/10 78/3 78/19 79/7
79/17 84/4 88/15 89/4
89/6 89/25 90/12
92/11 99/16 99/20
100/15 103/25 105/8
105/18 108/19 109/21
111/10 112/16 113/2
117/5 125/25 130/16
131/15 151/22 156/8
159/12 162/24 163/20
164/19 164/20 165/2
165/11 183/4 184/14
185/25 186/2 186/7
Fujitsu's [5] 12/6
133/1 139/20 146/17
168/4
fulfil [1] 8/20
full [17] 18/4 28/5
28/7 28/10 28/12
42/23 43/1 44/12
86/13 87/3 94/10
116/12 120/13 139/7
144/21 144/21 183/20

FUJ00142152 [1]

fuller [1] 136/1

fully [2] 31/21 169/11
function [6] 4/22
6/15 34/14 121/17
173/7 173/17

fundamental [9]
118/2 119/16 119/18
119/25 120/5 120/7

fundamentally [2]
96/4 161/21

further [22] 20/10
31/1 36/7 39/5 50/12
53/8 58/1 74/18 81/8
97/15 109/25 123/16
148/6 152/23 154/8
160/7 161/3 167/4
171/2 171/16 172/2
172/11

future [5] 103/22

184/24

G

gain [2] 98/19 174/5
garbled [2] 153/17
153/19

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3/18 3/25 4/12 10/25
11/4 71/2 109/19
111/8 150/11 171/4
183/14 184/16 187/2
Gareth's [1] 1114/5
gave [9] 7/11 20/2
38/19 50/13 79/14
100/20 106/10 140/5
175/22

general [5] 60/21
156/10 156/17 163/12!
172/25

generally [6] 4/15
31/23 39/25 108/23
162/21 180/19
generate [1] 105/6
generated [4] 56/24
58/8 60/12 89/4
generating [1] 66/1
Generation [1] 43/13
generic [24] 150/25
153/1 153/5 153/10
156/3 157/14 159/4
161/22 166/12 168/10)
169/1 170/5 170/25
172/17 172/18 172/21
174/24 176/6 176/18
178/14 178/25 180/11
180/21 181/1
genericised [1]
156/13

genesis [1] 1/20
genuine [3] 67/7 73/1
85/2

Geoff [1] 71/14

functioning [1] 119/3

120/18 125/20 180/20)

150/12 181/19 183/15)

get [42] 7/8 13/18

43/6 46/4 46/10 55/4
55/21 60/2 66/13
68/11 68/13 72/18
72/23 75/24 76/4
76/22 77/13 78/5
80/10 80/20 81/13

95/6 97/2 110/23
114/9 126/19 138/23
139/13 149/8 157/1
160/24 161/2 179/5
185/2

gets [1] 104/17
getsurrey.co.uk [1]
149/22

getting [7] 9/2 9/5
11/11 32/25 47/2
50/16 82/10

give [21] 18/11 18/20
25/10 26/1 29/7 29/15)
71/10 76/10 78/7
120/4 134/2 136/22

144/20 154/19 156/13
157/21 168/5 171/2
given [25] 20/3 33/2
33/5 54/4 62/20 78/24
102/20 129/3 130/24
132/10 132/11 132/21
144/6 145/12 146/5
146/17 148/24 149/12
152/1 153/15 153/19
159/5 183/11 184/23
185/16

gives [2] 76/14 172/7
giving [8] 52/18
56/23 78/9 83/20
83/21 100/23 108/11
140/20

GJ [1] 38/9

GJ/01 [1] 38/9
glance [1] 10/22

go [61] 2/19 3/5
10/13 12/20 22/8 24/5}
24/8 24/11 24/19
28/25 30/10 30/25
33/12 34/12 35/17
37/7 38/1 38/15 42/16
43/4 43/11 44/8 49/25
52/4 53/7 59/9 62/2
62/17 67/10 67/10
68/21 72/10 73/22
74/14 80/15 94/6
98/11 104/9 106/16
106/16 110/24 112/4
114/7 120/24 121/24
132/18 134/4 136/20
142/15 145/17 145/17I
153/23 153/25 155/14
157/14 159/3 163/3
164/16 168/23 171/16
173/1

28/14 32/12 42/6 42/7

81/20 82/5 84/7 94/12

139/11 139/22 140/18)

going [57] 2/16 12/2

41/17 41/18 42/13
43/6 45/19 52/12

62/13 62/13 62/17
63/2 63/13 63/15

67/20 71/13 71/13
71/19 78/13 78/13
80/18 84/18 86/17

100/11 106/5 106/22
107/8 110/13 110/25

133/8 136/4 136/20
140/17 142/13 151/8
153/12 154/19 158/6
165/24 166/6 170/6

186/10 186/14
gone [10] 37/15
89/19 89/21 98/1
134/13 143/13 147/19}
158/12 176/2 182/8
good [17] 1/8 1/9
61/15 68/19 82/23
84/21 84/24 97/12
98/9 117/18 117/19
119/7 134/18 149/14
154/25 155/12 173/10}
Google [1] 149/19
got [36] 9/8 9/11 10/3
32/23 32/24 33/19
34/10 35/2 37/5 43/11
48/14 49/15 49/18
52/22 54/14 54/25
77/15 80/14 94/1
103/13 119/3 125/23
129/1 132/5 132/18
135/25 141/12 142/20}
146/14 148/13 155/18)
162/22 162/24 176/17
178/12 179/6
grabbing [1] 155/1
greater [1] 165/10
gripping [1] 152/16
grounds [1] 125/6
group [2] 44/2
182/12

guarantee [2] 63/23
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13/15 13/20 14/1
14/12 16/24 72/6 75/6}
76/1 76/22 77/8 77/10)
77/13 77/15 77/18
77/20 77/22 78/2
78/23 79/8 80/8 80/10)
80/13 156/7 160/12
161/2 161/16 166/24
166/25 179/9
guidance’ [1] 159/23
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guilty [2] 150/7

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121/21 124/10 126/25)

171/23 181/14 184/19}

150/24
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had [254]
had a [1] 45/12
hadn't [15] 29/11
47/3 68/12 93/14
111/22 112/1 133/5
139/13 144/10 144/12)
144/24 146/14 147/1
155/10 178/16
Hadrill [2] 143/19
145/15
half [11] 33/21 125/3
128/5 128/12 128/22
129/2 130/14 131/18
142/20 145/23 146/23)
halt [4] 17/4
hand [5] 58/11 71/1
80/4 86/3 125/21
handle [2] 9/9 137/10
handled [5] 4/11
45/12 45/13 134/21
164/1
happen [3] 64/19
116/11 122/15
happened [21] 25/22
31/7 45/15 45/16 63/7I
63/18 63/19 84/10
91/12 93/14 122/24
124/20 128/10 129/17)
130/2 140/11 144/4
146/4 162/14 169/23
171/17
happening [7] 12/13
25/19 30/9 56/3 115/7
131/1 173/5
happens [2] 15/3
44/22
happy [8] 64/5
126/22 136/3 141/14
149/11 149/15 160/14)
185/6
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hardware [19] 16/11
16/16 17/9 17/20 18/3}
38/20 117/20 121/13
122/14 126/2 126/20
126/23 126/24 127/7
127/19 142/14 142/17)
148/20 170/21
harm [1] 168/21
Harvey [2] 182/19
182/23
has [46] 2/9 2/10
2/11 21/6 22/25 23/5
31/17 32/12 37/14
37/15 39/5 51/22 53/1
54/11 62/15 67/12
80/21 81/13 81/20
84/7 87/4 88/13 89/7
92/7 92/22 102/11
109/17 111/2 114/20

(58) FUJ00142152 - hasO
H

120/1 121/6 126/10

152/14 164/6 177/12

184/22

hasn't [1] 146/10
have [248]
haven't [7] 109/17

148/11 148/17 182/8

49/6 78/18 102/19
145/12 179/3

he [74] 2/8 2/11 3/8
3/11 3/12 10/21 11/4
14/21 21/15 21/18
50/15 50/16 50/18
50/19 60/23 76/7
84/21 85/7 85/8 86/7
106/20 109/19 111/8
114/20 118/3 118/13
118/17 118/19 118/21

119/2 119/3 119/5
123/6 123/7 128/2
133/1 133/3 133/19

146/19 146/21 154/21

155/20 155/25 159/6
160/6 160/7 162/5
162/5 164/25 182/24
182/24 182/25 183/4
he'd [2] 22/17 143/14
he's [2] 5/16 149/1
head [4] 10/9 83/17
159/19 159/20
heading [4] 41/20
91/6 98/15 176/11

83/11 83/18 141/5
141/9 148/1 161/4
171/19 175/22
hearing [3] 102/15
111/2 186/18
heavily [1] 8/17
hectic [1] 30/1
held [2] 45/6 88/4
Helen [1] 151/16
help [14] 3/22 4/25
13/16 74/6 75/24
80/22 84/4 121/12
122/6 133/25 137/12
149/1 160/4 162/21
Helpdesk [22] 17/8
17/12 17/18 27/21

has... [17] 115/3

136/18 145/23 146/16)
146/16 151/13 151/17)

177/24 183/18 184/16)

130/10 141/12 142/19)

having [7] 7/18 30/16

118/22 118/23 118/25}

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144/10 144/12 145/10)
145/12 145/13 145/13}
145/15 146/13 146/14}
146/14 146/16 146/18)

155/10 155/11 155/16}

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28/1 118/19 119/5
119/9 119/11 120/22
122/21 125/11 125/15)
125/22 134/13 134/17)
134/21 137/6 138/13
142/16 147/19 147/24)
helpline [2] 141/4
141/15
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26/2 68/25 70/6 136/3
136/7 136/11 138/3
139/6 139/14 140/6
147/24 178/10
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22/12 35/17 37/2 48/9)
62/3 63/7 64/23 65/23
67/17 74/19 80/17
83/10 100/8 107/22
108/15 114/19 116/12)
129/13 145/16 153/15)
154/2 162/12 166/23
170/10 171/21 172/12)
178/8
here's [2] 7/11 69/4
hesitate [1] 152/24
Hi [4] 1714/4
high [9] 30/22 68/13
71/23 75/2 75/21
128/8 129/14 146/2
156/16
higher [1] 75/22
highlighted [2] 2/9
69/9
highlights [1] 25/8
highly [2] 74/20 75/8
him [16] 3/9 30/6
118/9 118/14 133/4
133/21 133/24 133/25)
134/2 140/4 143/15
144/20 145/12 154/19)
156/12 160/9
himself [1] 146/19
Hinde [3] 3/7 3/7 4/7
hinder [4] 137/12
hindsight [3] 137/21
142/23 164/14
his [30] 2/11 5/4
10/15 10/15 10/25
11/4 22/13 22/16
22/17 30/7 30/23
54/14 61/4 62/16
80/24 85/4 85/7
109/19 111/8 118/3
118/15 123/8 137/17
141/5 141/14 143/11
154/16 154/18 157/16)
183/1
historic [10] 44/25
46/8 46/9 46/15 46/16
49/23 51/1 51/25
52/10 52/19
hit [1] 89/22
HIT' [1] 122/3
hold [5] 6/18 33/19

82/2 172/20 178/24
holding [3] 161/4
162/10 162/15
home [3] 139/1
150/19 176/2

hook [4] 185/2
hope [2] 70/21 164/6
hoped [1] 160/8
hopefully [2] 70/4
154/11

Horizon [183] 2/9
2/11 4/2 8/18 11/6
11/21 11/22 14/22
17/8 17/18 18/13
18/22 19/12 27/12

30/6 30/22 38/2 38/10

39/10 39/24 40/5
40/24 41/15 41/16
41/17 42/4 42/10

43/13 44/7 45/9 45/15

46/14 46/17 46/18
47/10 47/13 48/16

48/17 49/5 49/5 49/18

52/9 54/8 55/2 56/10
56/21 56/21 56/23
57/12 57/13 57/17
57/19 57/22 57/23
58/3 58/4 58/6 58/7

59/15 59/17 60/7 60/7

60/11 60/14 60/22

60/24 61/1 61/7 61/25
62/8 62/9 62/20 64/19

64/23 65/13 65/18
65/21 65/23 66/2
67/12 67/22 81/13
81/20 81/23 81/23
81/24 82/3 82/5 82/11
83/1 84/1 84/7 84/8
84/11 84/22 84/23
84/25 85/17 85/23
87/6 95/18 97/23
98/23 99/2 100/7
100/18 100/23 100/24
101/2 101/19 101/21
102/2 102/21 102/23
103/22 107/23 107/24
108/1 108/6 108/7
108/21 108/25 109/13
109/21 110/4 110/12
111/10 111/15 111/24
112/8 112/16 112/19
113/1 113/3 113/8
113/14 113/19 113/25)
114/15 114/25 115/1
136/15 147/8 148/12
151/17 151/22 152/6
154/6 154/6 154/12
154/13 154/13 155/1
155/2 155/6 155/10
155/13 156/16 158/9
158/24 160/8 162/8
163/9 163/14 164/22
164/22 165/12 165/15}
166/16 169/12 169/18}

170/1 170/8 170/17
177/2 17715 177/9

Horizon’ [1] 114/16
Horizon-related [1]
165/15

hours [1] 121/14
how [50] 5/5 6/10

43/5 46/13 48/24

86/13 86/21 86/24
87/25 90/17 91/3
92/16 93/12 94/13
100/12 105/7 105/10
106/7 112/9 113/22
115/16 119/17 123/6

151/8 152/17 156/8
156/16 159/8 160/12
164/9 170/12 170/12

Howard [1] 159/20
however [7] 42/23
62/24 74/19 114/24
146/9 160/11 169/14
Hughie [2] 158/10
158/19

human [4] 152/19
152/20 169/8 169/15
hypotheses [2] 30/7
30/24

hypothesis [1]
114/12

laccept [4] 112/23
113/23 140/1 166/17
l actually [2] 8/25
130/10

ladded [1] 167/3

l advised [1] 136/2

l agree [2] 52/3 74/17,
l agreed [1] 76/25
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34/1 34/10 35/9 50/14
179/8

lam [12] 15/1 39/2
48/2 59/8 91/15 103/3)
113/13 118/1 119/15
132/19 170/20 173/1

l another [1] 80/20

l apologise [2] 81/5
83/4

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173/3

lask [2] 185/21
186/14

lassume [2] 49/2
182/19

lassumed [4] 23/15
60/23 168/20 173/17

173/10 176/11 176/14)

177/17 182/15 183/10}

9/20 13/10 30/6 30/22,

50/15 62/5 74/3 74/20)
75/20 76/1 78/5 80/24,

126/21 134/16 142/10)

170/14 173/10 177/19)

lattach [1] 2/8
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I became [2] 17/14
176/24

I being [1] 180/18

I believe [17] 18/25
22/13 34/10 34/17
34/18 45/14 53/19
54/1 58/10 63/7 63/18
63/22 70/4 123/2
138/20 141/24 145/5
I believed [5] 39/19
81/14 118/22 166/8
169/23

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37/23 40/8 57/8 72/4
73/18 73/22 82/17
88/19 90/7 95/10
104/6 113/5 113/15
121/11 123/20 130/12!
131/12 137/21 156/4
171/14 181/20 185/13)
186/11

I can't [41] 10/7 10/8
26/4 31/10 33/10
43/22 50/7 56/17 57/3)
73/20 74/10 76/2
81/14 83/13 83/14
87/12 89/10 89/22
90/4 90/18 93/2 100/1
106/4 106/7 130/22
139/6 140/21 144/20
155/11 156/2 156/12
158/11 162/13 162/17)
163/1 164/8 164/8
170/3 174/9 174/15
181/7

I cannot [1] 57/9

I carried [1] 126/24

I certainly [4] 32/2
50/9 133/17 169/20

I clearly [2] 149/13
164/14

I commented [1]

6/21

I contact [1] 160/11

I could [10] 8/10
12/12 19/18 20/2 26/9)
75/24 97/14 129/9
149/9 160/16

I couldn't [4] 18/16

27/2 168/21 181/9

I definitely [1] 7/21

I did [32] 6/3 7/20

8/10 8/12 19/1 27/15

28/13 29/10 34/2

40/17 41/4 84/2 117/2
119/14 131/20 136/25)
137/4 137/25 138/3

138/4 141/7 143/15

144/20 149/19 150/16)

155/23 158/17 159/7

166/17 166/25 174/21

175/14

(69) has... - 1 didO
19/18 23/16 23/24
37/18 40/13 45/9
45/19 46/16 46/19
48/6 49/11 61/1 61/7
77/19 77/22 81/22
84/8 85/5 85/15 95/11
96/3 96/3 101/24

132/2 133/25 137/16
141/19 142/1 146/13
146/14 146/18 148/1
148/16 148/22 158/5
162/1 163/7 163/9

173/22 174/12 175/1
175/2 175/12 176/23
177/9 179/8 181/13
185/19

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6/6 6/18 8/25 14/18
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29/5 29/16 34/11 40/8
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58/17 59/19 68/17
69/11 72/10 73/21
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103/24 104/24 112/6
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122/7 122/19 124/4
124/4 130/20 139/24
145/14 147/25 162/22
162/23 166/1 172/3
174/16 174/16

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182/8
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13/19 13/21 14/12

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131/8 133/20 137/5
137/9 137/22 138/3
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139/7 139/12 140/18
143/2 143/3 143/13
144/14 145/21 149/5
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120/14 123/4 124/23
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129/4 129/24 130/5
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160/10 162/5 162/25

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171/21 173/21 174/1
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180/19 181/9 185/2
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140/9 146/12
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180/23 182/3
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55/24 56/15 57/24
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69/16 69/17 73/21
74/10 74/19 74/20
75/15 76/13 76/21
78/13 78/13 80/18
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168/6 172/3 174/13
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181/14 184/19 186/6
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103/18 104/1 112/4
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148/24 149/2 150/8
160/5 161/4 161/25
162/23 167/18 179/1
180/9 180/11 180/12
180/12 181/7
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102/15 104/1 122/23
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67/9 72/23
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37/24 39/4 66/16
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22/22 30/8 31/7 67/11
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IDRIS [2] 1/3 187/2
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12/20 12/21 14/23
17/16 18/11 18/20
19/10 19/20 20/2
20/23 21/12 21/14
22/8 24/6 24/11 24/19
25/11 26/13 28/13
28/20 29/6 29/20 32/1
35/17 37/7 37/22 39/3
39/21 42/16 42/20
44/18 44/25 45/24
46/1 47/3 49/25 50/7
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51/15 52/4 53/20
53/21 54/2 56/11 59/2
59/3 62/2 62/2 62/12
62/12 66/5 67/4 67/10
67/10 69/3 70/6 70/9
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73/23 74/14 75/24
78/22 79/6 79/8 82/12
85/7 86/1 86/13 87/23
89/2 89/20 90/20
91/14 91/17 92/19
93/22 94/6 94/13 95/1
95/7 95/14 95/16
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98/22 98/25 100/5
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106/16 107/2 107/14
107/17 108/4 110/19
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114/8 117/10 118/23
120/22 120/24 121/24
122/2 123/9 123/10
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126/16 126/24 127/11
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134/10 134/25 135/3
135/18 136/9 138/4
139/2 139/8 140/6
140/16 140/22 141/5
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150/10 152/13 152/23
155/14 156/18 159/3
161/4 162/16 163/16

168/23 171/1 171/13

173/4 175/15 177/16
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71/24 92/21 156/12
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43/10 46/20 47/2
55/12 59/12 59/13
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103/7 103/7 115/2
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95/10 130/9 145/18
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53/25 60/13 96/6
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83/3 120/1 161/19
161/21 161/25
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171/16 171/22 172/25}

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129/10 158/18
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169/15
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184/3 186/13
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183/9
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140/5 144/13 146/5
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(61) Iwas... - insteadO
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142/15 142/17 148/21
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173/13 179/25
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58/6 58/7 58/20 62/5
70/24 73/5 74/25 75/9
75/20 75/22 81/18
81/25 83/9 83/16 86/2
89/25 90/21 90/22
91/2 96/7 96/17 97/19
97/20 97/21 98/1
102/16 102/18 106/12
106/15 110/8 123/25
125/20 132/4 135/2
135/6 135/15 135/24
145/19 146/21 149/21
151/9 156/9 156/10
167/6 178/18 179/17
180/10 180/11 180/13
184/13

italics [1] 22/15

Item [4] 10/24

Item 3 [4] 10/24

its [5] 29/8 65/9
124/16 126/18 153/11

itself [9] 9/1 29/13
36/4 43/25 107/12
107/14 127/2 134/8
147/15

J

James [3] 159/22
180/6 182/12

Jane [3] 2/2 2/20
180/7

January [9] 36/13
41/14 82/22 87/7 88/8
89/13 93/9 97/6
128/21

Jarnail [23] 1/15 7/13
10/14 11/12 12/25
13/3 31/4 32/10 32/12I
82/13 103/17 109/16
113/18 131/9 153/17
153/19 160/2 160/11
160/14 160/25 161/4
169/4 174/17
Jarnail's [1] 160/5
JENKINS [13] 1/3 1/8
50/6 61/22 77/3 98/9

117/18 149/24 149/25
151/6 156/25 183/14
187/2
Jennings [4] 5/2 5/13)
1714/5 171/24
job [3] 9/20 119/1
185/7
Jon [5] 2/3 32/9 87/1
110/16 113/17
Jones [14] 9/16 10/4
10/16 12/22 13/4
13/20 20/21 20/24
21/13 49/14 76/6
80/14 112/12 164/22
journalising [1]
105/16
journalled [1] 104/17
JP [2] 50/12 50/13
judge [4] 78/13 111/2
151/12 176/1
judge's [1] 85/22
jump [1] 83/2
jumped [1] 84/5
jumping [1] 83/25
June [8] 1/1 65/9
69/3 84/16 101/10
126/6 126/7 128/21
jury [2] 152/7 176/1
just [137] 1/11 1/13
1/24 3/5 6/20 8/2 9/8
11/14 12/2 12/21
13/16 13/18 13/24
13/25 14/4 14/8 14/8
14/12 18/15 18/17
19/18 20/22 21/15
22/8 24/11 24/20 26/5)
26/10 27/20 29/20
32/12 41/17 42/16
43/19 44/18 48/23
49/7 49/19 49/21
49/25 50/3 50/5 50/11
50/19 52/4 52/15
53/11 53/23 56/12
56/19 57/8 60/5 61/12,
61/23 62/3 62/13 66/5
67/10 68/25 70/5
73/23 75/16 77/3
77/11 77/13 77/15
77/21 77122 77/23
78/5 79/1 79/12 79/23}
80/8 82/1 84/14 88/21
91/18 91/22 91/24
92/19 95/6 95/19
96/19 98/1 98/24
100/2 100/3 106/16
108/11 108/13 110/19)
110/19 111/18 114/8
118/13 120/2 120/14
120/24 121/16 125/7
128/4 129/25 136/9
136/20 137/17 138/6
139/8 140/11 143/17
143/20 144/14 145/17]
145/23 153/23 155/14

155/15 156/2 156/15
157/1 159/1 162/19
165/13 168/1 168/16
171/12 173/16 175/7
178/9 179/5 179/14
180/19 181/2 182/7
182/18 185/23 186/6

K

keen [1] 139/11

keep [9] 62/12 62/13
70/13 71/13 71/13
91/14 131/15 136/4
171/23

keeping [1] 160/13
keeps [1] 40/5

KEL [6] 25/8 58/15
58/16 58/18 58/20
59/3

KELs [12] 19/2 19/6
19/9 25/8 27/13 40/7
40/11 40/18 131/15
131/23 132/20 132/23)
kept [4] 9/2 9/3 9/4
127/2

key [1] 142/18
keying [1] 152/19
kind [5] 2/24 6/1
64/16 130/17 160/25
King [1] 167/19

kit [4] 136/15

knew [28] 4/5 29/16
29/16 39/18 50/3
52/18 55/10 60/10
60/12 68/6 97/8
101/22 123/6 123/6
125/7 128/15 132/16
142/9 158/4 162/5
165/2 166/1 166/3
168/17 169/24 173/14)
174/11 180/7

know [88] 2/23 3/24
4/6 4/25 5/7 6/18 8/5
11/20 12/19 13/24
14/4 14/18 16/7 18/8
19/24 20/8 20/9 23/16
23/20 23/22 23/24
23/25 24/22 26/11
28/21 29/1 29/5 32/22I
33/5 40/13 41/18
46/13 48/24 50/3 52/7
55/5 56/7 58/17 62/21
65/7 67/19 69/10 78/1
78/15 78/16 89/24
97/4 97/7 99/4 99/5
100/9 101/12 102/4
102/6 103/15 103/16
111/22 112/6 113/12
122/7 122/21 123/6
124/4 125/2 125/5
126/11 130/11 130/20)
132/25 137/6 1441/5
142/12 142/14 146/14I
146/14 146/18 148/18)

(62) instruction - knowO
K

know... [11] 148/20
158/5 159/7 165/8
166/10 167/17 171/13}
171/14 172/3 173/16
174/16

knowing [3] 87/24
115/23 123/5
knowledge [19] 12/6
12/6 25/1 28/16 28/20)
28/23 29/6 41/8 49/16}
68/18 101/18 114/3
117/7 119/4 130/16
130/21 132/6 165/14
173/10
knowledgeable [2]
29/14 167/2

known [38] 11/5
41/17 14/21 18/12
18/22 19/11 19/14
38/4 39/9 40/5 59/5
60/21 67/18 69/14
69/21 98/22 98/25
100/6 100/16 102/8
102/21 109/20 110/12)
111/9 112/15 113/1
113/18 113/24 116/13
129/7 130/18 131/18
131/23 133/2 133/15
146/17 146/22 164/11
knows [1] 11/22
KPMG [1] 183/25

L

lab [4] 48/4

lack [1] 169/16
lacked [1] 115/23
laid [1] 81/4

laptop [2] 143/14
145/4

large [3] 38/23 80/17
169/8

last [21] 3/17 21/18
39/7 44/18 49/21
56/22 62/2 92/23 93/5)
103/20 108/14 108/16)
136/14 149/19 149/20
150/9 162/11 168/24
1714/7 181/2 183/7
lastly [4] 84/14

later [20] 5/21 7/7
27/3 28/2 34/19 40/17,
42/10 43/9 44/11 53/8)
53/9 68/22 69/5
112/12 126/6 135/3
151/1 153/23 155/18
162/24

latest [1] 52/15

Law [1] 165/8
lawyer [9] 11/12
11/12 20/21 20/22
48/2 111/25 164/23
182/24 182/25

lawyer's [3] 110/12
111/1 111/19
lawyers [6] 159/13
159/14 162/24 165/2
167/19 183/7
lay [1] 34/8
layman's [1] 65/10
laymen's [1] 152/6
lead [4] 44/12 105/5
142/15 148/21
learnt [2] 29/10
103/18
least [9] 19/3 19/12
19/14 27/24 55/5
113/3 140/4 160/25
164/8
leave [6] 30/1 46/11
55/1 151/7 160/10
163/18
led [3] 41/25 134/6
147/13
Lee [2] 55/5 132/17
left [5] 5/5 46/1 54/22
86/3 135/4
left-hand [1] 86/3
Legacy [25] 41/15
46/18 48/17 49/5
56/21 56/22 58/3 58/6)
58/7 59/15 60/7 60/24
62/8 65/12 65/18
65/21 100/24 107/24
107/25 108/6 108/7
113/3 154/13 155/1
164/22
legal [38] 13/10
47/25 48/24 49/2 49/3
51/16 54/4 54/18
54/24 55/12 72/6
101/1 101/12 101/16
101/18 101/19 101/22)
102/2 102/12 102/22
102/25 103/7 103/14
103/17 133/15 151/25)
164/18 168/2 168/18
173/20 173/22 174/13)
181/10 181/18 183/11
184/23 185/3 185/14
Leigh [1] 73/19
Leigh-on-Sea [1]
73/19
lens [1] 45/18
let [4] 2/23 7/23
171/13 171/14
let's [6] 110/2 111/18
138/6 140/22 153/25
171/22
letter [1] 8/6
level [14] 17/20
30/22 75/22 115/21
118/15 128/8 129/14
141/15 142/3 146/2
156/16
levelled [1] 54/8
levels [1] 54/19

liaison [1] 183/4
life [1] 40/24
light [3] 51/7 140/16
151/24
lighter [1] 5/5
like [30] 3/20 9/17
57/5 58/3 67/6 77/16
83/16 108/5 112/2
121/13 122/7 122/20
123/23 126/13 134/11
141/14 142/14 142/23
147/17 150/8 150/11
152/18 154/4 157/1
158/15 158/25 160/24
176/25 177/22 177/25)
liked [1] 75/24
likelihood [1] 102/22
likely [4] 31/25 57/2
75/2 160/23
Lillywhite [1] 63/22
imit [1] 33/3
limitations [1] 61/9
limited [18] 12/5 12/5)
32/15 32/21 32/24
33/25 35/3 78/8 94/11
97/9 128/25 132/10
137/2 151/15 151/21
151/23 166/15 170/9
line [4] 9/18 16/5
174/23 175/3
lines [7] 91/24
102/10 103/2 108/14
108/16 164/14 181/9
link [2] 174/22 175/1
linking [1] 166/14
list [12] 27/22 44/10
92/22 99/18 141/3
157/22 158/10 158/12)
158/18 158/19 158/22
158/25
listed [7] 72/5 72/7
158/8 158/10 158/15
177/14 178/2
listen [1] 174/2
listening [1] 140/11
listing [1] 91/20
little [5] 28/16 140/14
143/20 152/16 153/23
live [5] 36/23 39/1
43/3 67/13 87/13
lo [4] 143/22
local [2] 38/7 115/21
locate [1] 129/21
locking [3] 15/3
108/15 108/18
log [12] 17/6 21/4
32/13 32/16 32/21
122/22 123/21 126/8
133/15 143/23 143/24
148/25
logic [1] 49/2
logs [35] 15/4 15/5
15/7 15/21 15/23
15/24 15/25 16/5 20/3}

21/21 23/1 30/10
30/12 30/17 30/24
31/14 31/16 32/6
33/19 34/1 36/25
39/20 39/22 109/24
119/10 119/24 125/22}
141/13 143/9 143/14
143/16 144/21 145/1
147/12 148/18
long [4] 18/9 31/23
89/7 106/7
longer [4] 3/18 3/25
88/4 185/11
Longman [7] 2/4 2/5
32/9 110/16 110/24
113/17 174/16
look [112] 5/23 9/19
10/10 12/14 12/21
14/19 16/17 17/8
17/18 17/19 18/4
18/23 19/2 19/7 19/13}
20/19 21/12 22/6
27/20 28/4 28/6 28/7
28/13 29/19 29/20
31/8 32/8 32/8 34/13
34/21 41/17 42/20
44/18 49/24 49/24
50/11 53/20 55/24
56/1 62/1 62/15 64/19)
67/4 67/6 67/9 68/24
73/16 80/15 82/12
84/14 86/17 89/2
90/21 93/7 93/8 97/5
98/12 109/2 109/13
110/15 120/7 120/22
120/23 123/3 123/9
123/15 124/24 125/7
125/15 128/1 129/4
129/8 129/12 130/13
131/6 131/12 131/20
132/5 132/7 132/11
132/21 134/24 135/1
135/3 138/5 138/6
139/3 140/10 140/22
142/16 142/18 143/1
143/17 145/13 146/24)
149/16 149/16 151/4
153/22 154/22 156/4
157/5 159/24 164/5
170/16 170/17 170/25}
171/22 171/22 172/11
181/22 181/23
looked [31] 4/13 4/14
18/10 21/16 27/22
32/2 34/11 37/5 38/11
39/20 50/5 53/24
56/19 60/20 63/9
68/25 85/16 93/22
101/7 109/15 109/24
127/25 137/19 138/14
141/22 144/3 149/2
149/5 154/14 157/7
160/5
looking [53] 11/14

12/3 13/9 13/19 14/12
16/19 19/6 19/24
24/12 24/20 27/6
27/19 31/1 31/5 34/6
36/19 37/19 41/11
56/2 61/3 61/23 65/6
71/16 72/25 73/7 74/7I
80/8 84/10 84/16
84/22 84/25 84/25
85/10 85/13 86/1
101/10 106/10 108/12)
109/3 110/8 114/4
117/21 127/24 144/1
144/7 145/8 148/8
149/9 156/14 158/13
159/14 171/2 180/22
looks [10] 57/2 57/5
112/2 122/7 123/10
123/23 126/13 150/8
150/11 154/4

loose [1] 100/17
lose [1] 81/23

loss [6] 38/21 90/20
98/19 98/22 99/1
100/6

losses [7] 39/5 82/21
82/24 94/24 130/2
134/11 147/17

lost [7] 15/2 22/19
23/3 86/15 87/17
94/22 94/24
lot [6] 49/7 59/7 59/8
81/9 133/25 136/21
lozenge [1] 165/22
LPN [4] 121/8

made [30] 7/16 8/9
15/8 17/19 20/14
21/21 22/25 28/13
30/11 31/17 36/6 37/3
39/6 50/5 51/17 58/22I
59/12 72/11 82/23
116/9 129/6 152/11
159/9 161/11 161/17
163/23 174/11 179/4
180/23 184/6
magically [1] 150/2
main [2] 100/13
145/8
maintain [1] 151/24
make [27] 7/19 13/6
14/25 18/16 24/2
35/15 36/7 39/12
40/17 43/9 49/7 64/10
68/11 70/11 71/15
77/19 77/23 93/20
96/10 105/22 109/24
116/4 137/23 153/21
164/13 176/22 176/23)
making [9] 21/24
23/4 48/11 59/10
62/23 64/1 64/9 64/18
162/22

(63) know... - makingO
malfunctioning [1]

118/17

man [3] 78/19 79/7
84/4

managed [2] 8/20
112/4

management [24]
6/25 7/4 7/17 62/6
62/7 75/6 75/10 75/11
77/14 77/18 77/20

77/24 78/2 78/22 79/7

81/7 94/12 161/6
161/19 168/4 168/8
168/12 179/9 182/3
manager [4] 9/19
159/21 182/25 183/2
managers [5] 3/8
9/14 159/16 159/17
162/16
manifest [7] 9/1
107/1 107/9 107/12
107/14 134/8 147/15
manifested [1] 43/25
manifests [1] 36/4
manipulate [3] 115/6
115/13 116/5
manipulating [1]
116/8
manually [1] 105/9
many [10] 40/5 49/16
81/12 87/25 93/12
97/1 97/1 142/10
152/21 152/22
March [13] 25/20
33/14 35/1 36/23 47/7
53/5 53/6 53/12 60/9
62/21 67/23 82/14
144/5
Mark [4] 32/10 86/5
86/5 92/22
master [4] 92/1 92/4
92/5 92/13
match [5] 36/17
44/22 59/3 59/4
129/11
material [4] 80/2
90/22 133/23 134/2
materially [2] 51/18
91/5
matter [2] 111/23
160/24
Matthew [1] 136/10
may [37] 5/21 5/21
10/7 15/10 22/22
30/12 33/7 42/11
42/13 43/7 50/8 55/16
67/5 71/6 72/7 72/8
72/15 85/8 89/8 89/9
89/18 89/21 89/24
93/19 97/6 97/17
113/6 120/25 121/1
127/8 128/23 139/22

154/4 162/17 176/13
177/19 178/2
maybe [6] 17/14
27/24 89/24 141/19
142/23 148/8
McLachlan [18]

84/18 84/21 114/18

140/4 144/6 144/17
145/2 146/6 146/9
148/10 148/25
McLachlan's [5] 6/5
6/9 34/7 35/9 114/12
me [69] 2/23 2/24
3/17 3/22 5/23 7/12
7/19 8/24 9/20 24/23
32/12 34/12 40/19
44/11 44/17 48/7
48/16 48/23 49/8
49/19 50/13 50/13
50/15 50/17 53/11
57/16 61/12 73/22
80/22 81/3 81/6
100/21 108/19 110/3
111/13 114/1 120/1
132/5 139/2 140/15
142/7 143/14 144/10
144/12 144/14 144/22)
145/14 146/11 148/9
149/24 152/24 158/22)
158/25 162/6 163/11
165/17 165/22 167/3
167/5 169/7 171/18
173/15 173/18 175/18)
178/6 179/10 181/11
181/21 186/1
mean [22] 7/4 8/13
8/19 14/6 30/20 43/1
53/11 58/16 70/23
75/21 87/24 93/6
102/7 121/16 122/6
139/10 149/7 162/10
166/13 173/9 183/12
184/23
meaning [2] 113/10
179/14
means [7] 12/3 16/5
30/7 64/9 69/10 75/18
126/11
meant [12] 17/3
27/11 63/4 75/9 76/15
87/6 113/6 172/16
173/8 173/17 175/7
185/2
meantime [1] 162/18
mechanics [1] 155/2
mechanism [7] 31/13}
65/24 66/1 67/22
68/10 91/20 160/19
mechanisms [2]
94/12 163/22
meet [1] 133/6
meeting [17] 43/14

22/12 30/3 34/16 74/5

130/25 132/25 133/18)

66/8 66/10 88/18
88/23 88/25 89/11
90/11 90/17 98/13

106/3 133/21 183/19
meetings [5] 88/15
88/19 88/22 99/8
99/15
member [1] 148/3
mention [12] 11/5
14/21 100/19 101/12
103/9 103/12 109/20
111/9 113/18 142/1
157/10 179/13
mentioned [11] 7/1
34/7 35/23 41/8 50/16
69/6 69/17 73/3 90/9
103/4 154/6
mentioning [3]
107/22 113/21 120/16}
mentions [1] 154/2
message [17] 18/4
28/5 28/7 28/10 28/12
65/16 93/25 121/8
121/18 121/21 122/4
122/11 123/22 124/13
125/16 127/9 153/8
messages [1] 126/16
met [1] 183/7
Michael [2] 182/19
182/23
middle [1] 121/1
might [22] 1/19 12/9
12/10 23/2 31/11 52/9
65/14 72/25 75/19
79/8 94/16 118/1
120/12 125/19 131/1
133/9 134/14 147/20
149/1 155/14 156/1
161/23
migrated [3] 57/18
60/4 60/7
migration [9] 56/20
58/9 58/21 59/1 59/15)
59/23 59/25 60/5
60/16
Mike [2] 182/17
184/16
million [5] 33/21
128/5 128/13 130/14
145/24
millions [1] 66/23
mind [11] 17/17
71/24 76/18 77/5
79/16 81/19 84/15
96/20 96/21 163/24
180/9
mindset [2] 47/17
80/25
mine [2] 5/3 118/16
minimal [1] 102/23
minimum [1] 43/10
minus [1] 70/20
minutes [8] 61/16

99/3 99/8 99/12 104/8

69/7 70/5 102/17
135/3 135/13 135/22
136/5

mirror [2] 122/2
122/14

mismatch [14] 25/11
57/20 57/21 85/25
86/10 88/16 89/3
98/11 99/1 100/16
102/19 104/4 115/20
165/9

mismatch’ [1] 36/10
Misra [30] 1/10 1/17

28/18 31/20 34/22
35/2 38/18 48/11
50/14 60/25 64/18
67/25 78/7 82/14
82/18 84/5 84/17
103/9 126/16 135/4
135/6 135/14 135/21
136/6 147/23 150/23
Misra's [25] 1/13
5/18 6/2 6/8 6/25 7/5
8/22 11/18 12/5 20/16)
22/8 27/7 29/9 60/10
64/25 81/2 101/23
114/4 124/12 136/24
164/25 165/4 165/5
174/6 175/19
missed [1] 68/12
misunderstanding
[1] 114/1
misunderstood [2]
72/15 113/23
moment [8] 12/2
12/3 50/19 86/17
130/22 140/21 152/15)
181/14
Monday [1] 146/15
money [8] 19/4 19/15)
81/13 81/21 81/23
81/25 84/7 136/16
money’ [1] 80/21
monies [1] 54/6
month [5] 31/8 75/3
107/11 115/18 178/13}
months [14] 31/25
52/24 74/25 87/9
87/23 88/14 125/8
128/18 132/10 137/2
152/22 168/10 169/9
182/1
months’ [1] 142/20
moral [3] 104/19
104/22 104/24
more [51] 1/24 2/25
3/6 5/5 5/7 7/7 14/10
16/8 20/4 23/5 25/22
27/17 34/20 39/25
45/3 46/2 50/1 58/2
59/8 65/14 87/9 87/23)
91/17 92/6 93/2 93/7
108/23 122/20 138/4

5/11 17/19 19/3 19/15)

138/16 141/18 152/16
160/23 162/21 164/9
166/10 166/13 167/2
168/11 173/2 177/7
180/15 180/16 180/20}
181/10 181/12 182/2
185/3 186/1 186/2
186/10
morning [14] 1/5 1/8
1/9 56/25 61/5 61/15
64/4 66/10 66/13
67/23 109/15 151/13
153/24 170/22
most [8] 51/4 54/17
75/5 91/1 107/1 107/8I
177/14 177/16
motive [2] 96/9 96/10
motives [1] 80/6
mouth [1] 142/14
move [5] 29/19 55/2
56/5 82/12 106/9
moved [2] 59/17
65/23
movements [2] 57/6
129/25
moving [4] 44/7
45/14 100/12 183/19
MR [78] 1/4 1/8 1/15
2/1 2/2 2/3 2/5 2/6 4/7I
10/16 20/21 20/21
20/24 21/19 29/22
31/2 39/9 50/6 50/20
52/22 52/25 54/22
60/21 61/22 77/3 83/5
83/14 83/15 93/4 98/9
106/20 109/17 117/18)
118/3 119/1 119/19
120/14 123/5 125/20
127/4 127/21 128/2
134/5 137/13 137/20
137/22 140/19 140/25)
141/2 141/9 141/13
142/9 143/19 145/15
147/2 148/1 149/25
151/5 151/6 154/25
155/8 156/1 156/8
156/25 157/6 157/16
157/19 159/4 163/11
163/12 164/5 165/4
165/4 169/7 170/2
174/15 174/16 187/4
Mr Beer [1] 52/22
Mr Castleton's [1]
165/4
Mr D‘Alvarez [1]
50/20
Mr Dunks [15] 2/1
2/2 2/3 2/6 118/3
120/14 123/5 125/20
127/4 137/20 137/22
140/25 141/9 142/9
148/1
Mr Dunks' [6] 119/1
119/19 127/21 137/13}

(64) mali

functioning - Mr Dunks'O
Mr Dunks‘... [2]
140/19 141/13

Mr Hadrill [2] 143/19
145/15

Mr Hinde [1] 4/7

Mr Jenkins [9] 1/8
50/6 61/22 77/3 98/9
117/18 149/25 151/6
156/25

Mr Jones [3] 10/16
20/21 20/24

Mr Longman [2] 2/5
174/16

Mr Norton [1] 54/22
Mr Singh [18] 1/15
20/21 21/19 29/22
31/2 83/5 83/14 83/15
109/17 151/5 154/25
155/8 157/16 159/4
163/11 164/5 165/4
169/7

Mr Singh's [6] 156/1
156/8 157/6 157/19
163/12 170/2

Mr Tatford [7] 39/9
106/20 128/2 134/5
141/2 147/2 174/15
Mr Tatford's [1]
60/21

Mr Wright [1] 93/4
Mrs [29] 1/17 5/18
6/2 6/8 7/5 8/22 17/19
19/3 19/15 20/16 29/9
31/20 60/25 64/25
67/25 84/5 124/12
126/16 135/4 135/6
135/6 135/14 135/21
147/23 164/25 165/4
165/5 174/6 175/19
Mrs Misra [14] 1/17
17/19 19/3 19/15
31/20 60/25 67/25
84/5 126/16 135/4
135/6 135/14 135/21
147/23

Mrs Misra's [14] 5/18)
6/2 6/8 7/5 8/22 20/16
29/9 64/25 124/12
164/25 165/4 165/5
174/6 175/19

Mrs Seema [1] 135/6

Ms [4] 1/6 2/5 82/18
171/24

Ms Eliasson-Norris
[1] 1/6

Ms Jennings [1]
171/24

Ms Misra [1] 82/18

Ms Owen [1] 2/5

much [19] 7/21 9/22
13/24 20/4 37/2 41/13)
46/2 50/10 60/4 82/6

82/7 105/14 116/2

159/2 174/17 186/13
multiple [4] 36/3
65/15 91/13 122/18
must [3] 96/12
114/25 152/17

my [97] 1/5 5/5 5/7
6/22 9/9 9/17 9/18
9/20 10/9 18/2 18/18
19/7 22/15 23/9 33/10
33/17 39/15 40/23
41/1 45/7 46/1 47/1
47/24 54/15 54/25
64/15 68/18 71/21
75/12 77/24 79/10
79/10 79/24 80/21
81/13 81/21 81/25
83/3 83/17 84/7 84/10
85/20 90/6 90/15
91/16 92/17 96/10
96/21 100/9 100/12
108/17 114/24 116/14)
116/15 116/20 120/9
120/13 124/8 124/23
132/5 134/16 142/8
143/14 144/4 147/6
148/20 150/19 151/11
154/5 154/24 155/3
156/7 157/12 158/16
159/21 160/12 160/17,
161/18 163/7 163/13
163/16 163/19 164/19)
164/20 165/1 165/5
167/11 167/23 168/14)
169/2 172/21 172/23
173/4 178/25 181/2
181/8 185/7
myself [7] 83/10
140/14 149/2 179/22
181/25 182/17 184/15)

N

name [2] 157/10
179/18

namely [6] 20/2 27/9
39/9 91/12 161/21
183/14

narrative [1] 56/11
narrow [3] 6/15
129/22 130/13
narrowing [1] 132/1
nature [5] 118/4
118/9 118/24 137/14
177/20

NB [1] 138/23
NBSC [6] 135/16
135/24 135/25 136/18)
137/8 137/9

near [3] 45/19 64/7
79/25

nearer [1] 171/14
nearly [1] 33/21
necessarily [3] 46/25

117/13 132/14 156/20)

93/14 147/10
necessary [5] 30/9
68/3 122/11 127/1
127/8
necessity [1] 117/4
need [85] 1/11 1/17
2/24 3/21 4/11 11/25
16/17 17/8 17/18 18/4
18/13 18/17 18/23
18/25 19/2 19/21
19/25 21/7 28/4 28/6
28/13 30/24 35/15
38/15 42/2 43/4 48/9
51/6 54/9 58/1 59/9
62/23 63/2 63/15
63/25 67/11 67/14
71/2 71/22 72/5 72/8
72/9 75/6 75/10 77/10)
77/18 77/20 77/22
78/2 86/12 86/20
91/15 93/7 93/8 94/2
94/10 94/12 94/24
95/2 95/7 109/8 122/9}
125/21 126/3 128/9
129/16 130/11 131/11
142/1 151/12 152/3
152/4 156/13 160/11
164/10 171/12 173/1
173/4 173/5 179/7
179/8 179/21 180/24
182/3 185/2
needed [35] 17/4
17/22 20/4 27/12
27/14 27/17 28/7 33/3
34/17 40/13 45/8
45/11 45/13 48/7
50/17 63/12 76/1
76/21 77/25 79/24
93/5 125/14 140/10
146/12 146/14 146/18I
148/2 160/17 164/13
164/20 165/6 166/18
166/21 168/1 168/21
needn't [2] 47/13
47/19
needs [5] 2/24 74/18
92/23 111/5 142/15
neither [2] 125/23
144/16
Nemesh [1] 177/25
nervousness [1]
133/14
net [1] 44/20
never [12] 25/23
48/16 48/20 49/19
50/16 61/12 95/5
100/21 144/6 171/19
175/22 181/10
new [5] 51/9 122/16
123/21 126/7 150/8
news [2] 84/21 84/24
Newsome [4] 159/22
182/20 182/21 183/3
next [17] 30/25 31/2

36/8 43/13 44/9 70/10
90/9 100/25 124/10
135/19 136/1 136/13
154/9 155/23 162/25
168/9 177/15
Nice [1] 150/11
niceties [3] 173/22
174/13 180/5
night [2] 143/6
149/19
no [128] 1/11 1/17
3/12 3/18 3/25 4/24
4/24 6/20 8/5 11/19
15/16 15/20 22/25
23/6 23/24 24/25 27/7,
28/22 28/23 29/1 29/5
29/6 30/11 31/5 31/9
31/16 32/18 36/12
36/21 38/15 40/18
44/11 47/9 48/7 48/23)
51/6 52/21 53/1 54/13)
54/22 59/13 59/19
59/25 64/22 67/2
68/17 69/21 71/4 72/4
74/11 75/22 77/22
78/15 78/20 79/19
79/22 81/3 83/8 84/2
85/9 87/24 88/1 92/5
94/25 95/13 95/13
96/10 99/7 99/9 99/11
100/21 101/6 101/15
101/21 102/13 102/15}
102/24 103/10 103/13}
103/24 104/1 109/4
109/7 110/8 115/5
117/4 118/13 119/14
120/1 122/23 123/7
126/12 126/20 128/7
130/9 131/3 136/25
137/4 139/18 140/15
141/10 141/12 145/12)
146/1 146/7 147/3
148/4 152/13 156/2
158/25 164/2 164/19
165/16 165/19 167/24
168/16 174/21 175/1
175/12 175/14 175/21
176/2 178/17 179/13
179/17 179/24 185/11
185/19
Nobody [2] 110/3
111/13
non [2] 55/10 107/15
non-civil [1] 55/10
none [9] 11/6 14/23
89/19 111/10 130/21
151/19 152/13 179/1
180/13
nor [3] 108/17 144/16
169/16
normal [20] 9/9 19/7
22/15 23/9 23/17 31/7,
118/5 118/10 122/25
123/4 123/5 123/6

123/7 124/6 124/16
124/18 126/18 126/19)
126/23 137/14
normally [4] 6/22
21/3 23/22 94/24
Norris [1] 1/6
Norton [2] 54/13
54/22
not [268]
note [11] 36/2 36/7
41/22 43/24 69/17
86/8 86/15 88/17
88/22 88/25 103/16
noted [2] 94/23
177/16
notes [1] 43/13
nothing [10] 62/19
109/25 122/24 141/23)
150/1 158/21 161/3
161/5 182/6 182/7
notice [2] 50/10
52/16
noticeable [1] 26/16
noticed [3] 25/15
102/9 103/3
November [1] 2/2
now [77] 3/19 7/23
8/7 12/7 12/18 12/19
15/14 16/22 18/9 20/7I
20/13 25/16 26/22
27/17 27/19 27/23
29/23 30/12 32/5 32/6I
33/14 33/19 35/16
37/19 37/20 40/8 42/4)
43/22 47/25 49/6 66/2)
TANT 82/15 83/13
88/14 89/23 90/2 90/3
90/19 93/3 96/18
102/7 103/11 104/6
110/8 110/21 113/11
113/23 119/12 120/20)
125/5 125/13 125/24
132/2 132/8 132/13
134/17 137/10 139/6
139/25 140/8 141/19
145/1 147/1 148/8
148/16 148/22 149/13)
150/11 161/25 165/8
167/6 173/15 175/2
178/18 181/11 181/24}
NT [20] 15/21 16/1
16/5 17/6 25/14 27/3
27/15 27/20 39/20
39/22 62/8 63/6 63/9
123/17 143/8 143/24
144/21 144/23 144/25)
148/25
NUM [7] 66/17 67/5
72/13 72/13 72/24
72/25 73/7
number [31] 2/9 3/10
TIT TI12 11114 14/19
20/14 42/7 42/13
43/23 56/11 62/22

(65) Mr Dunks’... - numberO
N

number... [19] 66/22
66/24 69/8 69/8 69/12
69/14 69/20 74/23
88/14 88/19 96/23
97/9 142/3 157/22
165/15 167/1 169/9
177/12 180/17
Number 20 [1] 56/11
number 3 [2] 11/14
14/19

numbered [3] 21/16
66/5 66/15
numerous [1] 148/19

(e)

oblivious [1] 175/15
obscure [1] 89/14
obscured [1] 141/17
obtain [3] 20/15
23/17 151/21
obtained [1] 36/25
obvious [8] 16/15
25/12 28/11 107/12
127/13 132/3 153/11
175/10
obviously [5] 44/5
62/19 75/21 103/14
150/4
occasion [2] 99/20
99/24
occasional [3] 9/5
38/23 126/20
occasionally [1]
124/17
occasions [4] 3/10
9/18 113/19 127/7
occur [9] 38/5 38/20
48/20 48/21 93/16
120/4 125/21 133/10
148/9
occurred [15] 30/16
33/8 36/1 36/4 48/16
48/20 49/19 61/12
76/6 85/17 89/15
100/21 121/7 126/21
130/12
occurrence [3] 89/18
89/23 124/19
occurrences [4]
92/22 93/4 93/9 93/13
October [19] 38/2
90/2 106/11 114/7
117/23 138/9 143/1
149/17 151/2 153/4
153/5 166/11 167/7
167/8 167/15 168/7
168/25 169/5 174/19
odd [2] 63/10 89/16
off [21] 10/8 44/14
50/12 53/21 55/14
61/22 83/17 86/2
87/16 87/17 87/23

98/10 126/14 127/2
134/22 135/25 154/11
159/12 161/7 182/4
185/2
office [117] 3/9 3/11
3/20 5/18 7/5 8/22
11/8 12/25 15/6 20/14
20/20 20/24 20/25
21/25 22/20 23/19
32/13 35/22 44/21
44/22 44/25 51/1
51/23 52/2 52/13
53/17 55/6 62/25
63/11 63/16 63/22
64/13 67/15 68/3 68/7)
68/11 70/1 70/7 71/16
71/19 74/22 75/20
76/12 76/17 76/19
77/1 777 77/12 77/15)
78/3 79/9 79/18 80/12
82/8 82/19 86/21
86/23 88/15 90/8
90/12 94/8 94/11
94/13 94/20 99/16
99/19 100/15 103/17
103/25 106/22 107/7
108/19 109/5 114/13
125/5 125/5 128/15
133/6 133/12 133/22
134/1 134/9 134/17
139/23 147/9 147/11
147/15 150/13 151/15)
151/20 151/23 157/13)
158/22 160/18 163/9
164/20 165/1 165/2
165/11 165/15 165/17)
168/8 169/24 171/5
177/13 179/22 180/8
181/4 181/17 183/4
183/7 183/8 183/11
184/7 184/14 184/22
186/9
Office's [12] 6/11
6/12 6/25 8/15 8/23
31/12 45/25 49/23
94/19 165/8 168/4
185/11
Officer [1] 151/16
Officers [1] 152/3
official [1] 2/25
officially [2] 138/23
139/13
often [2] 54/5 126/21
oh [9] 3/8 21/10 42/3
47/15 71/12 73/11
75/22 109/7 185/5
okay [27] 1/22 2/17
2/18 3/1 10/1 10/10
24/24 29/24 37/20
41/10 41/19 42/11
44/1 49/5 53/6 53/10
66/10 72/17 75/21
79/2 91/4 149/7
155/20 159/3 160/8

181/5 185/2

old [4] 25/17 26/23
87/9 87/23

on [225]

once [13] 25/19
55/11 65/14 92/6 92/7
94/9 111/19 111/20
111/25 112/1 113/17
113/17 137/22

one [81] 3/8 5/21
14/6 15/1 15/14 20/25
22/4 23/25 24/18 25/6
25/22 36/10 38/11
38/24 40/16 40/19
48/7 53/1 53/11 53/11
56/15 56/18 59/16
69/8 78/12 80/4 87/5
88/16 91/10 91/10
91/14 91/18 91/18
91/22 94/4 99/7 100/2
101/7 101/22 101/23
104/12 104/18 108/5
109/7 120/1 122/13
122/20 123/12 123/25
124/1 124/8 125/9
125/21 127/6 135/21
137/25 138/14 139/4
140/15 142/15 150/11
151/15 154/5 157/7
157/23 160/14 162/18
164/19 165/16 165/19}
167/9 167/18 171/6
172/8 175/17 178/12
178/19 178/20 178/20
181/2 181/21
ones [7] 10/9 68/12
68/13 112/21 149/9
158/13 158/16
ongoing [10] 95/17
101/1 101/4 101/18
101/22 102/2 102/12
102/20 102/22 103/7
online [54] 4/3 8/18
41/15 41/17 42/4
42/10 44/7 45/9 45/15)
46/14 46/17 47/11
47/13 48/17 49/5
49/18 52/9 55/2 56/10)
56/21 57/13 57/19
57/23 58/4 59/18 60/7
60/11 60/14 61/1 61/7
61/25 62/9 62/20
64/23 65/23 66/2
67/12 67/22 87/6
87/19 95/18 100/23
101/20 101/21 102/3
102/21 102/23 107/23
126/10 149/21 154/6
154/13 155/2 164/22
only [28] 25/21 40/16
71/25 78/12 83/10
89/15 90/5 91/14 97/5
101/3 107/24 107/25
108/6 115/25 122/13

128/16 128/24 129/1
129/8 131/6 132/15
132/17 142/20 149/1
156/4 175/21 185/21
185/23

onto [1] 131/5
open [2] 91/14
161/18

opened [3] 121/1
135/2 136/5
opening [1] 167/12
operate [1] 36/3
operated [3] 45/9
60/24 173/10
operating [10] 30/22

42/5 45/22 45/23 46/6

47/22 56/22 60/25
82/3 114/13
operation [3] 64/19
95/17 113/3
operative [5] 73/14
79/16 96/20 96/21
146/22

operator [1] 114/16
opportunities [1]
167/2

opportunity [2]
141/20 152/1
opposed [1] 182/21
option [1] 105/1
options [1] 41/24

or [163] 1/20 4/14
4/20 5/22 6/1 6/7 6/8
6/14 7/17 10/1 10/15
12/9 14/15 16/18
17/12 17/19 18/8
19/13 21/8 21/24
21/25 23/25 26/6
26/11 26/15 26/21
27/6 27/18 27/23 28/7,
29/2 29/8 30/2 31/6
31/12 31/18 31/25
32/5 32/15 32/19
34/19 36/1 36/15
38/25 41/12 42/18
43/17 44/23 45/17
46/23 47/7 47/19
49/17 50/8 52/23
55/10 62/4 64/17
68/22 69/9 74/6 77/10)
77/12 77/21 78/2
78/23 79/11 80/10
80/11 80/12 83/22
84/19 87/19 88/20
88/25 90/11 90/17
91/13 92/10 92/10
93/4 93/16 96/6 98/19
99/8 99/13 100/3
100/14 100/15 102/23}
103/6 103/7 103/8
103/25 105/7 107/20
108/19 109/11 111/24}
112/14 113/24 114/15}
115/18 117/4 118/6

118/11 119/21 120/5
120/11 120/12 121/19)
122/3 123/6 123/25
124/6 124/9 124/16
125/22 126/18 130/17
131/22 131/23 132/3
132/11 132/23 133/14)
133/14 137/12 140/4
141/8 141/22 142/3
142/3 143/11 145/6
146/21 146/21 152/14)
152/23 154/17 155/5
157/11 158/7 158/14
160/14 160/23 161/13)
161/13 162/18 164/8
164/11 164/11 164/20)
164/21 164/22 166/15)
169/16 174/15 175/23)
176/20 176/21 178/13)
182/9
oral [2] 7/1 140/19
orally [1] 136/23
order [11] 17/16
19/25 28/3 30/8 41/2
91/14 95/8 118/6
118/11 120/4 130/18
ordered [2] 111/2
151/13
organisation [1] 10/6
origin [1] 153/1
original [5] 53/11
53/12 70/14 70/16
178/5
originally [2] 72/11
167/15
originated [2] 12/19
39/8
originator [1] 83/5
other [62] 7/15 10/5
16/7 16/10 17/19
23/25 29/18 34/10
39/18 41/9 43/9 43/20
53/3 55/16 55/22
55/24 55/25 56/1
72/15 72/18 72/22
83/9 84/6 84/9 85/10
85/14 86/4 91/1 91/11
91/21 108/20 110/4
111/14 112/8 112/19
113/8 113/14 116/24
124/1 124/9 125/22
131/2 131/18 141/16
142/4 144/18 146/7
149/3 149/3 155/5
155/9 155/21 160/23
161/3 166/25 169/16
170/16 170/21 174/2
175/18 180/14 181/20)
others [11] 24/8
35/13 53/23 62/14
69/3 83/11 151/5
158/5 166/20 167/2
168/16
otherwise [1] 103/9

(6

6) number... - otherwiseO
[e)

64/17 148/6

our [8] 2/10 3/18 4/1
35/24 37/8 98/20
152/2 184/8
ourselves [2] 134/15
147/21

out [51] 1/11 7/20
12/1 13/1 13/3 17/5

42/10 42/12 48/4
49/17 55/3 66/13
68/13 70/21 70/24
71/1 71/6 72/25 73/1
80/11 81/4 90/16
91/23 96/20 96/22
98/20 104/14 105/14
106/6 112/24 121/14
122/5 126/24 131/18

177/8 177/23 179/10
180/4 181/13 184/5
outcome [1] 100/5
outside [10] 114/16
118/5 118/10 120/9
120/13 122/25 124/6

outstanding [4]
80/17 112/21 113/8
113/15

over [20] 25/12 31/18
37/22 42/16 59/17
74/25 75/2 84/18
92/19 94/6 124/10
139/23 152/22 157/1
162/7 162/25 164/16
168/9 169/9 182/1
overall [5] 73/9 93/18
96/25 149/11 163/23
oversight [1] 164/18
overview [1] 156/16
owe [2] 175/6 175/13
owed [1] 175/5
Owen [4] 2/2 2/5 2/20)
180/7

own [2] 12/6 186/5

P

PA [1] 10/15
package [1] 90/21
page [81] 1/23 2/19
2/19 3/5 4/7 10/14
12/21 20/20 22/6 22/9)
24/7 24/11 29/20
29/20 32/8 35/17 37/7
37/22 42/16 42/17
42/20 44/18 49/25
50/11 50/24 52/4
53/20 62/2 68/24
70/10 73/16 74/14
80/16 86/3 89/2 90/22

ought [4] 8/8 27/22

25/1 27/13 28/18 30/8
33/10 34/8 41/2 41/25

133/10 157/16 171/17)

124/16 126/18 137/14}

92/19 92/19 92/20
104/9 106/16 106/17
110/20 110/24 114/8

120/24 121/2 121/24
123/3 123/9 123/15
126/6 126/7 128/1
134/4 134/25 135/1

149/17 153/3 154/23
157/6 159/3 163/4
163/4 164/16 164/17
168/24 181/23
page 1 [5] 12/21
20/20 24/11 29/20
44/18
page 12 [2] 35/17
80/16
page 123 [1] 106/16
page 125 [1] 108/13
page 184 [1] 157/6
page 186 [1] 154/23
page 187 [2] 163/4
163/4
page 19 [1] 22/6
page 194 [1] 168/24
page 2 [10] 4/7 10/14
24/7 29/20 50/24
74/14 98/12 109/14
110/15 110/24
page 21 [1] 22/9
Page 22 [1] 134/25
page 3 [3] 3/5 89/2
104/9
page 37 [1] 120/23
page 4 [1] 117/23
page 40 [1] 121/24
page 45 [2] 126/6
126/7
page 5 [2] 2/19 68/24
page 548 [1] 164/16
page 58 [2] 128/1
145/17
page 59 [1] 134/4
page 6 [2] 1/23 90/22
page 67 [1] 143/18
page 7 [1] 92/19
page 8 [2] 94/6 114/8
pages [1] 124/10
paid [2] 75/4 160/17
paint [1] 51/6
pair [1] 145/3
Panter [2] 176/11
182/1
paper [3] 46/21
170/23 184/1
paragraph [32] 20/24
21/16 21/18 22/10
30/5 33/18 39/7 39/24
42/20 44/19 49/21
50/23 50/24 60/20
66/15 84/20 86/25

92/21 94/6 94/7 98/12
108/13 109/14 110/15)

117/23 117/24 120/23)

140/22 143/18 145/17)

89/2 90/9 91/24
108/14 112/14 114/9
154/23 162/11 163/5

168/25 169/2 184/21
paragraph 3 [1]
21/16
paragraph 369 [1]
108/14
paragraph 4 [1]
66/15
paragraph 541 [1]
154/23
paragraph 545 [1]
163/5
paragraph 574 [1]
168/24
paragraphs [2] 1/12
84/19
paragraphs 326 [1]
1/12
parallel [1] 184/15

118/10 122/25 124/7

part [33] 9/17 16/2
20/23 21/18 39/24
54/18 54/20 55/11

58/21 59/1 62/1 63/5
76/23 83/3 90/21

101/13 102/25 103/1
103/18 104/7 112/23
116/18 119/2 136/22

154/18 177/15
Participants [1]
186/15

particular [36] 12/13
13/4 15/2 25/16 25/21
26/22 29/12 49/21
52/17 57/3 57/10 59/5
63/8 63/13 63/23 76/3
79/24 80/9 81/8 89/20
93/1 94/5 128/10
129/17 130/25 131/1
131/11 131/12 138/2
146/4 146/6 153/12
164/2 165/7 174/20
175/21

particularise [1]
177/18

particularly [5] 13/5
13/20 45/10 73/21
183/5

parts [1] 66/20

party [2] 50/2 75/16
pass [4] 62/25 63/11
63/16 150/17
passage [2] 54/2
63/25

passed [3] 50/9
144/12 165/1

passes [2] 5/22

166/19 167/12 168/24

parameters [7] 118/5

124/16 126/18 137/15

55/19 56/20 57/6 58/9

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21/15

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52/9 52/19 108/20
108/25 109/12 110/4

152/13 156/9 173/15
173/18 183/13
Patel [5] 171/3

180/12

patterns [1] 130/17
Pause [1] 56/16
payments [14] 25/11
36/10 36/17 85/25

98/25 100/16 102/19
104/4 115/19 165/9
PC [1] 122/2

pdf [1] 138/18

62/3 91/18 91/20
91/22 92/1 92/1 92/5
92/13 138/16 138/18
139/3 139/6 140/3
141/22 141/24
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27/13 37/12 40/6
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91/13 91/22 131/15
131/23 132/20 132/23}
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20/22 21/13 29/22
31/2 33/15 62/14 65/7
67/20 68/9 68/17 69/4,
71/18 74/16 76/4
84/20 110/16 110/20
149/19 180/6
Penny's [1] 180/7
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20/24 84/19

people [17] 17/19
44/2 81/9 83/9 91/16
99/18 109/5 137/7
147/8 147/10 173/14
175/18 180/4 182/13
186/2 186/7 186/7
people's [2] 84/22
84/25
per [6] 28/8 28/9
69/17 89/1 164/7
167/19
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perform [2] 4/22 86/6
performed [1] 173/18
performing [4] 6/15
22/10 34/15 173/7
perhaps [8] 21/6
73/13 83/15 96/14

111/14 151/10 151/18)

171/24 172/20 177/25)

86/9 88/16 89/3 98/10)

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137/6 153/11 164/15
166/20

period [44] 19/3
19/14 21/2 23/17
23/19 23/20 23/22
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31/21 31/24 31/24
32/16 32/21 32/25
33/1 33/3 33/7 33/25
35/3 43/23 52/23 64/6I
64/24 74/25 75/3
124/23 125/2 125/8
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128/25 129/2 129/6
129/11 131/17 137/2
142/21 144/21 148/14I
153/7

periods [2] 31/14
33/6

persisted [1] 25/11
persistent [1] 127/20
person [4] 1/6 3/12
7/9. 12/25

personal [4] 25/1
28/16 28/20 68/18
personally [1] 11/20
persons [1] 185/23
Pete [7] 75/4 159/22
182/17 182/20 182/21
183/3 184/16

Pete Sewell [1] 75/4

Peter [2] 159/19
182/21

Peterborough [1]
171/25

phase [1] 42/8

Phil [3] 54/13 74/2
74/9

phone [1] 9/5

phoned [1] 50/15

phrase [3] 83/6 84/6
107/20

pick [1] 163/18

picked [8] 16/13
16/14 16/18 88/3
96/17 96/17 140/11
164/1

picking [2] 96/19

97/17

picture [2] 158/23

166/10

pilot [8] 42/4 42/8

43/23 56/3 56/4 56/10

64/6 64/23

PinICL [1] 138/5

PinICLs [14] 18/14
18/23 19/8 19/13

27/13 40/6 40/11

40/18 131/15 131/20

131/22 131/22 132/20}

132/23

piqued [1] 140/2

place [11] 23/11 43/6

44/14 60/5 61/2 92/11

(67) ought - placeO
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place... [5] 117/2
131/25 164/3 164/7
179/24
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64/21
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152/18 164/6 165/10
plan [1] 86/22
play [5] 16/9 19/3
19/14 131/19 131/24
plea [1] 162/21
please [122] 1/10
1/19 1/23 1/23 2/19
2/23 3/5 4/7 6/20 7/22I
9/4 9/4 10/10 10/13
12/20 20/23 21/12
21/14 22/6 24/5 24/6
29/19 29/20 30/25
32/8 32/9 33/12 34/12
34/21 35/17 36/7 41/7
41/11 42/3 43/11 44/8)
44/18 49/25 50/21
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56/6 61/16 62/2 62/12
63/4 66/5 67/10 68/24)
69/4 70/9 70/9 73/16
73/23 74/3 77/3 80/15)
80/16 82/13 86/2
88/10 89/2 90/21
92/20 94/6 94/7 98/3
98/11 98/12 98/16
104/9 106/9 106/16
109/13 109/14 110/15
110/15 110/21 114/7
114/8 117/13 117/23
119/9 120/23 120/23
121/24 123/9 123/12
123/15 124/13 128/1
134/4 134/24 134/25
135/1 135/18 136/4
140/23 143/1 145/17
151/4 152/24 153/22
153/23 154/22 156/19
157/2 157/5 159/24
160/4 163/3 164/16
168/23 171/1 172/11
176/9 176/10 176/10
178/4 179/11
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pleased [1] 85/4
plus [1] 70/20
pm [8] 98/6 98/8
117/14 117/16 126/10)
156/21 156/23 186/17
POA [1] 3/13
point [35] 8/3 17/14
17/16 19/1 19/17
21/25 23/4 23/13 27/9
32/4 35/14 56/3 66/6
67/10 72/11 75/13
84/11 90/5 90/16 92/6
93/15 97/13 98/24

100/25 101/14 103/20)
142/5 155/1 159/15
171/21 179/4 180/9
180/23 180/24 183/1
pointed [1] 30/8
pointing [1] 126/24
points [6] 10/22
104/2 109/17 111/6
154/5 154/9

POL [3] 54/9 72/6
86/13
POL00001643 [1]
34/23
POL00028838 [2]
88/10 98/11
POL00029084 [1]
86/1

POL00029406 [3]
106/10 127/25 143/18)
POL00029426 [1]
140/22
POL00049658 [1]
1/18
POL00054220 [1]
29/19
POL00061793 [2]
119/10 134/25
POL00093961 [1]
22/6
POL00096978 [2]
151/4 153/24
POL00096983 [2]
153/22 153/25
POL00097061 [1]
1714/1
POL00097137 [1]
176/9
POL00169122 [1]
32/8
POL00175839 [1]
82/12
political [6] 74/20
75/8 75/14 75/16
75/25 76/10
politics [3] 75/16
75/21 79/20
POLSAP [3] 94/20
104/17 105/16
poor [2] 81/9 97/20
poorly [1] 81/3
popped [1] 93/25
Porter [1] 62/15
Porters [7] 67/17
69/16 71/24 73/20
74/8 76/8 76/9
position [6] 29/7
29/14 36/18 47/25
66/21 139/19
possibility [5] 55/15
55/22 94/15 127/6
149/1
possible [12] 22/22
38/6 51/6 72/19 72/21
89/17 90/13 91/14

116/24 129/23 146/21
178/6
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19/22 20/8 23/2 38/21
44/25 46/8 46/15
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83/13 83/16 110/10
142/25 174/15
post [129] 3/9 3/11
3/19 5/18 6/11 6/12
6/24 7/5 8/15 8/22
8/23 11/8 12/25 15/5
20/14 20/19 20/24
20/25 21/25 22/20
23/19 31/12 32/13
35/22 44/21 44/22
44/25 45/25 49/22
51/1 51/22 52/1 52/13)
53/17 55/6 62/25
63/11 63/16 63/22
64/13 67/14 68/3 68/7
68/11 70/1 70/7 71/15)
71/19 74/22 75/20
76/12 76/17 76/19
77/1 77/6 77/12 77/15)
78/3 79/9 79/18 80/12
82/8 82/18 86/21
86/23 88/15 90/8
90/12 94/7 94/11
94/13 94/18 94/20
99/16 99/19 100/15
103/17 103/25 106/22
107/7 108/19 109/5
114/13 125/5 125/5
128/15 133/6 133/11
133/22 134/1 134/8
134/17 139/22 147/9
147/11 147/15 150/12)
151/15 151/20 151/23
157/13 158/22 160/18
163/9 164/19 165/1
165/2 165/8 165/11
165/15 165/17 168/3
168/8 169/24 171/5
177/12 179/22 180/8
181/4 181/17 183/4
183/7 183/8 183/11
184/7 184/14 184/22
185/11 186/9
postmaster [5] 44/23
45/2 46/23 51/3 51/11
postmaster/clerk [1]
45/2
postmasters [6]
80/20 81/12 81/20
81/24 82/4 82/9
postmistress [10]
135/9 135/23 135/24
136/2 136/3 136/7
136/10 136/12 136/19}
149/18
potential [5] 54/7
101/1 102/11 102/19
103/7

potentially [6] 50/25
51/12 62/22 63/13
64/2 120/21

pounds [1] 152/22
practice [1] 183/21
prayers [2] 66/6
66/11

pre [4] 1141/2
preferred [1] 185/7
prepare [1] 155/8
prepared [5] 41/13
134/1 151/17 155/6
167/6

preparing [2] 136/22
175/24

present [13] 4/11
22/9 41/24 43/15
77/11 88/23 88/24

115/18 151/12 151/19}

175/19 175/21 176/1
presented [5] 71/22
73/8 75/5 158/25
166/11

presenting [1] 71/25
presently [1] 112/6
pressing [1] 32/4
pressure [3] 8/21 9/1
9/6

presumably [5]
69/12 70/7 81/15
81/19 139/10
presume [1] 2/13
pretty [1] 70/4
prevent [1] 14/2
previous [5] 21/3
44/14 69/17 157/22
171/19

previously [3] 7/1
115/18 126/17
primarily [1] 170/11
primary [2] 51/19
93/1

print [2] 122/3
122/10

printed [1] 58/23
prior [1] 3/20
priorities [1] 160/12
priority [2] 68/13
161/8

Pritchard [1] 159/20
privileged [1] 139/19
probably [21] 20/10
31/22 37/20 39/11
44/15 53/12 66/24
74/18 74/19 86/20
87/2 87/4 88/7 89/13
91/5 103/12 112/17
127/13 137/19 147/25}
150/19
problem [106] 8/19
11/25 13/7 15/1 15/14}
25/18 25/21 27/1 36/1
36/18 36/22 37/10
37/11 37/14 37/17

41/25 43/10 54/10
55/1 55/2 55/4 55/19
56/17 56/18 56/20
57/4 57/10 57/16 58/3
58/5 58/6 61/1 63/14
65/11 67/1 67/1 67/2
67/24 68/2 72/12
73/10 84/8 86/8 86/9
86/13 86/14 86/21
87/1 88/21 89/5 89/9
89/12 89/15 89/18
89/22 90/5 91/17
91/23 92/6 92/8 92/10}
92/12 93/1 93/4 93/15]
93/19 93/24 94/1
94/12 95/1 95/10
95/21 96/23 97/1 97/7I
97/9 100/6 103/5
107/2 107/5 107/11
121/4 121/13 121/15
123/24 123/25 124/2
124/15 131/2 134/6
134/6 134/8 134/10
135/8 139/8 141/24
147/5 147/7 147/13
147/14 147/16 148/5
149/10 156/6 183/10
184/22
problematic [3]
30/19 50/25 127/11
problems [62] 2/9
2/11 11/5 11/17 11/21
11/22 14/22 16/7
16/10 17/2 18/12
18/22 19/2 19/11
19/14 37/23 39/9 40/5)
42/7 42/8 42/9 44/6
48/10 48/12 49/4
50/18 60/23 81/22
82/11 84/11 84/22
85/2 95/17 106/21
107/1 107/7 107/8
108/20 108/25 109/3
109/4 109/6 109/12
109/20 110/4 110/12
1114/9 111/14 111/24
112/15 113/1 113/18
113/21 113/24 125/10)
136/14 144/24 147/3
163/17 163/21 165/11
165/16
proceedings [9] 54/5
54/18 54/24 106/13
133/16 139/15 173/20)
181/18 185/3
process [15] 16/2
22/21 31/14 40/17
58/10 58/21 59/1 63/5I
91/15 92/16 92/18
105/15 124/2 177/14
184/4
Process’ [1] 183/23
processed [1]
160/22

(68) place... - processedO
Pp

produce [11] 2/14

60/3 152/21 154/8
155/23 165/18 169/8
produced [22] 26/8
27/11 38/2 56/22

64/20 66/25 67/21
68/1 68/20 92/22
144/4 155/18 160/9
176/16 176/17 177/3
177/7 180/10
produces [1] 68/22
producing [2] 38/17
65/18

products [1] 136/8
professor [25] 6/4
6/9 22/12 30/3 34/7
34/15 35/9 84/18
84/21 114/11 114/18

140/4 144/6 144/17
145/1 146/6 146/9

150/3 150/21
Professor
McLachlan [8] 30/3
84/18 84/21 114/18
132/25 133/18 146/9
148/25

Professor
McLachlan's [2] 6/9
35/9

profile [1] 71/23
Programme [1] 3/8
progress [3] 69/12
75/1 86/24

prohibition [1]
133/14

prompt [2] 93/20
93/22

prompted [1] 108/18
properly [5] 10/7
19/25 46/5 82/1 171/8)
proportion [1] 96/22
proposal [3] 160/15
160/19 183/8
propose [1] 161/1
prosecute [1] 64/14
prosecution [34]
1/16 3/18 4/1 4/16 6/8)
11/12 12/19 23/10
23/13 31/12 31/13
45/11 64/7 67/13
67/25 74/22 76/17
77/7 77/12 78/4 79/9
79/18 80/5 80/12
106/19 151/11 151/13}
156/4 157/10 157/12
158/9 168/4 183/5

processes [1] 164/3

10/12 26/3 26/12 38/9}

57/17 58/9 59/23 60/6

130/25 132/25 133/18)

148/10 148/25 149/24}

progressed [1] 67/13

186/10
prosecutions [19]
23/15 45/18 45/20
45/22 68/7 68/8 76/20
84/12 157/23 158/3
158/3 158/24 181/4
183/14 183/15 183/17)
184/25 185/9 185/12
prospect [1] 139/14
protect [1] 51/20
prove [2] 54/10 84/5
provide [26] 5/17
8/22 11/2 14/5 14/14
15/5 15/25 21/5 21/21
23/14 28/24 89/25
103/21 108/19 108/24)
109/11 110/3 111/13
114/14 150/24 156/2
157/11 158/23 162/16)
180/14 184/8
provided [13] 6/4
6/13 15/7 21/3 22/7
67/11 69/20 72/3 72/5
141/3 144/22 146/10
154/24
providing [8] 14/6
80/3 80/6 81/2 108/10
156/16 158/22 161/21
proving [1] 30/23
provision [2] 4/19
164/19
publicity [2] 95/20
151/25
purely [4] 6/12 58/7
59/15 59/22
purpose [8] 41/22
51/19 59/3 106/1
118/14 155/6 170/5
170/9
purposes [4] 22/9
83/20 87/14 155/1
pushback [2] 178/13
1791/5,
pushed [1] 180/12
put [17] 12/9 13/14
13/16 13/22 14/16
42/2 43/3 45/8 63/12
63/15 63/19 80/22
109/8 122/16 132/8
136/2 142/13
putting [4] 14/3
14/11 61/11 110/6

qualifications [1]
166/21

qualified [2] 113/16
182/25

qualitative [1] 119/24
queries [1] 87/21
question [65] 5/7 7/9
7/12 14/9 14/20 15/10)
17/16 18/12 18/18
18/21 19/10 19/17

26/21 26/24 28/3
28/23 29/2 29/3 33/9

45/4 49/9 51/12 60/21
61/4 61/9 77/3 78/16
78/18 91/8 107/6

109/22 110/11 110/11
111/15 111/18 111/23

113/5 113/22 113/23
114/2 115/14 116/18
119/21 120/10 127/18}
139/25 143/21 145/22
154/17 154/19 161/15}
163/6 167/21 175/9
question’ [1] 51/5
Questioned [2] 1/4
187/4
questioning [1]
130/23
questions [31] 5/1
5/2 5/4 5/16 7/18 29/4]
30/20 54/14 71/20
74/23 78/8 79/15 95/4
95/9 95/23 96/1 96/8
97/23 105/5 105/7
106/18 107/24 108/4
128/2 143/16 143/19
143/22 145/14 181/2
185/21 186/14
quibble [1] 177/9
quick [1] 67/16
quickly [3] 34/18
43/6 95/6
quite [13] 2/5 2/6 3/9
4/2 30/21 66/12 89/17
114/18 141/14 142/7
160/16 163/9 168/6
quoting [3] 118/13
118/14 120/17

R

Rachael [2] 176/11
182/1

raise [5] 9/13 58/15
58/18 74/23 86/20
raised [18] 2/11 2/25
9/18 16/24 35/22
36/14 39/3 50/21 59/2
91/17 96/2 109/5
139/4 154/21 158/9
158/24 160/22 180/20
raising [6] 36/12
108/17 160/19 162/2
165/1 177/17

range [1] 129/22
rare [1] 38/6

rate [1] 60/4

rather [31] 9/10 9/23
18/2 19/8 26/6 40/15
45/2 46/2 46/11 46/23
51/3 51/11 52/16
54/19 58/4 73/7 82/10

19/19 19/23 20/2 21/2

39/8 40/2 40/10 40/14]

112/14 112/18 112/25)

132/4 134/22 141/3

185/8

raw [4] 34/1 65/24
66/4 164/10

re [2] 95/2 106/18
Re-examination [1]
106/18

reached [1] 106/3
react [1] 89/7
reaction [2] 9/9
178/24

read [21] 2/16 12/10
56/12 56/16 74/3
TAIT 78/14 82/15
107/15 113/7 119/19

124/11 138/15 141/8
151/8 178/4 179/3
184/19

reader [1] 39/17
reading [5] 37/22
57/24 73/17 119/7
127/21

ready [1] 151/14
real [4] 29/2 29/17
67/8 130/11

realise [20] 7/23 7/25
8/3 8/7 8/8 12/18

125/13 125/24 129/1
129/5 132/2 132/8
134/17 140/8 173/15
175/1

realised [3] 128/15
161/25 173/6
realising [1] 71/9
really [31] 4/15 12/12
13/9 13/24 14/14
14/16 23/16 30/20
31/10 34/19 55/9
56/16 66/12 74/7
74/21 76/16 91/9 92/3
114/24 118/15 118/21
118/21 129/23 130/5
131/4 153/16 161/12
173/8 174/12 178/9
179/5

reappear [1] 36/8
reason [15] 10/3
49/10 57/21 59/5
83/10 97/18 107/22
115/25 145/8 149/23
149/25 150/20 168/20
174/7 186/9

reasons [7] 14/2 84/9)
103/14 168/18 181/10
181/11 185/18
reboot [1] 126/13
reboots [1] 124/14
recall [9] 5/17 59/10

83/5 84/12 97/6 111/1
111/23 113/20 118/16)

149/24 161/10 179/22}

re-introduce [1] 95/2

119/22 119/23 122/24)

27/17 35/16 48/6 49/9)

73/21 99/6 101/12
103/23 108/24 181/6
186/11
recap [1] 169/7
receipts [14] 25/11
36/17 57/6 85/25 86/9I
88/16 89/3 98/10
98/25 100/16 102/19
104/4 115/19 165/9
receive [1] 166/25
received [7] 6/1 8/8
10/12 73/24 121/5
126/17 185/15
receiving [4] 7/15
7/25 8/4 36/4
recently [1] 167/18
recognise [3] 119/10
119/12 158/17
recognised [2]
158/14 158/14
recollection [5]
74/11 99/7 99/11
101/16 102/24
recommendation [1]
58/11
recommended [1]
42/24
record [16] 45/4 51/5
51/14 51/24 65/9
65/14 66/19 72/4 92/1
102/18 120/25 123/16
135/19 169/12 169/22)
170/18
recorded [11] 38/7
45/5 65/16 81/10
98/14 98/21 100/8
102/16 114/25 122/21
135/8
recording [2] 170/13
170/21
records [33] 17/8
17/18 22/20 22/21
27/21 32/11 35/24
37/8 40/6 43/24 44/21
65/3 65/9 66/24 67/8
67/14 68/19 68/21
70/14 70/16 71/21
71/25 72/3 120/22
125/10 133/1 134/24
136/22 139/20 142/16)
146/10 146/17 146/22)
recovery [1] 54/6
recreated [1] 121/19
rectify [1] 124/15
refer [4] 15/14 16/3
91/10 163/7
reference [17] 1/11
1/14 1/17 7/4 15/18
15/20 37/7 38/15
80/18 128/12 159/9
161/23 163/12 183/25)
184/2 184/5 184/18
references [1]
157/21

(69)

processes - referencesO
R

referred [7] 66/11
137/25 138/1 149/24
150/21 163/14 170/23)
referring [18] 15/15
15/16 15/22 15/24
31/19 60/24 102/1
114/19 115/10 115/15
118/15 120/14 139/12)
157/6 159/25 162/11
173/12 173/14
refers [1] 72/13
reflect [7] 39/23 44/3
81/11 81/19 82/4
104/3 161/20
reflected [1] 27/16
reflecting [2] 83/8
83/18
reflection [1] 141/17
reflective [1] 45/5
reflects [1] 97/21
regard [1] 176/21
regarding [2] 148/19
154/6
regression [3] 42/23
43/1 43/4
regular [3] 66/8
105/24 149/9
reject [1] 85/22
rejected [3] 115/22
115/25 116/1
relate [1] 23/3
related [3] 165/15
172/14 172/15
relates [2] 41/15
62/20
relating [5] 23/1 23/6
23/17 66/24 92/12
relation [9] 5/18
20/16 20/23 35/22
98/13 128/21 139/19
147/3 172/22
relatively [3] 87/15
96/22 153/7
release [1] 36/23
relevance [2] 61/7
61/13
relevant [26] 20/15
30/10 30/17 36/24
37/24 47/23 48/17
49/20 61/2 67/24 68/8)
85/5 85/15 87/16
100/21 100/25 101/24}
101/25 114/24 116/25)
117/1 122/19 129/2
131/19 142/21 148/9
reliability [7] 27/12
45/8 76/11 176/14
(77/1 177/4 177/8
reliable [2] 72/14
73/6
reliance [2] 64/14
64/20

relied [3] 55/6 127/21
185/18
reluctant [2] 13/6
14/25
rely [3] 126/22
169/25 170/7
relying [3] 64/10
123/4 127/4
remaining [1] 178/1
remember [57] 3/7
10/7 10/8 14/19 17/1
18/9 24/16 26/4 26/10
33/10 43/22 49/21
50/7 56/7 56/17 57/3
57/8 57/9 74/7 74/8
74/11 76/2 79/12
81/14 83/13 87/12
89/10 89/23 90/4 90/7
90/18 92/25 93/2 99/9
99/13 100/1 100/3
102/15 104/24 106/4
106/7 138/22 139/6
140/21 144/20 155/11
158/11 162/13 162/17)
162/20 163/1 170/3
174/9 174/15 1814/7
181/20 185/13
Remind [2] 87/11
182/23
remote [7] 105/18
105/19 105/24 114/3
116/13 116/21 116/24)
remotely [1] 117/5
removable [2]
122/14 122/16
remove [1] 52/8
removed [3] 51/18
52/1 52/12
removing [1] 71/10
reoccurred [1] 37/14
repaid [1] 82/20
repeat [1] 180/24
repeated [2] 7/15
20/19
repeatedly [2] 132/25]
133/4
repeating [1] 75/12
replaced [2] 71/23
124/12
replacement [2] 23/2
127/1
replacing [2] 72/9
127/17
replied [3] 2/12 12/22
112/3
replies [2] 4/8 70/13
reply [12] 4/20 5/9
12/21 21/15 141/17
153/22 153/25 156/12)
164/5 172/2 172/12
179/11
replying [2] 4/25
29/25
report [112] 2/8 2/12

3/23 4/19 4/21 5/11
5/23 6/5 6/10 6/13
6/21 6/21 6/23 22/13
22/16 22/17 33/17
34/7 35/10 38/2 38/3
38/9 38/10 38/17 52/7
53/8 53/10 53/13
53/24 54/19 55/20
56/21 56/24 57/7
57/17 58/8 58/9 58/25)
59/22 59/24 59/25
68/25 73/17 73/24
74/3 74/12 74/17
74/23 76/25 78/6
78/24 79/1 79/2 79/4
79/11 79/25 80/3
93/18 95/1 99/8 101/7
114/12 114/19 120/25]
151/14 151/21 152/2
152/5 154/8 154/20
155/16 155/17 155/18}
155/20 155/24 158/16
159/5 160/7 160/9
162/25 163/7 163/10
163/13 163/14 164/19]
164/20 165/14 165/17I
165/20 165/24 166/3
166/8 166/22 167/7
167/14 167/25 171/6
172/8 176/6 176/12
176/13 176/16 176/17
177/14 177/21 177/24
177/25 178/6 179/12
179/13 179/17 180/10
reported [3] 26/14
53/17 92/10
reporting [2] 30/2
58/5
reports [18] 36/15
54/4 56/11 57/1 57/21
58/23 59/2 59/4 60/16
92/11 92/12 126/24
152/12 154/2 154/13
154/24 155/4 162/8
represent [1] 76/18
reproduce [2] 10/23
87/1
request [38] 2/24
3/19 4/19 10/12 11/11
11/14 11/15 12/3
12/19 13/10 21/8
21/25 22/25 23/6
23/10 24/2 30/11
31/14 31/17 32/16
32/20 35/18 39/11
63/8 74/4 80/24 110/5
110/8 112/15 133/4
133/7 140/6 153/1
153/10 156/1 156/8
161/11 165/14
requested [12] 2/15
21/1 21/6 23/19 23/22
30/13 31/16 32/6
33/25 35/21 69/19

133/22
requests [11] 6/11
6/12 7/15 8/9 20/19
24/19 111/3 143/11
160/2 161/16 179/21
require [2] 16/8
152/23
required [6] 31/11
157/12 171/11 173/1
173/3 173/18
requirement [1]
168/5
requirements [1]
154/11
rerouted [1] 137/8
research [5] 20/11
24/23 24/23 29/10
58/2
reserve [2] 171/18
184/9
resident [2] 150/12
150/15
resolved [6] 39/2
39/14 40/22 40/25
42/9 113/9
respect [3] 75/14
98/13 101/4
respective [1] 155/2
respond [8] 3/21
6/11 7/8 15/10 80/24
111/17 127/19 133/6
responded [5] 11/24
109/23 157/15 159/6
178/11
responding [2] 34/15
162/23
response [14] 18/18
22/15 76/24 78/6
78/24 112/14 112/18
126/1 140/6 160/25
162/11 162/15 164/13}
169/10
responses [5] 5/5
13/13 54/15 62/16
62/17
responsibilities [2]
174/20 175/16
responsibility [3]
115/2 144/15 166/20
responsible [1]
137/10
rest [1] 184/19
restarted [1] 17/4
restarts [1] 18/5
restrict [1] 60/4
restricted [4] 17/17
34/2 34/4 34/14
restrictive [1] 113/20
result [6] 54/8 89/3
90/11 91/23 107/5
169/15
resulted [2] 53/14
60/13
resulting [1] 53/24

results [2] 36/11
71/10
retraining [1] 44/23
retrievals [2] 25/17
26/23
retrieved [2] 87/18
170/15
returned [1] 69/19
returns [6] 65/10
67/12 67/20 68/6
68/10 72/7
reveal [11] 47/6
47/13 48/12 48/14
48/15 48/21 48/22
49/18 60/16 80/25
113/24
revealed [5] 45/24
47/21 64/17 105/17
141/18
revealing [3] 49/4
49/17 133/15
review [8] 27/13
27/14 51/16 51/19
67/16 183/9 183/20
184/18
reviewed [1] 184/16
revisions [2] 167/9
167/10
right [40] 2/5 2/6 4/4
6/2 15/15 20/3 22/12
24/14 24/15 31/20
33/24 38/13 42/1
52/22 53/18 54/12
56/17 58/11 61/17
66/18 67/3 91/1 93/21
99/23 105/2 126/25
127/4 140/1 143/8
143/12 144/16 162/4
167/6 176/4 180/2
180/3 184/9 186/8
186/12 186/16
right-hand [1] 58/11
ring [2] 139/2 140/6
Rinkfield [1] 158/4
Riposte [3] 121/16
123/18 124/14
robust [8] 151/23
151/24 155/10 155/22)
163/23 169/19 169/21
170/1
robust’ [1] 163/13
robustness [1]
155/13
role [7] 84/4 86/5
100/9 167/11 167/23
168/14 183/1
roll [1] 49/17
rolled [3] 25/12 42/10}
55/3
rollout [2] 8/18 45/15
room [2] 99/21
152/19
Rose [1] 151/16
rough [3] 128/8

(70) referred - roughO
R

rough... [2] 129/14
146/2

round [1] 53/4
route [5] 110/12
4111/1 111/1 111/19
111/20

routine [5] 118/4
118/9 118/23 118/24
137/13

row [1] 56/6

rules [1] 184/23
run [1] 87/21
running [1] 59/14

Ss

$90 [2] 25/19 36/22
said [64] 8/25 9/25
11/1 12/7 22/17 26/1
34/12 37/2 37/12
46/13 48/18 52/8
60/18 69/25 70/5
74/12 76/24 77/2
78/20 81/9 82/2 89/10)
89/25 93/25 96/14
99/10 100/22 102/10
102/14 102/16 103/11
103/13 103/23 104/19
105/4 107/17 109/7
109/17 110/3 112/11
116/14 118/13 118/24}
118/25 119/15 119/23
124/13 125/17 126/22
134/2 137/17 139/7
139/7 142/23 143/17
145/3 146/19 148/2
155/9 159/12 167/22
167/25 168/7 170/1
same [25] 7/9 7/9
7/15 21/12 21/13 24/5
24/12 37/21 65/14
65/16 65/24 85/11
91/17 92/6 92/7 99/21
99/25 112/11 123/15
123/23 123/25 126/16}
127/3 136/5 178/22
sat [2] 19/8 145/3
saw [7] 6/12 75/16
82/25 88/22 125/17
162/7 175/23
say [138] 8/7 8/12
8/24 9/25 11/21 12/16
13/12 14/24 15/12
15/22 16/3 17/23
18/15 19/22 22/24
23/19 25/18 26/9
26/25 27/6 28/15
29/11 30/1 30/5 31/3
33/12 33/18 35/20
37/10 37/11 37/22
38/1 40/4 40/19 40/21
42/21 46/10 47/1
54/16 55/13 57/9

57/11 58/1 58/2 59/8
62/17 62/21 63/15
68/17 71/3 74/7 74/15
75/8 75/11 76/2 78/1
79/12 80/19 81/10
81/18 83/14 83/16
84/8 84/20 86/5 86/19)
87/20 89/22 91/25
92/3 92/20 94/8 95/24
96/1 96/12 96/15
97/15 99/3 99/6 100/1
101/21 102/11 102/15)
104/6 105/3 106/25
107/8 108/13 108/16
109/10 111/12 111/22)
112/22 113/7 113/10
114/10 114/17 115/12)
115/13 117/24 119/17)
124/5 129/13 129/19
130/5 130/7 139/1
142/7 142/8 142/12
142/13 144/16 145/12)
146/12 146/13 146/18)
150/5 154/1 154/23
156/2 157/9 157/18
159/3 159/18 160/3
161/19 163/5 164/8
164/8 164/17 165/19
166/23 169/1 170/10
176/23 179/20 182/6
182/8

saying [63] 5/7 5/13
7/10 11/24 13/5 13/8
13/19 13/21 14/13
14/15 15/25 18/15
18/17 19/18 24/21
34/8 37/13 49/14
62/14 63/12 63/17
73/5 73/12 75/12 80/2
81/25 84/17 93/7
108/23 109/1 109/23
118/8 118/8 120/17
123/7 129/18 130/10
131/13 132/4 132/14
132/19 137/20 142/6
142/9 145/20 148/1
152/17 155/11 159/22)
164/5 166/16 169/11
169/20 169/22 171/24)
172/2 172/19 172/20
175/4 178/11 178/16
180/12 182/1

says [23] 2/7 10/21
20/24 21/18 22/12
25/9 26/21 44/19
46/25 50/19 52/3 54/3
63/25 69/4 70/6 71/14
71/18 95/22 101/22
106/20 135/6 135/14
153/8

scenarios [1] 38/5
scheduling [2] 8/19
68/14

scope [8] 86/13

86/23 87/4 94/10
97/13 115/17 155/25
183/23
scoped [2] 89/11
97/2
screen [1] 124/12
scroll [48] 1/24 1/25
2/6 3/5 4/7 4/13 20/23
21/14 24/6 29/25
51/15 53/22 54/2 62/3
62/12 66/5 69/4 69/22
70/6 70/9 71/3 71/13
71/18 71/18 73/23
82/12 86/2 92/19
104/12 106/12 109/14
110/19 112/3 114/8
123/9 126/7 134/25
135/18 136/4 136/9
140/22 143/20 150/10
171/1 171/15 176/10
179/11 184/17
scrolling [1] 70/13
Sea [1] 73/19
search [5] 63/9
129/22 130/13 131/7
149/19
searched [1] 138/16
searches [1] 130/18
searching [1] 145/6
second [10] 6/13
34/7 42/20 54/20
105/1 143/2 149/16
155/3 157/21 176/2
secretary [1] 10/15
section [5] 38/19
50/24 52/8 73/4
114/11
section 1.2.3 [1]
114/11
section 3 [1] 38/19
sections [1] 51/17
secure [1] 161/6
Security [2] 119/2
159/21
see [101] 1/25 1/25
2/1 2/20 3/6 10/14
12/7 12/22 18/6 18/6
19/2 19/13 22/9 24/7
24/9 24/10 24/11 25/8
29/21 31/1 33/22
34/23 42/15 43/14
45/9 46/9 46/16 46/19
46/25 50/12 50/15
52/4 53/3 53/21 54/2
55/18 56/6 56/12 57/8
57/25 58/11 59/10
61/1 61/7 66/15 68/25
73/3 73/16 73/17
73/18 84/4 84/14
88/19 88/23 90/22
95/10 97/14 98/13
99/18 101/24 104/9
104/23 106/11 106/23
107/4 109/16 110/16

110/21 111/7 120/7
120/20 121/1 121/10
121/24 123/13 123/16}
123/19 123/20 124/18}
124/21 125/11 135/12
135/17 135/18 137/21
140/16 142/1 143/20
144/23 149/10 150/19)
152/4 153/3 158/18
158/21 160/16 161/20}
162/2 164/10 168/21
179/11
seeing [1] 84/10
seek [2] 8/12 49/10
seeking [9] 13/15
13/25 79/7 159/23
161/15 166/24 169/18}
169/21 183/16
seem [4] 104/3 150/6
167/24 167/24
Seema [20] 1/10 1/13
5/11 6/25 11/18 12/5
22/8 27/7 48/11 50/14,
60/10 81/1 82/14
101/23 103/9 114/4
135/6 136/6 136/23
150/23
seemed [1] 48/23
seemingly [1] 66/16
seems [8] 32/19
51/24 52/23 58/3
80/22 83/5 124/10
152/15
seen [29] 6/6 41/12
45/17 74/21 76/16
76/19 77/6 78/3 79/17,
80/5 89/6 90/19 91/2
93/24 100/2 103/1
108/17 110/10 110/13}
120/19 128/5 128/23
144/25 145/24 162/23}
173/12 178/16 179/1
180/13
send [5] 31/1 143/15
161/3 178/5 178/10
sending [3] 143/8
154/12 154/16
sends [2] 2/20 68/25
senior [3] 77/13
186/1 186/2
sense [6] 24/2 49/7
75/25 76/10 129/10
153/21
sensible [1] 60/2
sent [17] 2/1 4/23
§1/22 52/1 52/5 52/13)
52/13 52/15 54/13
79/10 79/11 150/19
153/3 160/2 160/9
162/7 179/12
sentence [3] 49/22
51/24 97/11
sentiment [2] 21/8
64/17

separate [8] 5/22
47/15 47/16 56/18
65/2 66/15 68/1 73/13}
September [6] 61/24
86/4 90/7 90/25 91/2
103/16
serial [1] 66/21
series [4] 5/1 5/8
41/17 150/24
serious [6] 44/4
62/22 64/2 71/11
73/10 95/17
seriously [4] 44/24
45/25 49/22 50/25
serve [3] 177/22
177/25 179/14
served [5] 151/14
152/12 177/12 177/24I
178/19
server [4] 65/15
65/16 70/15 123/18
servers [1] 170/14
services [3] 66/9
126/10 159/20
session [1] 106/19
sessions [1] 71/5
set [10] 1/11 7/20
33/9 75/4 80/11 89/14I
89/20 89/21 157/16
177/23
sets [2] 41/25 184/5
settlements [1]
41/23
seven [2] 52/23
151/14
several [2] 25/22
31/25
Sewell [1] 75/4
shall [1] 161/3
shapes [1] 177/19
sharing [1] 145/1
Sharron [1] 171/5
she [43] 3/23 24/16
25/6 25/8 26/1 26/7
26/21 26/21 26/24
37/6 68/10 68/11
68/19 68/19 68/20
68/21 68/22 68/25
70/6 70/6 70/13 82/20
82/20 82/21 82/22
82/23 82/25 82/25
126/13 135/25 136/18}
138/4 139/7 139/7
139/9 139/11 140/6
148/4 151/17 172/7
172/19 175/22 177/11
she'd [2] 68/10
141/25
she's [2] 71/18
135/15
shed [1] 140/16
sheet [1] 56/6
Shoeburyness [1]
73/19

(74) rough... - ShoeburynessO
Ss

short [11] 31/24
61/20 62/5 72/3 82/19)
82/23 98/7 117/15
153/7 154/8 156/22
shortfalls [2] 127/24
147/24
shortly [2] 6/14
133/21
should [86] 3/18 3/25
7/24 8/5 13/5 13/8
13/14 13/16 13/19
13/21 13/22 14/12
14/14 14/16 16/24
18/6 25/15 35/16
36/16 45/19 48/15
48/22 49/4 49/6 49/10
49/14 54/11 56/16
62/25 64/10 64/13
64/13 64/21 66/19
72/18 76/19 77/6 77/9
77/11 77/21 78/3
78/23 79/8 79/10
79/11 79/17 80/9
80/10 80/24 86/22
92/4 92/5 92/14 94/4
94/13 94/20 94/23
96/14 103/12 107/16
111/8 120/6 125/13
134/19 134/21 137/7
137/19 138/15 140/3
140/8 142/23 149/14
151/25 152/1 156/8
160/12 160/14 161/13
161/13 162/19 164/15}
165/16 165/19 171/2
177/16 180/4
show [8] 23/1 36/16
70/22 95/16 141/23
169/25 170/7 181/21
showed [3] 53/11
73/22 141/24
showing [9] 56/25
134/12 135/9 135/15
135/23 136/7 136/11
136/15 147/18
shown [9] 17/6 45/1
46/22 51/2 51/10
57/12 76/23 125/10
140/4
shut [2] 121/9 121/21
sick [1] 44/15
side [7] 57/17 57/23
57/23 58/12 86/3
170/16 183/5
sideline [2] 150/12
150/15
sign [7] 53/21 128/6
145/24 148/5 161/7
165/25 180/18
sign-off [1] 161/7
signed [8] 50/12
55/13 60/9 166/2

168/25 178/5 178/10
179/6
significant [2] 72/8
105/4
signing [1] 153/4
signs [4] 144/18
145/6 145/11 149/3
similar [3] 21/24 75/2
107/20
similarly [1] 178/25
simple [6] 28/22
58/17 99/4 113/12
122/7 126/12
simpler [1] 116/2
simplest [1] 88/2
simply [4] 80/11
101/21 113/20 163/9
since [16] 13/5 18/9
25/16 26/22 37/14
55/5 67/12 72/1 87/4
87/5 87/7 88/8 100/2
114/25 116/13 149/2
Singh [36] 1/15 1/15
7/14 10/15 11/12
12/25 13/3 20/21
21/13 21/19 29/22
31/2 32/10 32/12
82/13 83/5 83/14
83/15 103/17 109/16
109/17 113/18 131/9
151/5 153/18 153/20
154/25 155/8 157/16
159/4 160/2 163/11
164/5 165/4 169/7
174/17
Singh's [7] 156/1
156/8 157/6 157/19
163/12 169/4 170/2
single [2] 122/13
178/14
sir [7] 1/7 61/15 98/1
117/10 117/17 185/21
186/13
sit [2] 174/2 174/7
sits [1] 161/7
situation [3] 58/5
61/8 79/20
six [4] 87/23 177/23
178/18 179/15
skimmed [1] 158/13
skip [1] 84/18
Skipping [1] 86/25
slides [1] 184/4
slightest [2] 128/6
145/25
slightly [5] 8/3 37/16
61/11 62/9 173/11
small [3] 96/22 96/23
97/9
SMC [3] 25/15 122/3
122/4
Smith [3] 51/22
80/21 160/10
snapshot [5] 56/23

56/25 60/6 122/4
122/10
so [204]
so-called [1] 60/13
software [3] 18/2
29/18 140/12
solid [1] 9/3
solution [10] 42/18
42/18 43/8 43/8 51/20
104/15 104/19 105/4
106/5 115/20
solutions [2] 42/17
104/10
solutions/fixes [1]
4217
some [83] 2/16 5/13
5/24 10/7 12/14 13/18
13/25 18/25 19/1
20/10 24/22 25/1
27/25 30/6 30/7 30/23
30/23 31/8 31/15 32/5
32/6 33/9 42/6 42/17
43/7 43/13 49/2 50/13
56/9 57/2 59/1 63/9
63/14 66/17 68/13
68/23 69/4 70/19
74/18 75/2 75/6 76/22
77/13 78/5 85/8 85/22,
88/14 88/24 90/16
91/6 91/13 93/15
107/2 119/9 120/22
122/7 128/9 129/16
131/8 134/24 137/23
141/25 143/16 146/3
149/8 160/11 160/23
160/24 161/2 161/3
162/24 167/9 168/3
171/18 173/2 173/21
173/24 176/5 179/9
180/14 181/10 181/25}
184/1
somebody [13] 5/9
18/1 22/11 28/23 29/2
103/25 119/23 160/8
167/10 167/21 168/14
175/9 176/19
someone [6] 17/11
17/24 83/18 103/11
173/10 179/4
something [34] 7/1
14/5 17/23 17/25
25/13 26/14 26/18
27/17 29/17 61/2 74/8
74/9 75/10 92/9 97/16
97/22 116/10 124/6
125/13 134/3 140/9
142/14 142/23 154/19}
158/15 161/13 162/6
162/18 162/19 167/22
168/1 171/19 175/9
176/25
sometime [2] 128/23
138/3
sometimes [3] 8/12

38/4 68/7
soon [1] 178/6
sooner [1] 87/21
sorry [16] 52/11
56/15 57/8 57/15
63/22 67/7 69/11
72/20 72/22 104/1
130/6 140/21 144/11
154/5 157/25 158/11
sort [49] 5/14 5/14
5/15 7/10 13/25 13/25)
17/4 35/15 38/20
40/19 46/20 49/2 56/9
57/2 59/2 63/14 64/7
68/13 68/13 75/23
77/13 78/5 91/23
97/13 103/3 104/7
105/14 105/22 120/15)
122/8 124/18 126/13
128/7 128/10 129/14
129/16 130/16 133/22}
134/1 137/10 137/16
142/2 146/1 146/3
149/8 162/14 164/3
179/3 181/10
sorted [1] 104/14
sorting [2] 106/6
180/4
sorts [3] 7/19 56/2
138/12
sought [4] 49/11
49/13 156/7 179/9
sounding [1] 121/13
speak [1] 70/6
speaking [1] 54/12
special [3] 58/8
105/25 173/20
specific [29] 12/14
31/7 31/8 31/14 34/6
39/4 41/4 49/13
105/21 109/3 109/3
109/4 116/8 145/14
154/9 156/4 156/5
156/6 156/14 157/10
161/22 163/18 172/14}
172/15 172/22 173/2
176/7 177/18 179/17
specifically [3] 106/1
108/5 118/3
specifics [4] 153/12
154/21 157/14 159/5
spell [1] 112/24
spend [1] 179/25
spoke [2] 141/21
170/22
spot [1] 163/22
spottable [1] 163/21
spotted [1] 72/12
spreadsheet [4]
151/18 152/4 157/22
158/7
spreadsheets [3]
65/18 65/25 66/2
spring [1] 71/24

sprung [1] 179/10
spurts [1] 9/2
Square [27] 15/15
15/17 24/9 24/21
24/25 25/23 27/10
28/17 35/5 35/18
35/23 37/24 38/24
39/18 40/16 85/12
131/2 132/16 143/12
143/22 144/5 144/13
144/19 145/7 146/7
149/4 165/3
SSC [4] 86/7 91/16
138/1 148/4
stable [3] 45/21 64/8
65/1
staff [6] 82/21 134/8
134/12 147/15 147/18)
148/4
stage [15] 3/3 4/24
6/3 11/19 18/15 27/2
27/25 31/22 42/5 79/1
79/25 147/25 148/6
161/12 171/10
stages [1] 177/13
stand [1] 78/21
stands [2] 66/8 87/12
start [14] 1/10 41/11
65/6 68/24 99/19
102/20 108/11 117/21
155/12 160/22 186/14I
started [3] 66/22
137/22 137/23
starting [2] 87/3
154/25
startling [1] 144/25
state [8] 45/20 76/18
77/5 84/15 152/13
152/20 163/24 180/9
stated [1] 135/25
statement [143] 1/12
2/12 2/14 4/20 4/21
5/10 5/25 6/24 8/14
10/13 10/25 11/2 11/4)
11/7 13/6 13/14 13/17)
13/23 14/3 14/11
14/15 14/17 14/23
15/1 18/16 22/7 22/24)
23/5 24/13 24/20
24/25 28/16 28/24
33/10 34/21 34/22
34/24 35/1 35/8 35/11
35/12 36/13 37/17
40/20 47/7 55/20
59/24 60/1 60/3 60/10)
60/17 64/10 68/2
69/19 72/5 74/2 80/6
93/23 94/3 102/1
108/12 108/13 108/20)
108/24 109/9 109/12
109/19 109/25 110/2
110/3 110/7 111/5
111/8 111/11 111/13
111/14 112/10 113/13}

(72) short - statementO
Ss

statement... [65]
114/6 116/20 117/22
118/3 119/15 119/19
119/23 125/17 127/21
137/13 142/9 144/4
153/1 153/5 153/11
154/22 155/4 155/8
155/15 155/19 156/3
156/13 157/5 157/12
157/14 161/22 163/3
163/4 165/25 166/2
166/4 166/6 166/7
166/12 166/22 167/8
167/12 167/22 168/23}
168/25 169/1 169/2
169/25 169/25 170/6
170/11 170/24 171/1
1714/7 172/19 172/21
172/25 173/4 174/24
175/4 175/10 176/18
176/19 178/10 178/14}
178/25 179/6 180/22
181/1 1841/8
statements [34] 14/6
22/16 36/15 41/8
41/21 47/8 48/11
53/15 53/25 54/24
55/7 55/11 55/17
55/23 60/14 62/24
64/1 64/9 64/18 79/14
81/2 83/21 88/18
108/11 109/11 112/5
116/23 136/23 140/25
150/25 168/10 172/16}
172/17 172/18
states [5] 118/4
135/9 135/23 136/7
136/10
statistics [2] 68/23
69/6
status [4] 54/4 78/9
173/20 175/15
steer [1] 13/9
step [1] 168/7
stepping [1] 48/4
steps [2] 127/8
163/25
Steve [1] 62/15
still [18] 30/14 47/24
48/2 49/3 59/14 85/20)
85/21 87/18 88/5
94/21 112/21 123/24
138/24 139/10 152/2
164/4 171/2 176/21
stock [12] 25/22 36/2
36/2 36/3 36/5 36/6
36/10 57/5 57/7 60/15)
70/21 70/25
stolen [2] 19/4 19/15
stop [5] 62/13 120/13
136/9 156/18 170/20
stopped [1] 25/19

stopping [2] 98/24
136/20
storage [3] 121/7
121/20 163/15
store [12] 18/4 28/5
28/7 28/11 28/12
121/8 121/18 121/21
122/4 122/11 125/16
12719
stored [2] 58/24
170/14
straightforward [2]
42/22 132/3
strategic [3] 42/18
42/21 43/8
strike [1] 129/10
strong [1] 154/5
strongly [1] 61/11
struggled [1] 8/15
study [1] 1/10
stuff [3] 9/20 128/8
129/15
sub [2] 22/20 82/18
subject [2] 149/17
182/15
submissions [1]
183/13
submitted [3] 114/21
167/15 169/13
subpostmaster [7]
47/21 70/12 106/21
107/7 107/13 115/23
157/11
subpostmaster' [1]
114/22
subpostmaster's [1]
117/16
subpostmasters [6]
48/13 54/6 55/8 83/25
93/19 181/18
subsequent [3] 47/7
63/21 168/9
subsequently [4]
78/7 79/14 103/1
150/17
substance [4] 9/23
123/22 161/10 182/9
subsystem [1] 62/8
successful [1]
183/19
successfully [2]
151/20 152/10
successive [1]
124/14
such [36] 13/24 15/6
16/10 16/16 19/23
30/12 31/16 36/8
36/12 36/21 38/8
38/24 38/25 39/2
39/12 40/15 50/18
58/7 62/24 64/1 64/10)
64/14 72/3 75/1 80/6
82/11 84/23 105/19
115/2 126/5 129/21

142/10 150/2 151/18
173/23 179/21
sufficed [1] 183/13
sufficient [5] 1/16
25/25 27/20 29/10
156/24
sufficiently [1] 29/14
suggest [8] 42/17
51/7 70/3 108/17
119/20 166/19 167/3
167/4
suggested [9] 31/15
32/15 34/10 69/25
120/1 132/16 164/20
165/16 165/19
suggesting [5] 17/9
17/20 63/10 70/16
82/23
suggestion [7] 46/3
117/25 119/21 120/11
125/18 126/2 127/19
suggestions [3]
20/14 100/2 131/5
suggests [4] 39/16
40/15 57/16 74/5
suitable [1] 3/22
sum [1] 71/5
summaries [1] 178/4
summarisation [1]
81/6
summarise [3] 81/3
81/16 82/17
summarised [1]
171/23
summarises [2]
36/13 86/8
summary [8] 38/19
53/13 71/7 88/21
137/18 152/11 169/11
178/1
summed [1] 176/1
summer [1] 42/10
summon [1] 143/23
supplied [3] 171/6
172/8 172/19
supplying [1] 76/12
support [15] 3/18
3/25 4/16 23/13 23/14]
31/11 31/13 82/9
87/14 104/13 156/3
181/4 183/13 184/6
184/10
supported [2] 77/12
80/12
suppose [3] 79/12
131/14 153/16
supposed [8] 65/20
92/17 113/7 122/15
122/16 130/12 134/16
139/1
sure [35] 12/7 13/13
13/16 13/22 14/16
16/20 19/6 28/8 28/9
28/10 28/13 31/21

41/4 43/9 55/9 66/12
68/11 74/20 76/13
76/21 77/19 77/23
86/21 88/20 91/3
92/15 96/10 102/9
103/3 112/9 141/21
142/7 166/13 168/6
174/15

Surprisingly [1] 21/5
Surrey [1] 149/21
survey [2] 27/25
155/5

suspect [3] 42/15
160/7 181/21
suspicious [1] 62/19
swapped [2] 121/19
123/12

swapping [1] 122/5
SWAPS [1] 122/1
Sweetlove [1] 123/22
symptom [4] 93/1
93/5 128/6 145/25
symptoms [3] 147/5
147/8 147/12

sync [1] 98/20
synchronise [3]
122/4 122/10 127/9
SYSMAN [3] 62/4
62/5 88/3

SYSMAN2 [1] 62/9
SYSMAN3 [2] 62/4
62/11

system [107] 2/10
10/1 11/6 14/22 17/3
18/13 18/22 21/4
36/19 36/20 38/5 38/7,
38/23 39/5 39/10 45/2
45/3 45/11 45/12
45/20 45/21 45/23
46/6 46/17 46/18
46/23 47/16 47/22
48/10 48/24 49/2 49/3)
51/3 51/4 51/11 51/13)
54/8 54/11 60/11
60/12 62/5 62/7 64/7
64/20 65/1 76/11
92/11 95/4 95/9 95/23)
96/25 98/23 99/2
100/7 100/18 105/6
109/21 111/10 112/16}
113/2 113/19 113/25
114/15 115/1 116/3
118/6 118/11 123/1
124/7 124/15 126/18
132/5 135/14 136/7
136/11 137/15 147/8
148/5 151/22 151/23
151/24 152/1 152/6
152/12 152/15 152/17}
155/10 155/21 156/10)
163/13 163/17 163/23}
164/5 164/6 164/9
165/7 169/17 170/14
170/19 176/14 177/2

1477/5 17719 177/17
177/19 183/10 185/8
system's [3] 96/2
96/8 97/23

systems [10] 94/19
98/20 114/13 114/22
115/5 115/11 115/13
116/4 116/7 152/18

TOO
tactical [2] 42/18
43/8
take [13] 4/10 31/25
43/5 48/9 60/5 61/16
117/10 127/8 156/18
158/6 163/25 165/22
170/3
taken [17] 23/11
50/10 52/15 61/2
80/21 81/13 81/21
81/25 84/7 89/7
101/25 104/2 117/2
123/21 126/8 131/25
148/5
taking [5] 52/16 67/5
115/2 116/22 168/7
talk [4] 91/16 109/8
116/20 141/20
talked [1] 44/17
talking [13] 23/21
31/23 42/4 62/3 64/23}
64/24 78/25 107/25
108/6 108/7 113/2
116/19 135/25
tampering [1] 105/6
task [6] 22/10 83/19
87/15 133/10 159/8
161/20
Tatford [10] 2/10
12/20 33/14 39/9
106/20 128/2 134/5
141/2 147/2 174/15
Tatford's [1] 60/21
team [5] 23/13 31/13
119/2 152/14 165/8
technical [5] 6/5
47/24 75/9 101/15
103/5
technically [1]
100/10
technician [2] 48/1
49/8
technology [1] 62/10
telephone [1] 74/5
telephoned [1] 32/12
tell [15] 5/25 47/19
49/1 64/13 77/15
77/21 77/22 84/15
89/9 117/4 124/8
132/4 166/20 175/7
185/14
telling [1] 77/25
tells [1] 41/20
ten [1] 61/16

(73) statement... - tenO
T

tends [1] 166/19
tenure [1] 20/16
term [4] 75/19 83/9
83/16 104/24
terms [24] 30/21
30/23 45/10 45/20
46/21 49/14 65/11
65/17 75/16 99/16
100/10 100/12 106/6
152/7 155/12 163/12
165/13 182/2 183/25
184/2 184/5 184/13
184/18 185/15
test [1] 152/1
tested [1] 106/1
testifying [2] 27/11
137/23
testimony [1] 147/2
testing [6] 38/25
39/13 42/23 43/1 43/4,
61/25
text [5] 73/8 121/4
135/4 135/13 136/1
Text’ [1] 123/17
than [64] 7/15 9/10
10/5 16/8 18/2 19/8
25/22 34/20 39/18
45/2 46/2 46/11 46/23
51/3 51/11 52/16 53/9
54/19 58/2 58/4 59/8
65/14 73/7 82/7 82/10)
83/5 84/12 87/9 87/23
91/17 92/6 93/2 93/8
97/6 111/14 111/23
112/8 112/19 113/8
113/14 113/20 118/16}
122/20 131/2 132/4
134/22 141/18 144/18}
146/7 149/3 149/24
152/16 161/3 161/10
164/9 165/12 166/10
166/25 167/3 170/21
179/22 181/20 185/8
186/1
thank [52] 1/7 3/6
3/15 10/14 20/12
20/20 21/11 21/14
32/9 41/6 50/1 50/11
56/15 60/8 61/14
61/18 62/12 62/13
64/16 65/2 66/5 73/9
73/23 74/14 98/5
98/16 104/12 106/9
106/17 114/8 114/10
117/9 117/13 117/17
120/24 121/2 123/9
123/10 126/8 127/23
128/1 143/21 150/22
156/18 156/19 159/24
167/6 180/25 185/20
185/22 186/12 186/13)
Thanks [2] 82/15

172/13
that [1325]
that I [2] 8/5 153/21
that's [96] 6/16 8/3
11/15 15/12 16/3
19/21 21/8 24/15
28/19 32/22 33/5
34/23 37/16 38/10
42/11 42/12 44/20
45/14 46/25 48/2 49/9
52/3 53/2 54/2 54/12
54/13 57/9 61/11
61/15 66/17 67/1
69/16 72/19 72/21
74/9 75/12 76/8 76/21
78/22 79/20 83/3 85/2
85/22 89/24 89/25
91/1 95/13 95/22
95/25 96/9 96/14
97/18 97/25 104/15
106/18 107/17 109/1
112/18 113/2 113/10
114/11 115/9 115/16
118/21 118/21 120/12)
121/2 122/19 130/5
130/7 131/13 132/15
132/17 132/19 132/24)
138/18 139/1 139/12
139/12 140/8 140/15
143/11 144/8 144/14
156/3 157/23 159/9
162/2 164/9 164/23
169/4 170/10 175/18
176/4 180/3 186/16
theft [8] 33/9 82/21
125/4 128/22 129/2
129/11 131/25 146/23)
their [10] 7/16 72/24
81/10 151/16 155/2
168/7 168/12 177/20
183/21 185/12
them [37] 13/14
13/17 13/22 14/3 19/8)
40/6 42/15 71/10
79/15 88/17 89/9
93/15 93/20 93/20
101/7 107/18 119/12
119/13 124/11 125/15)
125/23 133/11 134/22)
136/21 138/14 142/18)
144/3 144/7 144/10
144/12 158/15 158/16)
162/18 163/22 167/17,
168/5 175/1
themselves [5] 48/12
49/17 107/1 107/9
148/18
then [113] 3/23 4/7
4/13 7/8 17/4 22/6
26/13 26/24 28/25
30/1 30/9 38/1 39/5
43/3 43/8 45/13 46/13
48/2 51/9 56/24 58/20
58/20 59/5 59/5 59/21

62/2 62/21 62/21
64/25 66/21 69/3
69/22 69/25 70/9
70/13 71/13 71/13
74/14 75/11 79/14
79/22 80/5 83/21
86/22 86/24 89/16
89/22 91/18 91/21
94/12 94/24 103/11
103/14 107/3 109/25
111/4 111/7 112/7
115/4 119/9 120/22
121/5 122/10 123/11
123/15 123/21 123/22
125/7 128/7 131/6
131/6 134/2 134/11
135/13 135/18 136/1
136/4 136/9 136/23
137/24 138/15 140/9
141/2 142/17 143/23
145/9 145/13 146/1
146/12 147/17 150/10
152/13 157/18 157/21
161/5 166/22 167/7
170/5 171/14 171/15
171/16 171/22 172/2
172/7 172/11 175/2
176/17 177/23 179/20
179/23 180/3 180/13
181/22
theoretically [1]
116/15
there [226]
there'd [1] 33/8
there's [15] 4/18
24/20 27/5 80/2 80/17,
120/11 121/5 122/12
134/10 136/21 138/18}
147/16 156/5 171/24
179/17
therefore [34] 7/10
16/23 37/23 43/7 55/3}
57/20 59/6 63/10
72/24 73/5 74/20 93/7
100/25 109/10 115/23}
117/4 118/23 119/24
122/19 124/18 127/15
129/8 130/1 134/20
137/1 139/13 140/13
142/1 148/13 158/21
160/17 167/1 183/16
185/17
these [47] 15/8 21/22
25/16 26/22 31/16
33/20 43/13 45/7 46/5)
47/4 48/11 54/4 57/1
58/23 61/24 62/15
63/24 65/19 66/3 69/6
70/14 83/24 90/8
90/12 91/9 94/21
97/18 100/9 102/25
104/2 104/10 108/18
119/10 120/22 125/9
128/4 136/21 136/21

139/15 143/16 145/1
155/4 158/3 163/23
165/16 167/3 175/13
they [92] 3/20 7/19
8/10 8/24 10/9 16/9
16/14 17/1 23/22 24/2}
25/11 25/24 30/12
43/21 47/3 47/3 51/18
52/18 54/4 54/9 60/3
60/18 62/18 66/7
66/11 67/6 67/7 67/8
77/12 80/12 81/10
81/11 82/8 82/10
89/20 89/22 89/25
93/14 93/22 93/23
94/2 94/22 98/19
99/13 103/13 107/1
107/9 116/16 116/25
4117/1 118/10 118/11
118/24 122/8 124/3
126/21 127/8 127/11
129/25 132/16 132/20}
132/22 132/23 132/23}
134/18 134/21 136/14}
136/15 137/11 139/17
139/18 150/6 152/1
154/18 154/19 154/25)
163/21 164/4 167/4
168/17 171/13 177/19}
182/8 183/11 183/15
183/17 184/22 185/14
185/14 185/21 185/24}
186/13
they'd [2] 16/17
119/23
they're [4] 48/14
58/23 67/6 186/1
they've [1] 81/9
thing [21] 7/16 13/25
37/21 45/23 46/4
46/10 46/11 46/11
61/5 66/13 75/23 76/4
103/4 105/13 109/15
112/11 119/20 125/9
132/15 132/18 164/4
things [46] 5/3 5/14
8/2 9/8 9/9 9/10 17/4
23/12 25/6 27/22 30/1
34/6 34/11 43/20
60/17 67/6 72/25 73/1
73/12 78/12 82/1
92/14 96/4 105/1
105/2 105/14 106/6
116/2 116/2 126/4
132/20 134/11 134/16}
134/18 141/13 145/8
145/12 147/17 155/9
155/21 159/17 167/3
167/4 170/21 173/23
183/6
think [208]
thinking [9] 9/22
16/20 18/16 82/1
97/19 107/25 113/15

132/9 168/13

third [17] 1/12 16/5
22/13 34/22 35/1
53/20 60/9 98/24
104/19 104/22 108/12!
112/14 123/11 143/23)
154/22 157/5 163/4

this [372]

Thomas [18] 2/20 3/7I
10/17 12/23 20/22
21/14 29/22 31/3
33/15 62/14 65/7 76/5
76/6 84/20 110/16
110/20 110/25 180/6

Thomas' [2] 158/10
158/19

Thompson [2]
159/19 182/22

thorough [5] 18/10
27/13 27/14 34/20
107/15

those [52] 16/13 18/6
18/6 20/19 28/2 33/6
35/7 39/23 40/19
43/22 47/22 49/18
53/1 59/4 60/16 62/17
64/3 68/21 70/23 72/5
102/10 103/2 105/22
105/22 106/8 113/11
117/2 122/15 126/4
131/17 132/20 141/4
142/17 143/17 148/14)
154/16 158/2 163/18
164/13 165/13 166/17
167/8 167/9 167/14
177/10 179/2 180/5
181/11 182/4 182/8
185/18 186/7

though [12] 4/18
12/16 25/12 25/23
30/12 35/15 39/25
54/17 94/22 118/2
122/18 164/14

thought [60] 6/16
7/20 8/2 8/11 12/12
16/13 16/23 17/23
19/6 20/6 23/12 27/14)
27/19 38/19 40/9
52/20 54/17 55/18
60/18 73/20 81/4
82/21 84/9 85/2 85/13)
88/7 89/12 97/6 100/1
107/23 108/6 109/1
110/1 116/19 119/5
120/14 129/7 139/24
140/13 142/6 142/9
142/22 146/18 146/19}
154/18 154/25 155/12)
155/12 155/25 156/15)
156/15 161/18 164/2
166/19 167/25 171/13}
172/25 177/7 180/23
185/1

thoughts [1] 79/24

(74) tends - thoughtsO
T

thousands [1]

152/21

three [13] 11/8 60/16
61/24 64/3 66/20
69/20 84/19 93/16
100/3 104/2 135/21
158/14 175/23
through [37] 24/8
30/10 43/4 45/17
67/20 68/21 69/3
73/17 74/17 79/11
82/1 82/16 87/19 88/2
89/19 89/21 94/11
105/14 110/12 111/19}
111/20 112/1 112/4
114/15 1314/7 136/3
136/20 138/1 139/24
140/13 142/16 142/22
143/14 158/12 158/13}
160/5 179/21
throughout [3] 9/3
84/3 175/20
throws [1] 131/4
thrust [1] 133/8
Thursday [1] 1/1
thus [1] 151/20
TI [1] 70/21

ie [1] 9/21
[1] 149/18
time [144] 4/3 5/24
6/14 7/25 8/4 8/8 9/3
10/11 10/12 11/1 12/8)
12/11 15/17 16/7
16/14 16/15 16/18
16/20 17/15 18/9 20/6)
23/4 25/15 26/4 27/19
27/23 27/24 31/7
31/15 32/3 32/5 32/6
32/15 32/19 32/20
33/6 33/24 34/19 35/2
36/10 36/24 37/6
37/18 37/21 39/20
39/21 40/9 41/5 45/6
45/15 47/17 50/14
52/20 55/5 60/6 60/24,
61/15 62/23 64/2 64/8
64/15 64/24 64/24
66/23 72/4 73/12
73/15 77/5 81/19
82/22 85/6 85/9 85/13,
85/20 87/15 93/17
95/24 96/14 96/20
97/4 97/19 101/3
101/11 101/20 102/8
102/21 103/3 104/8
109/23 119/13 120/19}
121/6 121/14 124/11
124/21 124/24 125/1
125/6 125/14 125/24
127/14 128/11 129/5
129/17 131/1 131/19
131/24 132/2 132/9

137/17 138/2 139/22

144/17 145/10 146/4
147/1 148/8 148/16

153/7 153/14 158/5
162/1 162/14 164/2
164/7 165/12 165/12
166/1 166/2 166/18
168/12 171/14 173/6

175/23 176/23
timeout [2] 108/15
108/18
timeout/locking [1]
108/18
timeouts [4] 112/9
112/20 113/9 113/14
times [8] 8/15 25/23
30/10 30/17 50/15
89/16 179/15 180/19
title [4] 86/9 150/3
150/8 153/11
today [4] 1/6 111/2
138/12 160/25
together [9] 9/21
44/3 66/13 92/12
99/21 104/2 110/7
122/2 140/5
told [22] 7/10 33/7
34/17 37/4 49/6 52/7
54/21 63/22 90/2
90/12 97/4 126/13
135/15 147/4 149/17
178/18 179/7 180/11
180/13 181/6 181/9
185/10
Tom [1] 63/22
tomorrow [1] 186/15
too [3] 49/18 95/6
132/14
took [12] 33/2 34/12
44/14 77/24 123/8
137/5 137/17 158/20
159/1 177/6 179/3
185/1
tool [2] 132/1 133/8
top [15] 2/19 10/9
22/9 24/6 52/4 67/1
77/25 83/17 89/2
110/24 117/24 121/24)
121/25 138/19 153/3
topic [6] 41/7 61/22
84/14 114/3 117/11
181/2
total [2] 33/20 151/19
totally [10] 46/17
4719 47/15 47/15
48/23 60/18 64/22
83/3 103/10 161/25
touch [1] 10/3
traces [1] 163/18
track [1] 130/1
tracker [1] 56/9

139/24 141/19 141/24,

148/23 149/13 149/14)

173/19 174/19 175/20)

trading [16] 36/15
36/18 53/15 53/24
54/23 55/7 55/11
55/17 55/20 55/23
59/24 60/1 60/3 60/14
93/23 94/3
trail [7] 66/4 80/18
81/5 81/7 81/16 170/8
170/12
trails [1] 155/3
training [2] 82/10
169/16
transaction [24] 15/5
15/7 15/23 15/24
15/25 20/15 21/1
21/21 32/13 32/16
32/21 33/13 33/19
36/25 65/3 65/14
66/16 87/13 114/21
114/25 115/3 115/10
115/15 125/11
transactions [28]
15/1 21/2 21/5 22/18
23/3 31/9 31/18 33/21
36/8 38/4 38/4 38/7
39/4 42/1 70/11 70/20
7116 71/8 72/23 74/24
115/8 127/3 128/5
128/13 130/14 131/7
145/24 146/25
transcript [6] 106/12
106/15 108/2 127/24
127/25 134/4
transfer [4] 36/5 36/7
70/24 70/24
transferred [1]
136/12
transferring [2] 36/1
70/25
transfers [1] 70/22
tread [1] 63/2
treated [2] 174/10
176/20
treating [1] 82/9
treatment [1] 86/1
trial [22] 35/24 50/14
78/8 85/23 106/10
114/4 137/22 138/7
143/2 143/6 143/13
143/17 144/17 145/4
149/2 149/12 150/2
171/25 174/6 174/18
175/19 177/14
tried [4] 72/24 82/20
153/21 154/20
trigger [3] 134/14
147/20 168/13
triggered [1] 158/21
trouble [1] 134/20
true [6] 85/20 97/25
113/13 132/24 144/8
166/9
truly [2] 29/7 81/11
truth [6] 77/16 77/21

77/22 77125 166/7
175/7
try [5] 7/20 9/9 88/18
129/20 154/8
trying [24] 13/18
15/12 18/9 25/1 31/17]
54/6 60/20 60/23
80/20 81/3 81/6 81/12
81/16 81/20 82/4 84/6
92/3 95/24 96/19
129/24 130/5 130/7
155/13 170/10
turn [18] 1/19 1/23
41/7 65/2 73/12 78/13)
80/19 85/25 88/10
108/9 114/3 117/20
117/23 119/9 126/6
127/23 170/25 176/9
turned [1] 155/18
Turner [1] 159/21
turning [2] 126/14
127/2
twice [5] 22/4 111/16
111/19 111/25 113/17}
two [36] 33/6 50/21
51/16 56/18 57/1
57/20 67/8 68/22 69/9
69/15 72/23 75/3
91/24 93/16 100/3
101/3 104/15 104/16
106/5 125/3 125/12
126/4 128/22 131/18
135/3 135/13 136/5
146/23 154/2 154/24
157/19 158/3 162/7
167/8 175/23 177/10
type [3] 66/10 105/24
121/18
types [1] 152/21
typical [5] 141/15
142/4 142/10 153/17
153/19
Typing [1] 154/5
typo [1] 150/4

U

UK [4] 151/22
ultimately [1] 80/5
unable [1] 177/18
unable/not [1]

177/18

unavailable [1]
123/18

unaware [3] 93/19
106/22 107/8
unclear [3] 8/9 8/10
171/10
uncomfortable [5]
9/6 9/8 9/11 9/13 10/2
uncomfortableness
[1] 9/17

uncovering [1] 44/24
under [11] 42/21
58/12 91/6 94/7 98/14)

123/17 123/21 126/8
128/5 145/23 176/11
underlying [12]
29/17 37/5 107/5
125/23 158/6 161/24
164/10 165/6 178/16
179/2 180/13 180/22
undermine [10]
44/24 45/25 46/8
46/15 49/22 50/25
77/19 79/9 79/17
96/24
undermined [2]
77/12 80/12
undermining [6]
74/22 76/16 76/19
77/6 78/3 80/5
underneath [2] 91/24!
135/13
understand [49] 24/4)
31/16 32/22 40/8
47/25 49/3 49/5 50/5
50/7 54/17 68/17
79/23 92/17 102/6
102/7 104/6 113/6
117/25 120/10 125/18)
128/20 129/18 132/13}
137/11 139/25 141/19)
147/1 147/23 148/16
148/22 151/11 152/7
163/6 164/14 167/11
167/23 168/14 173/5
173/9 173/22 174/3
174/12 174/19 176/15)
176/19 177/3 178/7
181/12 185/19
understanding [20]
23/9 41/1 59/20 68/18
73/14 76/15 90/15
91/16 100/11 113/5
115/16 116/16 118/22)
134/16 144/14 163/20)
172/23 173/8 173/24
174/15
understood [12] 59/6
68/12 80/1 92/14
113/22 116/18 157/13)
159/4 167/18 172/13
172/21 175/5
undertaken [1] 70/19
undesirable [1]
104/5
unduly [1] 51/8
unfair [1] 139/23
unfixed [3] 46/1
46/11 55/2
Unfortunately [1]
62/18
unhappy [1] 178/25
unique [1] 66/19
unit [12] 25/22 36/5
36/6 60/15 121/7
121/8 121/19 121/20
122/1 124/12 124/22

(75) thousands - unitO
U

unit’ [1] 122/5
units [7] 36/2 36/3
36/11 57/7 70/21
70/25 124/17
unknown [1] 164/12
unlikely [3] 72/2
152/20 169/8
unrelated [1] 124/3
unreliable [2] 83/1
185/17
unspecified [1]
180/17

45/21 61/16 88/22
93/16 98/3 109/23

161/2 181/13 185/19
186/18

untroubled [1]
149/11

149/6 149/7
unwillingness [1]
113/24
unworkable [1]
183/21

up [59] 1/25 3/5 4/7

16/14 16/18 24/11
25/17 26/23 34/12

53/22 62/3 62/12
63/24 66/23 67/10
69/4 70/9 71/3 71/13
71/18 71/18 72/7
74/14 75/4 78/13
82/20 88/3 93/25
94/20 95/19 98/16
110/19 112/3 114/9
126/25 1314/5 132/4

150/10 153/4 163/18
164/1 171/15 171/21
171/25 172/2 172/11
176/1 179/11
updated [2] 114/19
150/6

upon [6] 9/7 64/20
73/14 101/1 102/20
183/17

urgent [6] 66/6 66/14
110/22 151/12 153/8
161/2

urgently [1] 161/13
us [16] 4/25 5/25
13/16 21/5 41/20 49/1
76/14 87/11 94/10
97/5 121/12 122/6
137/12 146/21 147/4
182/23

unit... [1] 127/14

until [18] 28/17 45/12

117/13 121/18 128/17)
128/21 146/15 156/19)

unusual [4] 18/5 23/8I

4/13 7/10 12/20 16/13

37/7 50/1 50/15 51/15)

140/11 143/20 143/23}

use [19] 66/2 73/6
75/19 84/6 84/22

84/25 130/12 131/25
132/6 168/10 169/25

179/12 180/25 181/3
181/17 182/6

used [27] 54/5 55/13
58/18 62/8 64/6 66/1
66/11 81/5 81/9 83/9
83/10 83/11 83/17
87/14 97/18 104/25
116/16 131/17 156/3
169/10 170/6 176/6
178/18 181/9 182/9
183/15 184/24
useful [4] 28/12
30/21 38/19 138/4
user [8] 26/16 26/16
36/9 38/8 39/1 39/4
115/1 116/5

users [1] 115/6

75/15 87/18 105/23
142/18 180/21
usual [1] 116/19
usually [4] 25/12
36/8 36/11 151/8

value [3] 158/20
159/1 185/1

values [3] 105/9
136/8 136/11

various [3] 38/5
74/24 177/13

verdict [2] 150/7
150/24

version [7] 6/23
51/22 52/12 52/16
57/19 62/10 114/19
versions [2] 58/22
91/1

very [33] 7/18 7/21
16/18 23/12 34/18
42/12 47/4 49/10 60/4
67/16 78/8 81/3 94/2
95/20 96/23 109/22
111/15 113/3 117/13
121/25 127/13 128/7
129/14 130/9 133/8
134/18 137/11 142/16)
146/1 156/19 174/17
175/10 186/13

view [14] 44/23 45/7
47/10 64/17 86/23
100/14 100/18 114/24}
116/14 133/23 141/10)
153/14 163/19 183/16)
viewpoint [1] 151/25
views [1] 45/5
visible [6] 36/9 36/18
94/21 107/2 107/9
107/14

170/25 178/11 178/13)

using [7] 67/22 68/10

Ww

160/14

waiting [1] 71/16
Wales [1] 158/19
walking [1] 48/5
want [20] 9/20 9/23

76/16 95/11 95/18
95/19 96/21 96/24
124/20 125/9 139/2

180/25 181/17
wanted [23] 5/13
7/19 8/24 13/4 13/7
42/12 68/11 70/6
77/13 77/19 77/23
78/5 79/23 95/22 96/1
96/1 96/4 97/22
145/13 157/13 159/4
163/10 169/24
wanting [2] 77/8
163/12
wants [3] 140/7
160/6 160/7
warrant [1] 183/17
Warwick [8] 2/10
12/20 33/14 33/16
43/21 43/25 53/17
60/13
wary [3] 62/23 63/25
64/9
was [744]
wasn't [53] 7/18 9/2
14/10 15/16 16/10
17/22 18/16 19/17
20/3 23/12 23/20
34/19 35/14 37/17
44/15 59/25 68/8
68/15 79/6 82/1 87/17
92/17 93/20 93/22
93/24 94/5 95/19
96/15 101/13 101/19
102/4 106/2 108/5
109/24 113/5 128/13
129/23 130/1 133/11
134/3 134/18 139/14
140/1 140/9 142/5
146/12 148/5 149/14
150/14 156/12 159/14]
161/22 169/20
waste [1] 85/13
wasting [1] 85/9
way [53] 1/13 2/25
6/21 8/2 9/1 10/5 12/8
12/10 23/25 40/9
40/10 40/14 45/9
48/15 53/3 58/7 61/10
65/17 72/14 72/19
73/6 73/14 75/15 82/8
84/2 85/11 87/24 88/1
88/2 89/11 92/14

volume [1] 121/7

wait [2] 124/13

44/6 50/3 74/21 76/14

155/15 171/22 172/11

92/16 96/17 105/2
106/2 107/12 108/5
110/6 110/10 111/17
111/21 113/5 116/1
120/19 120/20 124/8
132/8 132/9 142/22

184/8

ways [1] 27/6

we [326]

we'd [3] 85/11 97/13
143/13

we'll [5] 1/25 10/14
42/15 53/21 90/22

33/13 42/4 47/22
48/12 63/2 63/15
64/24 76/11 80/16
86/17 117/11 181/23
186/14

41/12 53/23 54/25
56/19 63/24 68/25
71/16 76/10 90/19

173/11

week [14] 3/17 34/19
41/23 44/14 76/7
80/14 88/20 88/25
90/8 112/12 149/20
1471/7 175/22 176/2
Weekly [1] 83/1
weeks [5] 31/25
93/17 100/20 126/6
136/14
Welcome [1] 151/7
well [43] 7/10 9/5
15/24 26/9 27/2 27/21
29/2 34/13 35/10
43/20 49/11 49/13
50/18 70/4 76/8 76/21
77/8 81/22 95/10
95/25 110/2 111/17
111/18 112/13 118/19}
129/7 133/11 133/20
137/9 137/11 141/21
142/12 165/5 166/14
171/16 172/20 173/14}
174/1 178/11 178/24
179/5 182/24 186/1
went [7] 17/15 36/23
82/25 93/16 97/6
106/2 159/12
were [232]
weren't [16] 6/4 7/25
13/16 14/14 29/7
39/17 48/5 57/6 73/1
111/16 111/19 112/20}
119/25 150/25 167/14}
176/1
West [32] 11/18 15/7
17/17 19/4 19/15
20/16 21/1 21/20 27/4
36/2 36/14 36/21

153/10 153/16 156/15}

we're [15] 28/2 29/23

we've [15] 4/13 21/15

122/24 148/13 162/22)

36/25 37/25 39/3 40/2
59/11 59/14 60/25
67/16 67/19 67/21
69/15 69/16 71/23
76/8 117/3 117/21
122/20 126/3 127/24
158/4
what [266]
what's [5] 122/14
122/15 134/13 147/19)
184/12
whatever [2] 23/19
140/2
whatsoever [1] 61/13
when [67] 4/22 5/17
7/11 9/18 10/25 11/4
12/13 15/3 15/10
15/25 16/3 16/15 19/3)
19/14 23/9 26/7 27/3
28/17 32/24 36/1
36/19 44/14 54/5 55/7
55/15 60/9 63/16
63/19 64/17 65/12
65/23 66/22 68/20
70/15 75/17 78/7
79/14 79/22 80/6 81/1
81/10 82/25 89/23
92/9 97/10 99/20
99/24 100/20 101/9
108/10 109/19 110/6
1411/8 115/19 130/11
132/8 134/18 140/18
140/19 141/22 144/3
159/12 163/16 175/3
175/24 176/1 179/1
whenever [1] 15/5
where [50] 2/8 7/8
14/25 15/1 15/22 39/4I
41/18 44/22 46/3
48/10 53/1 57/5 63/21
66/16 68/22 69/8
69/14 69/19 69/21
72/22 74/14 76/24
80/4 85/2 89/24
100/23 101/1 101/13
104/14 104/17 107/16
110/24 115/5 115/19
117/8 122/12 122/13
1427/1 127/7 130/2
131/11 132/5 158/8
161/7 161/15 167/2
170/17 172/11 173/12)
182/2
whereas [2] 57/12
98/18
whether [66] 11/5
41/17 11/20 11/21
11/22 13/18 14/21
16/8 16/17 16/20
18/12 18/21 19/11
19/13 23/22 26/2
26/11 26/15 28/6 29/8I
38/25 39/9 39/13 41/7
48/22 50/3 51/20

(76) unit... - whetherO
Ww

whether... [39] 59/10
64/16 67/13 76/14
77/10 77/11 77/20
78/2 78/23 79/10
80/10 80/11 84/10
84/14 88/20 88/25
91/2 99/7 100/14
103/25 107/4 109/20
111/9 112/15 120/5
120/7 123/25 124/5
124/21 125/11 126/1
131/20 141/21 142/3
144/24 148/11 156/5
164/11 182/9
which [142] 2/16
3/20 4/15 5/8 8/7 8/20
9/8 10/9 11/17 16/7
19/2 19/8 22/22 23/2
24/16 25/15 27/15
33/8 34/15 35/1 36/13)
36/16 36/23 37/5
39/17 42/11 42/17
43/5 44/15 47/21 48/1
48/12 48/13 50/18
51/19 53/14 54/3
54/19 55/4 55/16
55/22 56/23 60/5
60/13 60/15 61/3 61/4
62/10 64/20 65/13
65/17 66/19 66/22
67/11 68/1 68/6 68/12
69/9 69/24 70/14 71/5
71/8 71/21 75/15
75/23 77/16 78/9
79/25 82/15 82/21
83/4 83/25 86/17
88/10 88/13 88/20
89/4 89/8 89/15 89/15,
90/13 91/7 91/10
91/23 94/4 94/9 96/25)
98/14 99/19 101/4
104/12 108/5 108/9
112/11 113/9 116/14
122/20 124/13 124/25}
125/3 131/24 132/6
132/16 142/20 143/1
144/1 148/20 148/25
150/9 150/14 155/5
155/18 155/24 156/14}
157/21 158/4 158/24
163/8 163/10 164/16
164/21 164/25 165/2
166/25 171/11 172/11
174/3 175/7 176/17
177/4 177/7 177/14
180/10 180/18 181/20}
183/13 183/20 183/24}
184/1 185/8 185/15
185/17
while [2] 82/20
160/10
whilst [7] 62/9 64/24

124/13 154/20 159/4
165/22 184/7
who [23] 4/10 54/13
83/12 83/13 99/6
102/14 103/23 115/41
119/23 120/14 141/3
167/2 167/17 171/10
173/10 174/7 174/14
176/20 180/4 180/7
182/18 183/16 185/23)
whole [5] 23/13 56/3
89/16 114/9 175/20
whom [1] 174/5
why [84] 3/24 4/25
5/7 10/3 12/9 12/9
12/10 13/3 13/16
13/22 17/25 20/9
25/23 28/9 28/21
28/23 29/1 29/2 29/5
30/7 32/25 33/5 34/4
38/17 42/12 44/15
45/17 49/3 49/10
50/17 52/7 52/13 61/4
66/12 67/19 68/1 68/3
73/3 74/10 74/12
75/25 76/8 77/10 78/2
78/22 79/7 84/24 89/7
89/15 90/2 90/4 94/15)
95/6 96/12 105/12
113/9 113/19 117/1
120/10 122/11 122/21
125/2 133/19 139/3
139/25 154/16 156/1
156/12 159/19 160/7
162/2 163/7 167/21
168/13 175/9 175/16
178/11 179/5 179/7
180/18 181/16 182/10}
185/10 186/9
wide [1] 182/12
widely [4] 98/22
98/25 100/6 100/16
wider [2] 108/10
114/13
wife [1] 150/19
Wilkerson [1] 70/10
will [23] 4/11 22/21
38/23 42/15 54/10
67/14 71/10 71/22
89/3 89/4 89/25 94/9
94/12 95/2 98/20
121/8 152/3 154/11
169/12 171/10 171/11
184/7 184/10
willing [4] 177/18
willingness [2]
100/19 103/8
Winding [1] 28/15
wish [3] 80/4 152/2
152/23
within [28] 3/8 5/9
6/22 10/5 10/8 11/21
20/13 23/13 38/3 84/8
85/17 91/20 95/17

99/15 108/19 109/5
118/18 119/4 124/6
124/16 125/25 126/3
126/18 136/5 151/14
156/7 161/7 165/15
without [19] 6/7 6/9
22/19 30/16 51/8 67/5)
71/9 72/25 74/24
104/21 115/6 115/22
116/5 117/6 152/17
161/23 171/12 173/8
180/22
witness [138] 1/12
2/12 2/14 4/20 4/21
5/10 5/25 6/24 8/14
10/13 11/2 13/14
13/17 13/23 14/3 14/6
14/11 14/15 14/17
22/7 22/24 23/5 24/13
24/19 24/24 28/15
28/24 33/10 34/21
34/22 34/23 35/1 35/7
35/11 35/12 36/13
37/16 41/8 47/7 47/8
48/11 60/10 60/17
62/24 64/1 64/9 64/10
64/18 68/1 69/19 72/4
78/10 79/14 80/6 81/2
83/21 88/17 108/11
108/12 108/12 108/20
108/24 109/8 109/11
109/11 110/2 110/7
111/12 112/4 112/10
114/6 116/20 116/23
117/22 118/3 119/15
119/19 119/23 125/17
136/23 140/24 142/8
150/12 150/15 150/25
153/1 153/5 153/10
154/22 155/8 155/14
155/19 156/3 157/5
161/22 163/3 163/4
165/25 166/2 166/4
166/6 166/22 167/7
167/12 167/22 168/23
168/25 169/1 169/2
1714/7 172/16 172/17
172/18 172/19 172/21
173/5 173/7 173/13
173/15 173/16 173/19}
174/3 174/10 174/20
174/23 174/24 175/3
175/10 175/16 176/18}
176/20 176/21 176/24
181/4 181/8 181/17
185/11 186/10
witnesses [3] 171/10
171/11 174/2
wonder [1] 117/10
wondering [1] 139/8
word [6] 96/15 123/8
137/17 155/24 158/2
170/4
wording [4] 81/5

83/3 169/9 170/3
words [12] 9/25 57/9
57/11 81/9 97/18
97/20 97/20 97/21
113/11 142/13 167/10
167/14
work [17] 35/12
35/13 66/13 69/12
75/5 92/15 92/17
94/25 96/19 103/1
103/18 134/17 136/22)
160/17 160/20 164/7
164/10
workaround [1]
TANT
worked [5] 3/9 8/2
48/24 90/16 170/12
working [18] 3/13 4/2!
69/23 92/15 96/25
118/5 118/6 118/10
118/11 122/25 124/7
124/16 126/18 137/14}
147/8 147/10 156/17
185/7
workload [1] 68/14
works [2] 30/6 164/7
worried [2] 14/10
85/7
worry [3] 9/10 48/7
182/3
worst [1] 51/6
worth [1] 87/2
would [203]
wouldn't [26] 16/17
16/19 17/10 17/21
18/4 18/14 19/5 44/16}
46/25 50/10 59/12
59/12 71/11 80/4
102/8 103/8 105/19
105/23 116/7 116/12
118/11 121/17 124/8
127/12 132/12 142/24
Wright [4] 86/5 86/6
92/22 93/4
write [1] 156/2
writing [3] 97/10
105/9 163/15
written [4] 151/9
166/8 167/21 184/1
wrong [4] 25/13 96/4
105/13 152/19
wrote [3] 53/13 61/23)
96/16

Y

yeah [19] 14/8 14/8
20/10 47/18 48/19
77/4 79/3 79/5 80/8
80/13 139/16 143/5
162/3 172/6 172/6
172/10 181/15 182/11
182/11

year [5] 72/1 75/3
131/10 177/15 181/24}

years [8] 31/18 125/3
128/22 131/18 146/23)
151/1 160/10 175/24
yes [272]
yesterday [8] 4/14
7/11 38/11 85/18
116/14 141/6 141/9
154/14
yet [5] 67/18 69/20
150/6 152/9 152/14
you [836]
you'd [13] 11/1 16/17
16/19 17/8 35/2 35/3
107/11 110/11 111/25)
125/9 146/3 149/12
180/20
you'll [6] 3/6 14/19
58/11 88/11 104/10
153/3
you're [41] 2/5 2/6
3/3 4/25 5/7 11/11
15/22 22/10 23/4 27/6)
30/2 31/19 32/4 35/17)
44/9 50/2 59/7 62/3
62/14 69/25 78/19
86/15 98/14 108/14
109/16 130/10 133/16
138/9 138/24 139/10
139/25 143/8 152/25
157/6 159/25 161/15
168/24 172/20 178/18}
181/21 182/9
you've [9] 12/4 27/17
32/4 61/6 93/25
103/13 119/15 178/12
179/6
your [141] 1/12 1/13
1/19 1/20 5/25 6/10
6/24 7/1 7/4 8/14 9/14)
9/25 10/6 12/2 12/6
12/21 17/17 20/13
21/15 22/24 27/16
28/15 30/2 34/21
34/22 34/23 35/1 38/9I
38/10 39/12 41/8 41/8)
47/6 47/17 59/20 60/9)
60/17 64/3 64/18
72/10 76/18 77/5 78/8
78/18 79/6 79/8 79/16
80/25 81/19 82/4 84/4I
84/15 86/1 86/15
88/17 90/22 96/9
96/20 98/9 100/19
101/18 103/8 103/16
106/15 106/18 107/22)
108/10 108/12 108/12!
109/8 110/2 111/12
112/14 114/3 114/6
116/23 117/22 119/4
119/15 125/17 127/3
128/4 130/21 136/22
137/5 140/2 140/6
141/10 142/13 145/3
145/18 145/23 147/4

(77) whether... - yourO
Y

your... [48] 150/23
151/7 151/10 151/12
152/5 153/22 153/25
154/9 154/11 154/22
156/9 156/12 157/5
159/10 161/6 161/7
162/16 163/3 163/24
163/24 166/11 166/15}
166/21 167/22 168/5
168/23 168/25 170/3
170/5 172/12 173/24
174/24 175/3 175/10
176/6 176/13 177/1
177/21 177/24 177/25)
178/6 178/13 178/24
179/11 180/9 185/16
185/24 186/4

yours [2] 22/11 53/8
yourself [10] 35/13
56/12 120/2 137/20
168/18 173/12 174/22)
175/17 176/21 178/3

r4

zero [5] 36/18 94/5
102/23 107/15 107/16

(78) your... - zeroO