ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Tuesday, 16 July 2024
(9.45 am)
MR BEER: Good morning, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BEER: Sir, can I ask that Mr Dunks isn't sworn for the
moment. I know that his legal representative wants to
provide me with a piece of paper that sets out
a correction that Mr Dunks wants to make to his witness
statement and he hasn't given me that yet.
SIR WYN WILLIAMS: That's fine.
(Pause)
MR BEER: Can I call Andy Dunks, please.
SIR WYN WILLIAMS: Yes.
ANDREW PAUL DUNKS (re-sworn)
Questioned by MR BEER
MR BEER: Good morning, Mr Dunks, my name is Jason Beer and
I ask questions on behalf of the Inquiry. Before I ask
you those questions there's a matter that the Chairman
will raise with you.
‘SIR WYN WILLIAMS: = Mr Dunks, under our law, a witness at
a public inquiry has the right to decline to answer
a question put to him by Counsel to the Inquiry, by any
recognised legal representative or by me, if there is
a risk that the answer to that question would
incriminate the witness. This legal principle is known
1
SIR WYN WILLIAMS: = Thank you very much.
Over to you, Mr Beer.
MR BEER: Thank you, sir.
Mr Dunks, can you, give us your full name, please?
A. Andrew Paul Dunks.
Q. You last gave evidence on 8 March 2023 for half a day
before the weather interrupted us in Phase 3 of the
Inquiry. Since then you have prepared a second witness
statement, the URN for which is WITN00300200. It's
69 pages long and it's dated 24 May 2024. I think there
are two corrections that you wish to make to it; is that
right?
A. Yes.
Q. Can we deal with the first of them, which is more
substantial, by looking at page 23 of the witness
statement. If that could be brought up on the screen,
so second witness statement, page 23, and if you look in
the hard copy in front of you. Have you got that?
A. I've got it here, not (unclear) in front.
Q. Paragraph 77, if we scroll down, please. You say in
that paragraph:
"I do not know why system event logs were not
supplied as part of the ARQ process."
Is there a correction which you wish to make to
that?
ONOaARWN
©
1
12
13
14
15
16
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
16 July 2024
in shorthand form as the privilege against
self-incrimination.
I take the view that fairness demands that I remind
you of that privilege before you give your evidence. If
at any stage you wish to rely upon that privilege,
however, it is for you to alert me of that fact.
If, therefore, any questions are put to you by any
of the lawyers who ask you questions, or by me, which
you do not wish to answer on the ground that to answer
such a question might incriminate you, you must tell me
immediately after the question is put to you. At that
point, I will consider your objection and thereafter
rule upon whether your objection to answering the
question should be upheld.
Now I think I understand correctly that you are
represented today by lawyers at the Inquiry; is that
right?
THE WITNESS: Yes.
SIR WYN WILLIAMS: So if the issue relating to
self-discrimination arises and you wish them to assist
you, and if at any stage during the questioning you wish
to consult your lawyers about the privilege, you must
tell me so that I can consider whether that is
appropriate. Do you understand all that, Mr Dunks?
THE WITNESS: I do, yes.
prop
Yes, there is.
I'm going to read it out at dictation speed, it's quite
long.
Do you wish to make the following correction:
"I have now been shown records which indicate that,
as part of the ARQ process, the CSPOA Security Team,
including me, supplied the system events log to the SSC
to check them for any financial implications ..."
Then you give a reference, eg FUJ00186421. Then you
add:
".., though I now have no recollection of this."
Correct.
Is that the correction you wish to make?
Itis, yes.
So:
"I have now been shown records which indicate that,
as part of the ARQ process, the Security Team, including
me, supplied the system events log to the SSC to check
them for any financial implications, though I now have
no recollection of this."
Correct.
Then the second correction, please, much simpler,
page 52 of the witness statement, paragraph 167. In the
first line, you say:
"It appears that I was asked to provide Litigation
4
(1) Pages 1-4
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry 16 July 2024
Support in respect of this prosecution in August 2006."
Do you wish to amend that to "May 2006"?
Ido, yeah.
Is that because you have now seen a document which has
got your name on it, which is dated from May 2006?
Yes.
Thank you. Can you go to the last page, please, which
is page 69 of the witness statement; is that your
signature?
Itis, yes.
With those two corrections brought into account, are the
contents of the witness statement true to the best of
your knowledge and belief?
Itis, yes.
Thank you very much. That can come down, thank you, and
you can put the witness statement to one side.
I'm not going to address your background, your work
at Fujitsu or the organisation of the Customer Service
Post Office Account, the CSPOA, and, in particular, the
Security Team within it, as you addressed those issues
‘on the last occasion and you provide considerable detail
about them in your most recent witness statement. You
say in that recent witness statement that, as of 24 May
2024, you remained employed by Fujitsu as an IT Security
Analyst in the Security Team; does that remain the case?
5
Yes.
This is a document you refer to in your witness
statement and, if we just pan out a little bit to look
at the whole of the front page, I don't think we see
your name on it; is that right?
Yes.
Then if we look at the second page, I don't think we see
your name as a reviewer, either mandatory or optional,
or a person to whom it was issued for information; can
you see that?
Yes.
Would that reflect the fact that the level at which you
operated meant that you didn't contribute towards
documents of this kind?
Correct, yes.
If we go back to page 1, please and if we scroll down
alittle bit, thank you. You'll be familiar with
a number of the names of the contributors there; would
that be right?
Yes.
Of the contributors, can you tell us, as at 2005, what
they did and what their relationship to the work that
you did was?
Neneh Lowther was part of the same level as I was,
within the Security Team, and she carried out or looked
7
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Yes.
Can I begin with what might be described as some process
issues. You refer in your witness statement to the Post
Office Account's Prosecution Support Section, the PSS.
Yes?
Yes.
Can you confirm that that entity, the Prosecution
Support Section, was not part of the Post Office; it was
part of Fujitsu?
Where -- I'm sorry. I believe so, yes.
Okay. Was there anyone embedded from the Post Office in
it?
No, there wasn't.
Can we look at a policy document, please, FUJ00152209.
It'll come up on the screen for you. Can you see this
is a document, the title of which is "Network Banking
Management of Prosecution Support"?
Yes.
The date of it in the top right, Version 2, is dated
29 February 2005. A summary of it, under the title,
“Abstract”, is given:
[It] outlines the end-to-end procedures required to
manage and deliver the Network Banking Prosecution
Support Service."
Can you see that?
6
after, I believe at the time, ARQ requests along with
other jobs within our team. Bill Mitchell was the
Security Manager, which would have been our line
manager. Penny Thomas would have been the same level as
myself and Neneh, I'm not sure what her role then --
whether she had become the litigation manager.
Jan Holmes and Alan Holmes -- this is where I get
confused because they've both got the same surname --
I think one --
If we just go to page 2 to help you -- and scroll
down -- we can see Jan Holmes is described as the
Quality Assurance Manager and Alan Holmes is described
as Audit. Does that help?
Yes, one was like a -- I believe the role was around
a Service Delivery Manager, that would have been Jan,
and Alan Holmes was audit support.
Thank you very much.
This document, which sets out the procedures
required to manage and deliver the Prosecution Support
Service, is this a document you would have been familiar
with back in the day, back in 2005?
Um, familiar with? I don't know. I would have probably
read it at one stage but I can't remember --
How were documents distributed to users of them at that
time?
(2) Pages 5-8
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
oP
p>po>
The Post Office Horizon IT Inquiry
I can't remember how they were distributed back then.
Was there a centralised library, sort of an intranet,
that was a depository/repository of policies that you
were able to access or expected to access or were
documents physically passed to you?
Oh, no, yeah, I don't believe they were physically
passed to us but they would have been available if
needed.
Okay, so this is the kind of document that would have
set out the procedures to be operated for --
Mm-hm.
-- the Prosecution Support Service in 2005. Just again,
looking at the reviewers and, if we go back to page 1,
the contributors, would you agree that this is
an internal Fujitsu document to which Post Office did
not apparently contribute?
It appears so, yes.
All of the contributors and reviewers are Fujitsu
employees rather than Post Office employees --
Yes.
-- is that right?
Yes.
Do you know the extent to which Post Office was given
the opportunity to comment on, or amend or provide
contributions to policies of this kind?
9
shall be recorded and included in the relevant witness
statement of fact.
"Requirements for witness statements explaining the
extraction of audit data from Horizon in response to an
[ARQ] shall be completed by the individual from PSS who
completed the request."
That's the same point as is made in 7.2.4. It
continues:
"The statement shall follow the standard format and
layout for witness statements of fact provided in
evidence. Contents of witness statements of fact are
flexible depending on specific requirements of each case
and the knowledge of the witness giving the statement.
An example of a witness statement of fact is provided in
Appendix 2. For each request, Post Office and
[Prosecution Support] will agree relevant matters (such
as those listed below) which will be covered in the
witness statement of fact (based on the knowledge of the
witness)."
If we read on, we can see that those matters
include -- if you just read the first five there and, if
we go over the page, please, to the fourth bullet point
on that page. Matters which should be covered in the
witness statement of fact include, bullet point 4:
"The process for extracting information for [ARQs]
1
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
No, I've no idea what level or whether they -- what
documents they were aware of or saw, no.
Okay. That was something that happened, if it happened,
above your level; is that right?
Correct, yes.
Thank you. Can we go to page 22 of the document,
please. Can you see, if we just scroll down, please,
under 7.2.4, it provides "Complete witness statement of
fact":
"[The Prosecution Support Service] PSS will provide
a witness statement of fact in respect of 250 [ARQs] per
annum. This will as far as possible be undertaken by
the person responsible for the actioning of the work ...
so as to retain continuity of evidence and obviate the
need for additional statements."
Just on the point -- the provision of the witness
statement will be undertaken by the person, as far as is
possible, who is responsible for undertaking the ARQ
work described earlier in 7.1 -- that, I think, accords
with what you tell us in the witness statement: if you
did the extraction, then you were the provider of the
witness statement; is that right?
Yes, yes.
Thank you. It continues, 7.2.4.1:
“Any material or otherwise pertinent information
10
and the controls in place to ensure the integrity of
that data."
Then the fifth bullet point:
"An analysis of the [ARQ], when the [ARQ] form was
received and the dates when the audit data extraction
took place. This shall be taken from the Prosecution
Support Database and audit trail file.”
Then, lastly:
“A summary of the evidence provided for the
request."
So was it right that the Post Office's only role was
in relation to ARQs, identifying the relevant matters,
ie which of these bullet points needed to be addressed
in a witness statement?
Sorry?
If we just go back, please, and scroll up, please. You
see the third paragraph there. Four lines in it reads:
"For each request, Post Office and [the Prosecution
Support Service] will agree relevant matters (such as
those listed below) which should be covered in the
witness statement of fact..."
So was it the Post Office's role to agree, with
Prosecution Support, which of the bullet points that are
listed needed to be addressed in a witness statement?
I don't know, at that level. I'm not quite sure.
12
(3) Pages 9 - 12
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
>
The Post Office Horizon IT Inquiry
We know that you made many, many witness statements --
Mm-hm.
-- what did you take as your guide, if any, as to what
to include?
In the data that we supplied or in the witness
statement?
No, in the witness statement.
From our witness template that would have been given to
use.
Okay, the witness template, we're going to come on to
look at it in a number, has a number of paragraphs in it
that have a capital letter, A through Q, I think, some
of which are optional?
Okay.
It's your evidence, not mine, that is important.
I don't give any evidence at all. The witness
statement, the template, appears to include a number of
paragraphs that are optional. Does that reflect your
understanding?
Um ... optional? No, I don't recall that.
We in the Inquiry have seen a number of emails from
either within Fujitsu or from Post Office to Fujitsu,
where they say “include paragraphs D, F and Q. No need
to address K and L".
No, I'm not aware of that taking place, no.
13
your name to and signed --
Yes.
-- you decided what went into those, did you?
No, we used the -- a template that we were told to use,
within the team.
Right?
The Litigation Support said this is the template to use,
fill in the appropriate information to accompany the ARQ
data and that's what we did.
Where was the template kept?
Um ... I believe in a shared fold.
Was that a Prosecution Service Support shared folder
within your Security Team?
Yeah, I believe so, yes.
So I don't suppose now you can help us as to whether it
looked like this document or not?
No, I'm afraid not, sir.
Okay, if we go back, please, to page 22, and scroll
down. The highlighted part at the bottom:
"For each request, Post Office and [Prosecution
Support] will agree relevant matters (such as those
listed below) which should be covered in the witness
statement of fact..."
I think, Mr Dunks, but maybe you can confirm if this
is correct, that did not accord with what happened in
15
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
p>rore>
16 July 2024
If we go forwards to page 29 and scroll down, I'm
actually going to look at this in an earlier iteration
of the policy in a moment but, if we scroll down,
please, this is the template, you remember that the body
of the policy said that there's an example witness
statement in Appendix 2 and this is Appendix 2. Can you
see that each paragraph is starting above the body of
the paragraph with a capital letter --
Yes.
-- can you see that?
Yes.
If we go over the page, can we see some more, yes?
Yes.
If we scroll on, and keep scrolling, you'll see that
there's some more paragraphs, each with a capital letter
above them. What did you understand the capital letters
were for?
It's difficult. I don't -- I don't remember whether
I read this document or if I ever used it to reference.
So I wasn't aware how the witness statements were
generated, who drafted them and how they were drafted.
But you drafted them, didn't you, the witness
statements?
Not the template, no.
Okay, the witness statements that you eventually put
14
practice? You included what was in the template, rather
than what the Post Office and Fujitsu would agree should
be covered in the witness statement.
Yes, yeah.
Would you always use the whole of the template or would
you ever say, "That paragraph isn't relevant to the
thing that I'm speaking about on this case, I'll cut
that paragraph out"?
I don't believe that happened no. I'm basing -- would
use a template that had been agreed within the team or
Litigation Support advised us to use.
So you don't remember a stage of the process where Post
Office and Fujitsu came to an agreement on what needed
to be covered off in a witness statement; you just
pulled the template from the shared drive, populated it
with the data that applied to the ARQs that you were
talking about and then signed it; is that right?
Basically, yes.
Okay. Can we move forwards, please, to page 25 and look
at paragraph 8.2. "Expert Witness Statement" is the
heading. In the second paragraph there, the policy
says:
“Itis ... conceivable that, given the size and
complexity of the Horizon system, the integrity of the
witness statements of fact may be challenged by defence
16
(4) Pages 13 - 16
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
counsel in order to discredit a prosecution. In these
cases additional, granular detail about the technical
working and integrity of various systems that constitute
the Horizon system may be required if only for ‘unused
material’.
"Expert witnesses could comprise anyone within the
Post Office Account or its approved contractors who
could be called upon to provide and testify to this
additional evidence.
“Expert witnesses could be called upon to provide,
for example ..."
Then the first one is "Operational logs" and the
last one is "Subsequent analysis of this data".
Were you aware of, never mind the detail of what
this says, but the sense of what these paragraphs say,
that, as well as what are described as witness
statements of fact, there was the facility for expert
witness statements to be provided.
No, no, I don't think I was ever made aware of anything
like that, no.
Was that language in use at the time in Fujitsu in the
Support Service, "Mr X or Ms Y" -- probably by their
first name -- "is providing a witness statement of fact"
or, "In this case, because there's been a challenge, we
need an expert witness statement"?
17
descriptions. The local work instructions were informal
documents, which at some stage had been written by those
actually performing the tasks, and which focused on the
practicalities of how to do each task. I believe Penny
Thomas drafted local work instructions in respect of ARQ
extractions, and I wrote the local work instruction in
respect of how to extract the HSD call records, though
both documents may have been updated by different people
over the years. None of these local work instructions,
that I used-on a day-to-day basis, have been disclosed
to me by the Inquiry."
I should say that's because we haven't got them.
So you tell us here that there were things that you
call local work instructions and that they were used,
rather than Fujitsu policies and service descriptions;
is that right?
Yes, correct.
In the drafting of them, were they based on the Fujitsu
policy or service descriptions?
I don't know. That I don't know.
Did you create these documents, you within the Security
Team, of your own initiative?
On the HSD calls, because that's the ones I would have
done, I can't remember whether it was off my own
initiative or I was asked by the manager to create that
19
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
pr>pPr o
oP
16 July 2024
No, not that I'm aware of. I don't recall anything like
that taking place within the team at any time, no.
You'll see that it says, "Expert witnesses could
comprise anyone within the Post Office Account”; can you
see that?
Yes.
Were you ever told that you were a person that could
provide evidence that would be classed as expert
witness?
No. No one did, as far as I'm aware, describe me as
an expert witness.
That can come down, thank you. Can we go to your
witness statement, please, your second witness
statement, it'll come up on the screen at page 17,
paragraph 53. You say:
"I and the other ... Security Analysts assisted the
Litigation Support Manager as and when required, in
addition to performing the other tasks assigned to us by
the Operational Security Manager. We were very process
driven and followed local work instruction documents
That's what I'm going to be concentrating on in
a moment, Mr Dunks:
for many of the tasks that we performed, rather
than consulting the Fujitsu policies and service
18
work instruction, so other people within the team could
perform the same task.
So if there had been a tasking, it would have been by
your manager; is that right?
Yes, yes.
Did any managers approve the local work instructions?
I don't remember that happening, no.
Can you help us as to why a manager may not have
approved the local work instructions?
No, I don't know why.
You see, we've got a suite of documents, and there are
a lot of them, which are Fujitsu policies, which say how
your work is to be undertaken, yes? I've just shown you
‘one of them.
Yes.
You tell us here that, instead of using those, you were
relying on some local work instructions?
Yes.
I'm trying to find out who signed those off, rather than
the formal policy documents that all sorts of people had
reviewed, contributed to and quality assured?
Well, I can only say my experience of the -- I created
many, many work instructions to do with my main role,
which is the key management because, again, there were
vast documents explaining things and how things worked
20
(5) Pages 17 - 20
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
within the key management arena. And for -- instead of
keep referring to that, we'd take the instructions and
create the local work instructions for somebody who
could come along and perform that task, in an easier,
step by step, and that's what we classed as local work
instructions.
To what extent were they based on the requirements of
Fujitsu policies like the one I've just shown you?
Ive no idea, actually. They would have taken
information from that.
Was any consideration given to, "We're drafting up
a local work instruction on how to extract and put into
a witness statement information about Helpdesk calls",
any consideration given to "What does our policy, our
company policy, say about that"?
I can't say for the ARQ local work instructions but, no,
I don't believe, from my point of view, from the HSD
call extraction, no.
On your document, the one that you tell us here that you
drafted, can you help us: did it say anything about
whether the Helpdesk calls that you were obtaining
should be summarised in the witness statement to which
the case related?
No, no. It was purely the actions of requesting and
downloading the Helpdesk calls.
2
No, it didn't, no.
Was there any document that regulated or regularised
what went into a witness statement, and let's stick with
HSD calls.
I don't believe so, no.
You understand that you could do it in different ways,
couldn't you? You could say, "I am Andrew Dunks. On
Monday, 1 January, I extracted 120 calls in relation to
this branch between these two date parameters from the
HSD. I exhibit them as my exhibit AD1". That's one way
of doing it, isn't it?
Sorry, are you saying would that have been part of the
instructions?
No, that could be a way of doing it?
Yes.
Another way could be making a witness statement which
said, "I'm Andrew Dunks and I accessed and read the
calls and I've cut and paste a summary of them into my
witness statement"? That would be another way of doing
it, wouldn't it?
Yes, it would have been.
Another way of doing it would be to add on the end of
either of those two some analysis of what those calls
meant?
Yes.
23
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
oP
2
prop
prop
prop,
16 July 2024
So it was quite practical about how to go about, is this
right, the extraction of the Helpdesk calls?
Correct.
It didn't say what you then did with that data?
No.
So it didn't say you must exhibit it to a witness
statement, the download?
Yeah. No, it didn't.
It didn't say you must summarise it in your witness
statement?
No, it didn't.
It didn't say you should or you should not seek to
analyse what the data means?
No, it didn't.
Is this right: it didn't say if you're unsure about what
an entry on the HSD log means, it's permissible or not
permissible to go and speak to the SSC about that to get
an explanation ~
No, it didn't, no.
- and that if you get an explanation you should record
that fact in the witness statement?
No, it didn't.
So it didn't speak about any of, from our perspective,
the important things of what because into the witness
statement?
22
By "analysis", I mean offer an opinion on what they
mean --
Yes.
-- what the entries mean, and offer an opinion over
whether the content of any of the calls related to the
integrity of the data being processed by Horizon?
Yes.
Was there any instruction at all, that you were aware
of, that told you which of those things you should do,
or which of those things you shouldn't do?
Written instruction? No.
To start with, yes, written instruction?
Yes. No.
Because, in a moment, we're going to see that, over
time, you did all three of those things, in different
cases. Was there any oral instruction that told you
when you're summarising -- sorry, when you're dealing
with HSD data, this is the way to do it in a witness
statement?
I don't recall instructions.
How about advice or guidance?
No, not advice and guidance, no.
Thank you. Okay, that can come down.
Can I turn to the issue of the extent to which you
extracted ARQ data and the extent to which you gave
24
(6) Pages 21 - 24
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
The Post Office Horizon IT Inquiry
evidence, ie the scale of the enterprise that you were
engaged in. You tell us in your witness statement, and
I'm summarising here, that, firstly, you held limited
technical knowledge of the operation of Horizon; is that
correct?
Yes.
Secondly, that you had limited knowledge of bugs, errors
and defects in the Horizon system; is that correct?
Yes.
Thirdly, that you had no role, and you did not and never
had worked, in HSD, the Helpdesk?
Correct.
Is that correct?
Can we look at paragraph 20 of your first witness
statement, please, which is WITN00300100, and can we
look, please, on page 6 at paragraph 20. Can you see
that on the screen?
Ican.
You say "On occasion", and it's going to be those words
that I'm going to be focusing on in a moment, Mr Dunks:
"On occasion, I was requested to provide the Post
Office with records of calls made to the HSD by
a particular Post Office branch and (if requested) to
summarise these in witness statements. While
I therefore did have access to the historic HSD call
25
knowledge to be able to do that, yes.
Enough knowledge to what, say that what was recorded on
the calls meant that either the Horizon system was or
was not operating as it should?
I had enough knowledge to understand -- well, during my
looking at the calls and investigating the calls,
I believe I gained enough knowledge to satisfy myself to
make that sort of statement, yes.
When you made that kind of statement, whether the
Horizon system was operating as it should or not, by
reference to the Helpdesk calls, you were offering an
opinion, weren't you?
Yes, I was.
You weren't making a statement of fact?
Yes.
Can we go, please, to POL00003219. This is
a spreadsheet. Thank you.
This is a spreadsheet disclosed to the Inquiry by
the Post Office. It appears to be a record prepared by
Fujitsu of the dates that requests for work were
received, whether a statement was required in relation
to each case and, if so, who prepared it, and whether
the statement had been posted out or not. The document,
runs from 5 April 2004 to 22 March 2005, so just under
a year.
27
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop,
16 July 2024
records, I would only be looking at them when requested
to do so as part of this task. I was not party to the
calls themselves and had no role in investigating any
errors ... or communicating with the system users about
them."
Can you confirm that that accurately records the
extent of your role in the provision of witness
statements concerning calls to the Helpdesk?
Yes.
Would you agree that what you're describing there is
a purely procedural, administrative or mechanical one,
ie extracting the data but also then summarising them in
the witness statements?
Yes.
Would you describe the function that you were performing
as a limited function?
Limited, yes.
Would it be right that you didn't have the technical
expertise to interrogate whether the Horizon system was
‘operating as it should at the relevant time?
Sorry, say that again.
Yes. Would it be right that you didn't have the
technical expertise to interrogate whether the Horizon
system was operating as it should at the relevant time?
In respect of the Helpdesk calls, I believe I had enough
26
If we look at the column F, can you see that?
Yes.
If we just go to the dropdown. Thank you. You'll see
that in, a number of rows, for example 10 and 11 and 24
‘onwards, something has been redacted -- can you see
that -
Yes.
-- I think before we got the document. We understand
that to indicate whether or not a witness statement was
required and, therefore, I can't say one way or the
other what was populated in column F. But if we go
further to the right to column N, and then if we scroll
down, you see, for example, there Penny Thomas’ name
under a "checked by" box appears, and if we just look at
the dropdown -- just look at the dropdown once more,
thank you -- you'll see that you're one of the people
who can be ticked; can you see that?
Yes.
Was that essentially the team there?
Yes, it was.
Your name, we counted them up, appears in 98 different
lines in this column between 17 August 2004 and 9 March
2005. So in a six or seven-month period, you have had
input on 98 requests from the Post Office?
Yes.
28
(7) Pages 25 - 28
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
prop
The Post Office Horizon IT Inquiry
The "checked by", was there a process of checking
something?
These checks were, if I remember correctly, for the ARQ
data and once someone had extracted the data, they'd
performed their checks at the dates, and the data looked
okay, and before it was sent to Post Office, a member of
the team, whoever was available -- so there was no
formal -- would run -- get asked to run their eyes over
it to double check before it was sent to the Post
Office, and that's who would have been put in there.
So would the "checked by" be the same person who had
done the extraction?
No.
It would be a different person?
Yes.
Okay. So over this six or seven-month period you have
checked 89 requests from Post Office. Would that sound
about right to you, about 100 over a six or seven-month
period?
I don't know. It varied. It could have been more it
could have been less over the years. I can't say that
that. That sounds about right but ...
What proportion of ARQ requests resulted in the requests
for the production of a witness statement?
I've no idea.
29
only on occasion that you were asked to provide call
records?
Yes, it wasn't - yeah.
Again, how many times a year?
Again, I don't know. It would have varied from year to
year but it wasn't large -- from what I remember, it
wasn't that many.
So once a month?
I can't say. I don't know. No. It could have been one
a month, it could have been none for the period of
a couple of months, it could have been a couple --
I don't know, I'd be guessing.
Okay, we can take that down, then. Can we go to your
second witness statement and turn to the issue of the
approach that you took to the provision of witness
statements provided by Fujitsu to support Post Office
prosecutions. I want to start with the question of
whether you were happy to provide such witness
statements, whether you were content to do so. Can we
look at your second witness statement, please, at
page 16, and read paragraph 48, please.
You say:
"I recall that Ms Bains was the main person
responsible for performing ARQ data extractions for
atime."
31
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prppreroe
16 July 2024
Can you help us whether it was always or --
Oh, no, no, no --
-- infrequently --
-- as far as -- sorry. Sorry to interrupt.
It's all right.
As far as I'm aware it was quite infrequent.
If we just go to the top of the page and look at column
O, again on "Witness Statement Required”, look at the
dropdown. We can see that's been redacted in each
column.
Yes.
I don't think we can tell the proportion of cases in
which a witness statement was required. How regularly
were you providing witness statements?
Again, quite -- I don't know, again -- for -- this is to
do with ARQs. Quite infrequently.
So, over a year, how many would you provide?
From memory, I have no idea. It could be half a dozen.
It could -- I don't -- I honestly can't remember --
Would you always do it the same way: by pulling up the
template from the shared drive?
Yes.
You remember in your witness statement you said, "On
occasion I was requested to provide the Post Office with
records of calls made to HSD". Is that right, it was
30
Can you help us with who Ms Bains was.
That was Raj Bains.
That's Rajbinder Bains, is that right, to give her her
full name?
Yes.
You tell us she was the main person responsible for
performing the ARQ extractions for a time?
Yes.
But then did that change?
Yes, it did, I mean there were a number of people who
took that main responsibility.
You continue:
“However, she did not want to be a witness in any
court proceedings so I do not believe she prepared any
witness statements. I got the impression she was
nervous because it was something unknown to her, and the
idea of going to court and being questioned was a bit
daunting.”
Just stopping there, were they the only reasons that
Ms Bains did not wish to provide witness statements?
I don't know. I'm not sure I ever had a proper
conversation about it but I do remember her being
nervous. She's not that type of outward person to want
to do that.
You continue:
32
(8) Pages 29 - 32
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
pPrPoro
The Post Office Horizon IT Inquiry
"Where [Post Office] requested a witness statement
at the time of the ARQ request, I or someone else would
therefore perform the data extraction and supply the
statement. If Ms Bains had performed the data
extraction and [the Post Office] later requested
a witness statement, then I or someone else would
re-extract the data."
So you, is this right, were not apparently afflicted
with the same concerns that Ms Bains was about making
witness statements and giving evidence and appearing in
court.
Sorry, afflicted?
Yes, she didn't want to be a witness. She was,
according to you, nervous and didn't like the idea of
going to court. You didn't suffer from any of those
afflictions?
I wouldn't say I didn't but I think I was probably a bit
more confident than Raj was at the time.
Okay, you were happy to go to court, firstly happy to
provide witness statements and then content to go to
court; is that right?
Yes, yes.
Were you provided with any training by Fujitsu, or
otherwise, about the tasks that you were performing in
extracting ARQ data, obtaining HSD call records and then
33
1.
What did you do accordingly?
I would have done that task to the best of my ability
and as thoroughly as I could.
What about the provision of evidence part of it, rather
than being professional over the extraction of the ARQ
data or the HSD call records? Was there anything in
particular that you did when you were providing the
evidence part of the function?
What do you mean by providing the evidence part? I'm
sorry?
Well, you were writing witness statements --
Yes.
-- and then you were going to court to give evidence.
Yes.
You said that you took your role seriously. Was there
anything that you did, because you took your role
seriously, in the provision of the witness statements or
the going to court to give evidence bits?
I can't think that I did anything differently, no.
I just performed the task that I did to the best of my
ability, yeah.
Okay, can we look at some documents, please, and start
by looking at FUJ00225644, and look at page 2, please.
If we scroll down, we've got the bottom part of the
35
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
16 July 2024
writing witness statements and then appearing in court?
We would have had training on the extraction process for
ARQs, and HSD calls, I'm not sure I had trading on that
because that's my responsibility and I sort of managed
that process.
So, if there was training, you'd be the trainer not the
trainee?
Quite possibly, yes.
What about the other bits, the writing of witness
statements and appearing in court; any training from
Fujitsu or otherwise on those?
No, none at all.
What thought, if any, did you give to the role that you
were performing and the fact that the evidence that you
gave may have had a significant impact on people's
lives?
I don't recall my thought process at the time of
generating those but I took that responsibility quite
seriously. I mean, I was supplying data and had to be
happy with that witness statement.
You said that you took the role quite seriously.
Mm-hm.
What did you do in carrying into effect that state of
mind: if you take something seriously, you sometimes do
things accordingly?
34
email. Can you see an email here from Lisa Allen to
Phil Budd of 29 July 2009, concerning the Porters Avenue
Post Office and the provision of a statement, yes?
Yes.
Now, the Porters Avenue Post Office, I think you know
that was run by the subpostmaster Mr Jerry Hosi, yes?
Yes.
Before we get into the detail, because it's not a case
we've looked at in any substance before, I think it
would be helpful to remind ourselves as to what happened
in Mr Hosi's case, so can we temporarily go away from
this email and look at RLIT0000130. I think you'll
recognise this as a judgment from the Court of Appeal
and, if we just scroll down, it's dated 7 October 2021
and it's in the case of Ambrose & Others, and one of the
others was Mr Hosi.
If we can look, please, at page 7, and scroll down
to paragraph 33. I'm just going to read, to get us all
in mind of what happened in Mr Hosi's case, because it's
not a case we've looked at much. The Court of Appeal
records that:
"On 12 November 2010, in the Crown Court at
[Southwark], [Mr] Hosi was convicted of one count theft
and three counts of false accounting. On the same day,
he was sentenced to a total of 21 months' imprisonment.
36
(9) Pages 33 - 36
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
On 5 August 2011, a confiscation order was made in the
sum of £3,500."
And then 34:
"An audit of Mr Hosi's branch identified a shortfall
of [£72,000, or so]. As a result, [he] and his son,
Edem Hosi, who worked in the branch with his father,
were interviewed under caution by [Post Office]
Investigators. Edem Hosi told the Investigators that
his father had four or five months earlier (before Edem
started work at the branch), told him that there were
unexplained shortages. He said his father was very
careful about money as he had worked hard to make
a success of the business.
"35. In his own interview, Mr Hosi said that he had
experienced discrepancies at the branch since he had
become the [subpostmaster]. He could not understand how
the losses were occurring. He complained about the lack
of support from the Horizon Helpline to which he had
reported the apparent losses. He said that he had
inflated the figures for cash on hand because he did not
have sufficient cash to cover the apparent losses. He
denied stealing money and blamed the losses on the
Horizon system."
Over the page.
"As Mr Hosi had blamed Horizon, the Post Office
37
other words, no work has been done to ascertain whether
the cash imbalance was because of the amount physically
to hand was too low (ie as the Post Office allege) or
because the amount shown on the IT system was too high’.
"The defence also instructed an IT expert. Although
there was correspondence complaining about disclosure,
it appears that the defence were able to view the
material they wanted, though we note that the defence
complained about the amount of time they were afforded
to do so. Gareth Jenkins was instructed by [Post
Office] to respond to the expert evidence but no formal
report or witness statement appears to have been
prepared by him. He was not called as a witness at
trial. In the event, [Post Office] relied at trial on
evidence from Phil Budd and others.
"[Post Office] accepts that this was an unexplained
shortfall case and that evidence from Horizon was
essential to the prosecution case. [Post Office]
accepts ... that the prosecution of Mr Hosi was both
unfair and an affront to justice."
Conviction was quashed on all four counts.
So that's a reminder of what Mr Hosi's case was
about. Can we go back to the email, please,
FUJ00225644. Page 2, bottom email, Lisa Allen to Phil
Budd. Lisa Allen, is this right, she was
39
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
Investigators arranged for Fujitsu ... to undertake hard
drive analysis ... [The court] have been provided with
an extract of the report of the analysis (by Phil Budd
of Fujitsu) from which we infer that the results were
inconclusive. The extract does not strike us as
supporting a prosecution. ARQ data was obtained for the
period 10 August 2006 to 29 November 2006 and disclosed
to the defence.
"Emails going back to May 2005 (five months before
the indictment period) indicate that Mr Hosi had told
Post Office about 'major problems balancing’ such that
he needed ‘urgent face-to-face help’. [Post Office]
accepts that it is not clear whether this material was
disclosed. Logs from [the Post Office's NBSC] show that
Mr Hosi made numerous calls categorised ‘Horizon
balancing’.
"The defence obtained expert evidence to challenge
the Horizon evidence. An accountant's report ...
stated:
"In the interviews it is clear that the Post Office
proceeded with a pre-determined view that Mr Hosi had
stolen the allegedly missing money. Other possibilities
have been ignored ...
"In particular, it has not been explored whether
there was any missing money in the first place. In
38
an Investigation Manager in the Post Office?
I don't know what her role was, no. Sorry, I can't
remember what her role was.
Okay, she gave evidence to this Inquiry back on
20 December 2023 and told us she was, at this time,
an Investigation Manager in the Post Office. Phil Budd,
he was a colleague of yours, is that right, at Fujitsu?
Yes. Say colleague. He worked on the account but
I didn't have day-to-day dealings with him.
If we scroll up, I think we can see his signature block,
that he was an RMGA Development, Systems Engineer. Was
that somebody who didn't work in the same team as you,
then?
Yes.
Okay. Anyway, Ms Allen says, let's read her email:
"Phil,
"Sorry for not getting back to you -- we had another
hearing and the trial has been adjourned for further
enquiries as the defence want an expert to analyse the
equipment and they need to get funding.
"Thanks for the statement I will forward it to our
Legal Team."
So it seems Ms Allan was saying there had been
another hearing, an adjournment of the trial, for the
defence expert report and a thanks for the witness
40
(10) Pages 37 - 40
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
statement.
If we go back to page 1, please, foot of the page.
You'll see, at the foot of the page, that exchange is
forwarded to you.
"Morning Andy,
"That court case reared its head against a few weeks
ago. You remember I analysed a couple of counters back
in July '07 then you got me to sign a new witness
statement in June '08, well, they came back again and
wanted me to sign another one -- just a single paragraph
to say that the counters were in ‘full working order and
would not cause a discrepancy’. I was not happy with
the implications of ‘full working order’ since I did not
perform test transactions on the counters so I provided
a new paragraph to reiterate my previous statement --
that the files thereon were correct and the counters
should be expected to perform as required.
"The reason for my email, now the defence are hiring
an expert to analyse the equipment I just wanted to make
sure [Post Office Account] are not solely relying on my
analysis -- I assume we have supplied evidence of the
transactions going through and the systems working
correctly? II'm just trying to reduce the stress I feel
whenever this pops back into my head!"
Do you know why Mr Budd was not happy with signing
41
Do you know what that means? Can you decode what's
being said there, please, by Mr Sewell?
The only thing I can deduce from that is that, after his
42 days, the message store is no longer available. The
other parts I probably wouldn't have been involved in.
Just go back down to what Mr Budd's worry was, if we
keep going, thank you. He says he was "not happy with
the implications of saying in a witness statement that
the counters were in full working order", and he says
that he felt stress whenever this popped back into his
head and seemingly was stressed again because the
defence were now instructing an expert.
Would you agree that, overall, this wasn't
a complete refusal to provide a witness statement, like
Ms Bains, but that Mr Budd was anxious to make sure,
firstly, that the witness statement he signed did not go
beyond what he actually could say --
Yes.
-- and, secondly, that other people with knowledge of
other areas of the system should carry out their
investigations properly and not put the burden on him to
say something that he could not himself say?
I'm not -- well, no, I don't believe it says that --
he's stating that other people should carry out their
work properly but there are other areas that can be
43
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
a witness statement which said that the counters were in
full working order and would not cause a discrepancy?
No, I mean, I can't remember this email but I would only
have taken my understanding from reading the email.
You wouldn't have had a discussion with him about, "Come
‘on, Phil, why don't you just sign the witness statement?
What's all this worry about, saying that the counters
are in full working order and wouldn't cause
a discrepancy"?
Acconversation on -- well, I don't remember having
conversations with him, but I would certainly not have
had a conversation along those lines, no.
If we just scroll up, please. You forward this to Peter
Sewell saying:
"I think you need to be made aware of what Phil has
been asked for."
He was your manager; is that right?
I think ... yes.
He replies at the top:
"Phil
“Your statement is fine and is all you can actually
say. If they stump up the cash the counter equipment
can won't be of much use as the 42 days retainer of the
message store is long gone, and will be endorsed by
Gareth."
42
looked at, or used --
So, if the expert report is going to be commissioned by
the defence, other people in the Post Office Account
should not rely solely on his analysis, Post Office
Account should supply evidence of the transactions going
through?
I don't know. I'm not sure -- I don't know what he was
thinking, whether he thought he was the only person.
I can't --
At the very least, would you agree that this kind of
email of Mr Budd being careful, should have alerted you
to the need for yourself to be careful about what you
could and could not say for yourself in a witness
statement?
No, I don't know. I can't remember what I took from
that, I'm sorry.
But this is, on the face of it, a systems engineer
saying, "I'm only going to be prepared to speak to the
matters about which I have personal knowledge"?
Of the testing that he carried out, yes.
And that "I'm not prepared to say that the counters were
in full working order and couldn't or would not cause
a discrepancy’, ie give some master opinion about the
counters and their working?
Well, no, he's saying that he couldn't do that because
44
(11) Pages 41 - 44
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
he hadn't put, from a testing perspective, he hadn't
carried out those particular tests.
In fact, as we're going to see, you gave witness
statements that were, in part, based on conversations
which you had with other people, in the SSC in
particular, weren't they --
Yes.
-- and your witness statements were based on what you
say people in the SSC had told you, weren't they?
Yes.
But what they told you was not attributed to them in
your witness statements, was it?
No, it wasn't.
Instead, it was presented in your witness statement as
if you were speaking from your own knowledge and
expertise, wasn't it?
Yes, it was.
Did you realise, when you were undertaking that task,
going off to speak to or speaking down the phone to
people in the SSC, writing things in your witness
statements that were based on things they were telling
you, about which you had no clue yourself, that you were
blurring lines?
Sorry, what was the question?
When you were doing this, writing witness statements
45
a copy of an email from Mik Peach dated 7 August 2007
with the subject ‘Requests for data and calls’ in which
he describes an ‘incident the previous year ‘in which
an SSC staff member ended up in court’ and says that
‘the SSC is NOT in a position to undertake this role’.”
In fact, the whole email -- I'm just going to quote
it without reading it -- went on to say:
“It may be that the underlying issue is a lack of
resource of a particular kind of in the Security Team,
someone who has both the technical knowledge to retrieve
and understand the data and who is capable of supplying
the analysis in the correct legal terminology to the
Post Office."
Was Mr Peach right in that respect, that within the
Security Team, there was a lack of resource of a person,
or people, who had the technical knowledge to extract
the data, on the one hand, but were also capable of
supplying analysis of the data in court proceedings?
No, I don't -- at that time, no, I don't believe that
there was. In my role within supplying those witness
statements and the calls, the call log data, no, I don't
believe I did.
In that email, the one that is cited on that page there,
Mr Peach suggested that Gareth Jenkins could fill the
gap. Do you remember, however, that when it came to the
47
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
prop
prop
16 July 2024
that were, in part, based on what other people had told
you, the facts themselves, you yourself could not speak
to, from your own personal knowledge, did it occur to
you that you were blurring lines?
No. No.
Had anyone told you, or given you guidance, that it was.
acceptable to essentially speak on behalf of SSC staff
without revealing that that was what was going on in
your witness statement?
No, no. No one had explained that I had to -- well, as
I say, it wasn't just SSC. No one explained to me that
I had to state where I gained that knowledge from.
Can we go back to your witness statement, please,
page 19. This is second witness statement, page 19,
paragraph 60. You tell us that:
"One person from the SSC who I do recall interacting
with concerning litigation support was Anne Chambers.
I recall sitting a witness waiting room with Anne
Chambers for a couple of days prior to us both giving
evidence (which I thought was the Old Bailey but now
understand would more likely have been the Lee Castleton
proceedings at the High Court). My recollection is that
after that case Ms Chambers did not give evidence in
court again, and that Mik Peach did not want any of his
team to go to court. The Inquiry has provided me with
46
Seema Misra trial, Mr Jenkins deferred to you over the
reading of the Helpdesk logs?
What, during the Misra trial?
Yes.
No, I don't remember that, no.
You don't remember that, okay. In any event, you've
told us in your witness statement that you passed on
what people told you in the SSC, in terms of analysis of
HSD calls; is that right?
Sorry, I'm trying to listen to the question. Can you --
Yes, in your witness statement generally you tell us
that you went to the SSC and spoke to them, or called
them --
Yes, I -
-- and asked them for assistance --
At times, yes.
-- on what entries in HSD logs meant, and whether or not
what was recorded there would have had an effect on the
operation of the Horizon system?
Yes.
You presented that in witness statements as if that was
from your knowledge and understanding, and your own
analysis. In the light of that, did you think that it
was appropriate, given the SSC's reluctance to undertake
that function themselves --
48
(12) Pages 45 - 48
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
o>
2
A
The Post Office Horizon IT Inquiry
No.
- ie they don't want to go to court either, and explain
their own entries on records and, instead, what's
happening is you're phoning them up asking what entries
mean, presenting it as if it's your analysis but without
saying so?
No, I don't believe I saw it along those lines. I saw
it along the lines -- through any investigation or any
reading of any literature or documents or speaking to
people, once I've spoken to those people, or asked
questions about this, that and the other, I had that
understanding. So it was within my -- at that time, it
was within my own knowledge.
So because somebody tells you something, you're allowed
to repurpose it as your own knowledge in a witness
statement and evidence in court, is that what you're
saying?
Repurpose?
Yes. As if it's your own knowledge.
Well, no, I then understood it, and then I considered
it, that I knew then, that.
Did it ever occur to you or did you ever think, "Why is
it that I'm speaking to what the SSC are saying, and yet
the SSC don't want to go to court themselves"?
No, I didn't see it like that, no.
49
that many mobile phones are stolen on the streets of
London every day, that doesn't mean I approve of it.
Well, I would have taken approval of signing off that
they were aware that I was doing that. So, I mean, if
they didn't think I should be doing it, they would have
said I shouldn't be doing it.
Was there a relationship between Mr Peach being
protective of his team, saying that they aren't to go to
court any more, and you taking a greater role and
effectively giving some of the evidence that they would
have given?
I don't think so, no. I don't believe so. I can't
remember that.
MR BEER: Thank you. Sir, we're about to turn to
a different topic. Might we take the break until 11.25,
please?
SIR WYN WILLIAMS: Yes, of course.
MR BEER: Thank you, sir.
(11.13 am)
(A short break)
(14.25 am)
MRBEER: Good morning, sir. Can you see and hear us?
‘SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Thank you.
Mr Dunks, can I turn to the issue of the extent of
51
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
16 July 2024
Did you think at all as to why the SSC don't want to go
to court any more?
I can't remember my thought process but I do remember
that Mik Peach was quite protective of his team in all
respects of doing things.
Did anyone decide that it was acceptable for you to
essentially provide SSC evidence in court so that they
no longer had to answer for their work, their own work,
in witness statements or in oral evidence?
1.
Did a manager sign it off and say, "Look, Mik Peach is
being protective over his team, he's not letting them go
to court. I'm being put up instead. I chat to the SSC
and I say what they would have said if they had gone to
court". Did anyone sign that off?
Well, sign off... um --
But --
If you're saying sign off as they were aware that that's
what I was doing and so they accepted that I was able to
do that, well, yes, because -- I mean, I would have had
discussions with that and I think some of the
documentation, that they were aware. That that's what
I would be doing.
When I say "sign it off", I mean give explicit approval
to it, rather than being aware that it goes on. I know
50
the analysis that went into the HSD logs. Can we look
at how you described this in your second witness
statement at page 18, paragraph 57. Thank you. You
say:
“In respect of the HSD calls, as part of my due
diligence when analysing whether there could have been
an impact on the integrity of the data, I would consult
with colleagues who had come across the issues before or
who had [a] greater technical knowledge than me, such as
the Software Support Centre (SSC), to better understand
the nature of the issues being raised and how they were
resolved."
Can you please explain your approach to what you
describe as "due diligence" in providing evidence about
whether phone calls to the HSD might demonstrate
an issue that went to system integrity?
Sorry, what was the last bit of that?
Yes. Can you explain the approach that you took,
ie what prompted you to make a call to the SSC; what
level of concern in what you read on a call log would
cause you to go to the SSC?
Um --
You call it due diligence, here.
Yeah, due diligence. I would have carried investigation
and look at through each of the calls.
52
(13) Pages 49 - 52
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
>
>
prop
The Post Office Horizon IT Inquiry
Stop there. You say you would have carried out
an investigation. What did your investigation consist
of?
Right, I'd have printed out all the calls in detail, or
printed them out. I'd have read through the calls --
So printing and reading them?
Yes, step by step, and looking at the calls. If there
was an area within there that I didn't quite understand
what was going on, or what was -- how it was being
resolved, I would consult whoever I believed at the time
would have been able to help me understand what was
going on.
How did you identify that person?
Just through knowledge of who within the account could
help me with that information.
What does that mean? Did you go back to the person in
the SSC that was mentioned in the call log?
Er, I can't remember if that's what I did, because the
SSC team changed. I may have done. I may have done at
times but that wasn't always the case, no.
Would you phone them?
I'd phone them, or -- no, not really. I didn't do a lot
of over the phone. A lot of the time I would go up to
the sixth floor where the SSC were based and speak to
them personally because I had a lot of dealings with
53
I don't know. I had --
Would you agree, Mr Dunks, that you, from your own
perspective, could not say that what you were being told
was right or wrong?
I don't know, because I -- these were the people who
dealt with these calls, so I would have had to rely on
their own knowledge. I mean, if they didn't know --
Isn't that the answer then?
Sorry?
You yourself couldn't know whether what they were
telling you was right or wrong?
Um --
You just said, "I would have to rely on them"?
Yes, I suppose so, yes.
That's why you were actually speaking to them -- because
you didn't know the answer yourself?
I didn't know the answer prior to the investigation, no,
I didn't.
Prior to speaking to them, you didn't know the answer.
Yes -- no, correct.
So I think we've agreed that you couldn't yourself say
whether what the SSC were telling you was true or false?
I suppose so, yes.
Why did you want to speak to colleagues about whether
a record of a call might suggest a system issue with
55
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
them on lots of other issues to do with other roles
within our Security Team.
And so you would go and speak to somebody, you can't
remember how you identified who the somebody was?
No, I don't, no.
Would it be whoever happened to be on shift, on duty at
that time?
More than likely, yes.
Did you make a record of the conversation that you had
with that person?
No. I may have -- sorry, I may have made notes of
what -- on the resolution or what I needed, yeah, but
I didn't make a record of the conversations, no.
Did you know whether you were required to make a record
of your conversation with the person to whom you spoke
where what they told you was essentially going to form
part of your witness statement?
No, I wasn't aware, no.
I take it that you didn't think that you needed to do
so, even though your witness statement was going to be
placed before a criminal court?
No, I didn't -- I wasn't aware I needed to, no.
You personally, would you agree, couldn't say whether
the thing that you were being told was actually right or
wrong?
54
Horizon?
Because I'd have had to defer to someone who's got a far
greater technical knowledge than I did.
We've addressed whether you thought that you needed to
make a record of what they were telling you. Did you
know, one way or the other, whether you had to explain
in your witness statement that what you were telling the
court was, in fact, not based on your own knowledge but
was what somebody had told you?
Two things there: firstly, I wasn't aware and had never
been made aware that, if I'd spoken to somebody to gain
that knowledge, that I had to state that; and, secondly,
as I said before, I read that part of the witness
statement as within my own knowledge and, if I'd done
research or investigated something, at that time,
I would have had that knowledge. That was from --
I knew about it.
Who did you depend upon, if anyone, to give you advice
‘on those sorts of issues, ie whether it was permissible
to speak to somebody in the SSC; if you did speak to
somebody in the SSC, whether you had to make a record of
the conversation; and that if you did speak to somebody
in the SSC, you should disclose that transparently on
your witness statement?
I don't know. I would have relied on management. My
56
(14) Pages 53 - 56
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
line management, they were aware of what I was doing.
Can you name names, please?
I would have said any of my -- the Security Managers at
the time. I mean, I think I've listed the ones that
I remember. Brian Pinder, Pete Sewell, Donna Munro, off
the top of my head, right at this moment.
Did you have access to legal advice within Fujitsu?
I'm not sure. I wasn't made aware that I did, so -- but
if I did, I'm sure -- no, I wasn't aware.
Were you aware that there were lawyers within Fujitsu?
I think so. I can't say when or I was aware or did
know, no. I don't...
Did you ever seek advice from lawyers within Fujitsu
‘over any of the matters that I've asked you about?
No, I didn't.
Did, to your knowledge, any of your managers ever seek
such advice over people in your Security team providing
evidence that was based in part on what other people had
said, who themselves were refusing to go to court?
No, I'm not aware that anybody did.
Can we look at something else you did, as part of the
process in satisfying yourself that calls either did or
did not have an impact on the integrity of data, and
look at page 38, please. It's paragraph 115, which is
towards the bottom of the page. You say:
57
Horizon data?
In supplying the witness statements, I would have had to
have satisfied myself -- because of the wording within
the witness statement, I'd have had to satisfy myself
that there wasn't any impact.
I'm asking, did you, therefore, see it as your role in
the Security Department to give assurances that what
you'd read in the call logs could have had no impact on
the integrity of Horizon data?
I didn't see it as -- well, yes, I saw it as my role
because I was supplying the witness statements. So yes.
Did you ever provide a witness statement in all of your
years in which you said that a call record did challenge
the integrity of Horizon data?
I don't believe I did no.
Did you ever provide a witness statement, in all of your
years, in which you said that what was recorded in
an HSD call record even possibly challenged the
integrity of Horizon data?
No, I didn't. No.
So it was all one way? Nothing you ever read over
decades ever, even possibly, called into question the
integrity of Horizon data?
Through my -- no, I didn't, through my investigation,
no, I didn't. I satisfied myself that it didn't, no.
59
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
"Where there was a possibility that the issue being
raised could have affected the data, I examined the
records of the investigations carried out by the
engineers assigned to deal within the call to confirm
that they had either determined there was no impact ...
or that a fix had been deployed to remedy any fault.
Where I was unsure of anything, I would consult with
colleagues who had come across the issues before or who
had greater technical knowledge than me, such as the
SSC, to better understand the nature of the issues being
raised and how they were resolved, to satisfy myself
that it had had no impact on the integrity of the data."
You describe here the way that you went about
satisfying yourself that what was recorded in call data
did not have an impact on the integrity of Horizon data.
Yes?
Yes.
Who told you that you were supposed to satisfy yourself
that call data did not have an impact on the integrity
of Horizon data, ie what was recorded in the Helpdesk
records?
I don't think anybody said that I had to satisfy myself.
I don't think anybody has used those words to me, no.
Did you see it as your role in the Security Department
to give such an assurance: no impact on integrity of
58
Can I look at a third aspect of your approach, please.
Page 59 of your witness statement, paragraph 196. You
say:
“When I stated that ‘All of the calls were of
a routine nature’ ..."
Just stopping there, that's a phrase that you used
in, I think, all of the witness statements that you
produced, ie every call that you ever read about was of
aroutine nature. Yes?
Yes.
So:
"When I stated that ‘All the calls are of a routine
nature’, I meant that these were the type of calls which
were frequently made to the HSD, and which I would
regularly see when reviewing the call records. I note
that some of the calls made to the HSD in respect of
this branch ... related to balance discrepancies that
the [subpostmaster] was stating were repeatedly shown on
the system”, et cetera.
You say:
"_. [note that the calls were repeatedly referred
by the HSD to the NBSC. I would therefore likely have
understood this to be a commercial or user issue rather
than a technical error. I would often see commercial
issues such as this being raised by the [subpostmasters]
60
(15) Pages 57 - 60
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
and then referred to the NBSC, and therefore would have
considered these calls to be of a routine nature."
So can I summarise it that whenever you saw, in
an HSD record, that the call had been referred to the
NBSC, you believed that that was (a) a call of a routine
nature, and (b) did not raise a technical error,
a system error?
Correct, yes.
So that involved, would you agree, an assumption that
the HSD were always right to refer the call to the NBSC?
Yes.
It involved an assumption that if the subpostmaster
thought that the discrepancy about which they were
complaining was a result of a technical error, a system
error, then they were wrong?
If the call had been referred to the NBSC, yes, I would
have seen that as a business commercial or a user error.
Yes, and what I'm asking, Mr Dunks, is that you're
assuming that the person in the HSD has got it right,
and that the subpostmaster has got it wrong.
No, I would assume that it had been referred to there
because they're assuming that, at first glance or
whatever, that it could have been a business issue. If
it turned out that further investigation would have been
needed, that call -- and I think I've seen it before --
61
you wouldn't know if that happened, when it got into the
NBSC?
No.
You wouldn't know if they were told in the NBSC that
"Clause 12 of the contract says that you must pay,
irrespective of fault, for all losses" --
No.
-- and many subpostmasters did, and that the technical
issue that they were complaining of therefore never
reached the surface. You wouldn't know if that
happened?
I would have known if it needed further investigation,
as in the fact that it may have been a technical issue,
that that call would have been passed back.
What about if they, in the NBSC, were told "You just
need to pay up"?
No, I -- no -- I wouldn't know.
You would write all of these up as being calls of
a routine nature, which didn't involve the integrity of
the Horizon data, wouldn't you, in your witness
statements?
It was a routine nature that those calls were passed to
the NBSC, and we have seen those calls routinely.
Isn't what you were conveying, by “All of the calls are
of a routine nature" was not about the frequency with
63
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
a call would have been passed back for further
investigation to see if it was a technical issue.
You were working on the basis that Fujitsu, in its HSD,
was correct in its categorisation of issues as being
commercial or business, on the one hand, and therefore
referred to NBSC, weren't you?
Yes, in a way, yes.
Did you have access to, and therefore the facility to
examine, when a call was referred to the NBSC?
Sorry, say that again? Did I...
Did you have access to, and the facility, therefore, to
examine, what happened when a call was referred to the
NBSC?
No, we didn't. We didn't have access to the NBSC.
So you don't know what happened after it had left the
HSD?
I -- what they did and what they carried out, no,
I don't.
So if they, for example, just kept telling the person
"Turn your machine on and off again", you wouldn't know
if that was the advice --
No, I wouldn't, no.
-- that was given. If they said to the person under the
contract that "You've got to pay up this discrepancy,
irrespective of you claiming that it's a system fault",
62
which the calls were being made but rather about the
substance of the issues, ie "These calls, you can be
assured Mr Defendant, Mrs Defendant or court, that these
calls do not involve a system issue"?
Repeat the question, sorry.
Yes. You weren't talking about the frequency with which
the calls were being made by saying “All of these calls
are of a routine nature"; you were implying that these
calls did not involve any system issue with Horizon,
weren't you?
No, not when saying they were of a routine nature, no.
They would, as I've said -- as stated in there -- that
the contents or the type of calls were seen frequently.
Might not that mean that there was a big system issue,
if you were frequently seeing calls of the same nature?
No, I don't believe so, no.
Why?
Because the types of the calls that I'd looked at and
seen.
Sorry, the types of calls --
The types -- the contents of the calls. I mean, that's
what I'd have based that on.
Can I turn to your approach to HSD call logs and, in
particular, whether you summarised them or exhibited
them. Did you always exhibit HSD call logs to your
64
(16) Pages 61 - 64
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
prop
The Post Office Horizon IT Inquiry
witness statements so that the raw materials were
disclosed to the defence and to the court, or did you
sometimes just summarise them in your witness
statements?
Sometimes just summarised them.
Why did sometimes you give disclosure of the raw
materials, so that the court and the defence could
actually look at them, and other times you didn't?
That would have been dependent on what was requested by
the Post Office.
So sometimes they would just ask for a summary and
sometimes they would ask for the call logs to be
exhibited?
Correct.
Do you know what determined, in their mind, whether it
was a summary case or an exhibiting of raw material
case?
No, no idea.
Was it chance --
No, I --
-- for the defendant which level of service they might
have got?
I've no idea. I don't know, I was just basing that on
what they requested. I don't know why they would
request one or the other. That's —
65
Do you agree that gives the reader the facility to
record everything that is recorded on the call log
itself?
Absolutely, yes.
Were there any hidden screens or hidden dropdowns, or
were they all available if you did a print to see?
No, that is the full contents of a call at the time.
Thank you. Can we look, please, at FUJ00083702. Just
look at the email first and then we're going to look at
the attachment. An email from Lisa Allen, I should say
this is about Jerry Hosi's case again. You will see the
email at the bottom, "Porters Avenue Post Office":
"andy
"As discussed.
"Can you please provide another full statement for
the above office including in the outcome of the faults
reported that it would have had ‘no effect on any
counter discrepancy’. I appear to have mislaid the
original statement and so will use the copy that I have
as unused.
"Additionally can you exhibit the disk detailing the
call logs ..."
Yes?
Yes.
Just remember, for future purposes, the request at the
67
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
16 July 2024
Did it ever occur to you, "Hold on, in some cases I'm
actually handing over the raw product here as an exhibit
and, in other cases, I'm just summarising it"?
Um --
Why is that?
No, I don't think it did. I knew full well that if --
the raw data, as in the complete call, was there and was
available if requested. At any time that they requested
any data, it was supplied.
Okay. Can we look, please, at POL00073280. This is
an exhibit sheet to your witness statement dated
27 September 2006 in Post Office's claim against Lee
Castleton; can you see that?
Yes.
We can see that it's your exhibit APD1, Andrew Paul
Dunks, I think that is?
Yes.
If we go over the page, please, can we see that you're
exhibiting here HSD call records, yes? If we just
scroll down, and just keep going. It can be done
relatively quickly. Keep going.
Aseries of HSD call records, yes? So here you are
in a civil case, in a civil context, exhibiting the call
logs themselves. Yes?
Yes.
66
end of the first line to include that it would have had
no effect on any counter discrepancy. Okay?
Mm-hm.
You replied at the top, attaching a document; can you
see that?
Yes.
"Please take a look and let me know if [it's] okay ...”
Can we look at that attachment, FUJ00083703. Then
if we scroll down, please, and go to page 2, you say, in
the fifth line:
"I've been asked to provide details and information
on the calls for advice and guidance logged by HSH ..."
That's the same as HSD, essentially, is it?
Yes.
"... recorded during the period 01/09/05 to 29/11/06 for
Porters Avenue", then you give the FAD code.
"A report outlining each call was created and
I produce the resultant CD as [your] Exhibit APD/01."
You say that was sent to the Post Office.
So you, in the Porters Avenue prosecution, seem to
have been asked by the email to exhibit a CD with the
full call logs on it and, in this witness statement, you
do exactly that: you exhibit the CD, yes?
Yes.
Then, if we scroll down:
68
(17) Pages 65 - 68
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
"I have reviewed the HSH calls pertaining to [that
branch in that period] there were 33 calls", and there's
the phrase:
all the calls are of a routine nature and do
not fall outside the normal working parameters of the
system. And in my opinion would have had no affect on
any counter discrepancies.”
I'm going to examine as to how that came about later
‘on but you'll see that that's essentially the line that
Ms Allen asked you to insert, yes?
Yes.
So, in this case, if we carry on scrolling, you then
give a summary of each of the 33 calls, by putting the
date and time, a reference number, what the problem was,
what the resolution in summary terms is recorded on the
call log to be and then the outcome. This first one was
passed to the NBSC, yes?
Yes.
That one does seem maybe routine, "check foreign
currency rates", but the second one, problem of “failing
to rollover", “passed to the NBSC for resolution".
So on that one, for example, would that fall within
your category of, because it was passed to the NBSC,
that must have been a business or commercial issue, it
can't have been a fault with Horizon because it was
69
It all would have depended on conversations and
discussions with Post Office, either Investigator or
lawyer. This would have always been probably the
starting point as in a high-level overview of the calls
and then it would have progressed from there. But if,
at the very first instance of discussions, they wanted
the calls submitted and an in-depth overview, that's
what would have been given at the starting point.
Do you know how the person that you were speaking to or
engaging with on email from the Post Office knew what to
request; would they explain what prompted them to
request more information from you --
No, I don't think I remember having a conversation like
that at all, no.
-- ie whether it was because of what they'd read in what
you had provided them, whether it was because the court
was ordering them to provide more information, whether
it was the defence asking for more information: what
prompted the unfolding of the disclosure of more data?
It could have been either of what you've just said. It
could have been where the first -- me first supplying
a witness statement to them, they would have looked at
it and reviewed it and come back and said, "Oh, we
possibly need to expand here or there”, or -- and also,
depending -- because I don't know what communications
ral
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
rPOPrSO
16 July 2024
passed to the NBSC?
Yes.
Thank you. So that's one way of doing it. Here you've
summarised all that -- firstly, in the civil case you
exhibit a printout of all of the call records; do you
remember, in Mr Castleton's case? In the second
example, you exhibit a CD of the call records and you've
summarised them in very summary terms, yes?
Yes.
Can we turn, please, to what happened in the Seema Misra
case and look at your witness statement, please. Second
witness statement, page 57, paragraph 192 at the foot of
the page. You describe in this paragraph essentially
how, in each statement in the Misra case, you gave more
and more detail of the HSD calls and that that was done
at the request of the lawyers and the Post Office?
Yes.
So this was more of an unfolding picture in the Misra
case?
Yes.
Again, can you help us, what determined which approach
you took, whether you did the first thing, gave them the
printouts as part of an exhibit, whether you provided
a CD with all of the call logs on it or whether you
summarised?
70
they were having with lawyers or whatever -- defence --
if somebody had asked for the full disclosure of the
call details, they'd have come back to us and said, "Oh
can we have those call details?"
No, I'm not aware of the process they went through.
Who did you take your orders from?
On the witness statements?
Yes.
Well, orders -- first, it would have been the request of
the Post Office, of what they wanted, any changes.
Can we go back to Mr Hosi's witness statement, please,
FUJ00083703, and look at page 2, please, and look at the
second paragraph down that we'd looked at. Thank you:
"I have reviewed the ... calls pertaining to Porters
‘Avenue [between those dates] there were 33 ... and all
the calls are of a routine nature do not fall outside
the normal parameters of the system. And in my opinion
would have had no effect on any counter discrepancies."
In order to provide that opinion, had you spoken to
anyone in the SSC in relation to any particular call or
calls?
Would have gone through the same process that I would
have done every single time, and got as much information
as I possibly could.
Had you in fact spoken on this occasion in relation to
72
(18) Pages 69 - 72
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
any of these 33 calls to anyone in the SSC?
No, I can't remember if I did. I honestly can't
remember.
You can't remember in part because it's not recorded on
the face of the witness statement whether you did or
didn't --
Correct.
-- and there's no other record of whether you did or you
didn't --
Correct.
-- and so you can't tell us the extent to which the
opinion that you formed there was or was not affected,
or was influenced, by the views of others?
No, no.
Can we go to page 13, please, of the witness statement.
You refer in page 13 to two particular calls, one ending
in 970 -- if we just scroll down a little bit, thank
you -- and one ending 008. You say, those two calls:
referred to a ‘critical event’, ‘Critical
NT_Error’. The term critical is the comparative level
of attention required to generate remedial action. It
refers to the level of attention required on a grading
system for example critical high level of attention or
warning would be medium level of attention. These
critical events occurred outside the post office opening
73
what took place for that call.
Okay, I'll move on. Can we look at POL00052220. This
is an email chain in mid-2009 concerning your first
witness statement in the Seema Misra case. Can we start
with page 4, please. Just scroll down, I think this is
the first email in the chain. You're emailing Dave
Posnett; do you remember who Dave Posnett was?
I believe he was an Investigator or part of the Security
Team within Post Office.
Thank you. It's 22 June 2009. I should say that your
witness statement eventually -- your first witness
statement in Misra -- came to be signed on 30 June 2009.
You say to Mr Posnett:
"Hi Dave,
"Please have a look at the attached Witness
Statement for West Byfleet HSH calls logged. Can you
let me know if this is okay and I'll print/sign and post
it to you."
If we go to page 3, please, and if we scroll down,
please, we'll see his reply on the 22nd; can you see
that?
Mm-hm, yes.
"Andy,
"Statement looks fine to me, though I've copied Jon
Longman (Officer in Case) for his [information]. My
75
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
16 July 2024
times and a standard action of a reboot of the systems,
which would also highlight any further issues, was
undertaken and repaired the problem and confirmed
stability of the system. I should add that this is not
my particular area of expertise. I have a general
knowledge of these procedures and have made the comments
above to aid the court."
Where did you get that information from?
I can't remember specifically where I got that
information from. No, I can't say exactly where I got
it from.
Do you agree you would have got the information from
somewhere else?
Yes.
That wasn't your own personal knowledge?
Part of that, yes. Yes, I agree.
So you're providing an opinion there, acknowledging that
this isn't your particular area of expertise, based on
somebody else's opinion?
No -- oh, what you mean generally or those particular
calls?
Well, you say, amongst the things that are included in
that paragraph, that the reboot of the system repaired
the problem?
Yes, yeah. I mean, that's -- yeah ~ trying to explain
74
only query would be that the log of 107 calls may need
to be produced as evidence or be disclosed as unused
material. If produced as evidence then it could be
incorporated in your statement now or produced in
a ‘further to’ statement later. I'll let Jon comment on
this though, as the court may be happy as it is.
"Jon,
"Can you give Andy the green light and/or comment on
my thoughts above.”
So it seems that your statement mentioned 107 calls.
You were picked up on this and, if we scroll up, please,
we can see Mr Longman's reply:
"The statement is fine but the mention of 107 calls
will no doubt interest the defence barrister. If
possible could you include in the statement a breakdown
of the calls to cover time/date/nature of call. If we
don't include it now the defence will only request this
information later."
Then scroll up, please. Your reply:
"107 calls may seem a lot but that only equates to
approximately 3-4 calls a month over the time frame."
Just stopping there, is it right that you saw it as.
routine for branches to have to call the Fujitsu
Helpdesk three to four times a month, ie nearly every
week?
76
(19) Pages 73 - 76
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
The Post Office Horizon IT Inquiry
Routine? Well, I would have said so. At the time,
I would have looked at the number of calls, I've done --
I would have done the maths and looked -- and through my
knowledge of dealing with Helpdesk calls, one call
a week, in my opinion, didn't seem that much.
Did you use the frequency of the calls as a proxy for
whether or not the substance of the calls was routine?
The frequency, at that time, I was just trying to
explain.
Overall, did you use the frequency of calls as a proxy
for whether the substance of the calls was routine?
No, I don't believe I did.
So the frequency, to you, wasn't a relevant issue?
Um ... I don't know whether I'd have taken that into
consideration. I was just talking about that -- he'd
made a statement about 107 calls seems a lot, so I just
did the maths and sort of went back to him and gave my
opinion that I didn't think it
Okay, you carry on:
"To add the information you want is going to take
1 to 2 days of uninterrupted work to complete. So to
get it [done] is not impossible it would be cutting it
fine ...
"If you need the extra detail I will enquire about
when we can get this to you ..."
77
I don't -- no, I think that was an add-on, because we
got the -- I can't remember the details of what the
first -- that witness statement I supplied him with.
Okay. I can maybe check that to see what was --
Yeah, I don't know the progress and how that -- I can't
remember how that worked. I don't believe it was just
a statement saying "Oh, there was 107 calls".
Can we look at what happened after you signed the
witness statement off on 30 June. Scroll up, please.
Keep going to page 1, please. We see a chain that
I don't think includes you, between Penny Thomas, Dave
Posnett and Jon Longman. So Fujitsu to two Post Office
men:
"Dave
"An approximate estimate for this work is:
"ARQs [£13,000-odd]
"Helpdesk Calls -- individual breakdown £1,800.
“Call-type breakdown £630.
"Do you want me to arrange a formal estimate?"
Was the level of information that you provided in
the witness statement affected by the cost of the
provision of it?
Well, I never knew there was an individual cost.
I don't believe I ever knew there was an individual cost
of the work I was doing. I understood that the whole
79
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
16 July 2024
Then if we scroll up to page 2, please, Jon Longman
says:
“Let's run with the statement as itis. If the
defence do want details of the 107 calls then a further
statement will be needed at a later stage. Maybe you
could add into your statement that the total calls only
work out at 3-4 a month over the time period and that is
not a high amount for a [post office].”
Again, would the substance of the calls make
a difference as to whether the number was significant?
At that time, I believe I was just giving an opinion
that I didn't think that the frequency or the number --
I don't believe at the time that's to do with the
substance. It was the frequency -- because he'd asked
that there were -- seemed a lot of calls there but, in
my opinion, I didn't think that there was.
So I think you were content to provide a statement with
the addition proposed by Mr Longman, because you reply
"Okay [I'll] add this to the statement and get it
posted”, agreed?
Yes, yeah.
So, in summary, at this stage, you're not providing the
substance of the calls, you're providing a witness
statement that says how many there are and that that is
not a high number?
78
ARQ process was covered under an agreement on --
based -- and payment on a number of ARQs we supplied.
I mean, I never -- I've never seen this. I don't
believe I ever knew that someone was giving this -
an estimate of cost or charging on the work I carried
out.
So if there was an effect on the level of service
provided, by reference to the amount that it costed,
that information never found its way to you?
Correct.
If we just scroll to the top of the page, thank you, you
can see that that chain doesn't then find its way on to
you. So, in summary, on this aspect of the story, you
just did what you were asked to do by Post Office, is
that right, and didn't know the extent to which
financial considerations affected the choices that they
made?
Absolutely, no.
Thank you. Can we go on, please, to FUJ00122673. This
is still in the context of the Seema Misra case and can
we look, please, at the bottom of page 1, and the top of
page 2. Just to scroll up a little bit more, please.
Thank you. We can see we're December 2009 from you to
Jon Longman. You say:
"Hi Jon,
80
(20) Pages 77 - 80
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
a
A.
prop
The Post Office Horizon IT Inquiry
"Please find below answers to the questions you
asked.
"Can you confirm how you want the complete call
information, do you want the whole call transferred to
a CD in its raw state. There are over 100 of these."
Then if we scroll up, please, and keep going. No
more relevant information there. You appear to be
querying, in this chain, in relation to what would be
your second witness statement, which you were to sign
off on the 29 January 2010, whether you should
essentially exhibit the CD; is that right?
Can you just scroll down, please?
Yes, and again, please. Maybe we should see the below
questions. If we scroll a bit further. The answers
haven't come out in red. If we just scroll back up,
please. Thank you. You say:
"Please find below answers to the questions you
asked.
confirm how you want the complete call
information, do you want the whole call transferred to
aCD in its raw state. There are over 100 of these.”
Can you help us with what you were asking?
I think that the "Please find below answers to your
questions", now seeing the contents, they were to do
with the answers about the counters which are passed on
81
"Further to [a previous witness statement] I provide
a CD AD/01 containing details of all calls logged from
West Byfleet ... between [those two dates].”
So would this have been in response, essentially, to
that email we saw of 16 March?
Exactly, yes. Well, I'm assuming, yes.
That worked its way through to you somehow?
Mm-hm.
Does it follow from, at least at this date, Mrs Misra's
defence team had available to them the underlying call
data upon which your earlier summaries were based?
Yes, I think so, yes.
Can you help us with what would have been on the CD as
AD/01?
I'm guessing -- I'm assuming it would have been as we
saw before, the call logs in their entirety.
Okay, so a series, one after the other, of 107 call logs
between those two dates?
Correct.
MR BEER: Thank you.
SIR WYN WILLIAMS: Yes, before we do, in case we've missed
Sir, that is an appropriate moment for the second
break. I wonder if we can break until 12.35 to?
it, and it's in my head, Mr Dunks did you give oral
evidence in Mr Hosi's case?
83,
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
18
19
20
21
22
23
24
25
>
A
16 July 2024
to Leighton Machin, and I then forwarded them those.
"Can you confirm how you want to complete”, that's
probably through a discussion of supplying the call
data. Does he want them printed out or -- I'm guessing
there, sorry. That may have been to do with did he want
them all printed out and sent or does he want them all
ona CD? It's just over how he wanted them.
It's not whether or not the raw data should be provided?
Absolutely not, no.
Do you know why you wouldn't provide the raw data at
this stage in one form or another?
Depending on the request that they, the Post Office,
wanted.
Okay, can we move forwards, then, to FUJ00153059. If we
look, thank you, scroll down, please. That's it. Just
there, bottom of that last email. Can you see, if we
scroll up a little further, an email between Mr Longman
and Penny Thomas, we're now on 16 March, third
paragraph:
"_. we will need Andy to produce the disk
containing the raw data of Helpdesk calls from 1 January
2005 to 31 December 2009 ...”
Then if we go forwards, please, to POL00058443, and
page 7, please -- scroll down -- we can see a witness
statement of yours, dated 30 March 2010, and you say:
82
In which case, sorry?
‘SIR WYN WILLIAMS: = Mr Jerry Hosi?
A
That's Porters Avenue, is it?
SIR WYN WILLIAMS: Yes.
A.
I don't believe I did, no.
SIR WYN WILLIAMS: All right. Thank you. Yes, fine. Yes,
MR BEER:
‘SIR WYN WILLIAMS:
12.25 -- sorry, what time did you say?
12.35, please.
12.35, yes.
MR BEER: Thank you very much, sir.
(12.24 pm)
(A short break)
(12.35 pm)
MRBEER: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Good.
Mr Dunks, you remember that I asked you about that
email exchange in mid-2009, concerning Seema Misra's
case, in which you had provided a witness statement
saying that there had been 107 calls to the Helpdesk,
and this was picked up and you were asked for more
information because otherwise the defence barrister will
only ask for it, and there was a question over how
detailed your first witness statement had been, the
witness statement that had been served on 30 June 2009,
84
(21) Pages 81 - 84
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
you said you don't think you would have just included
the number in the witness statement, or words to that
effect.
Can we look at that witness statement, please,
POL00051960. This is your witness statement of 24 June
2009, which was served under a notice of additional
evidence on 30 June 2009. If we just scroll down, we
can see some standard paragraphs. No need to read all
of those. We're going to come back to the detail of
these boilerplate paragraphs later. Then at the bottom
of the page, you say:
"An important element of the support provided to
subpostmasters and counter clerks is the Horizon
Helpdesk [It] is the Horizon user's first ‘port of
call'," et cetera.
Then five or six lines in, you say:
"I have been asked to provide information pertaining
the working condition of the Horizon system."
I think that must mean:
"I have been asked to provide information pertaining
[to] the working condition of the Horizon system. The
following information constitutes the calls logged by
HSH [for West Byfleet between 30 June '05 to 14 January
'08]. I have the reviewed the calls [between that
period]. There were 107 calls ... this equates to
85
you cut into the witness statement bits of the call
logs. Again, just one last time, what determined what
the entry-level point was, ie first statement you
provided?
The -- on the request of the Post Office, what they
wanted.
Did you have any clue as to what was motivating them or
what was influencing them as to what to ask for?
None whatsoever, no.
Okay. Can we turn to a separate issue, then, namely
what the standard paragraphs in the witness statement --
what I've described as boilerplate paragraphs -- meant
or were intended by you to mean. Can we look, please,
to start with at FUJ00155555.
If we scroll down, please -- and again, that's the
bottom of the chain, just scroll up, thank you --
an email at this point, not copied to you, it's about
a witness statement, it's between Mr Posnett, Mr Hooper
and Mr Ward; do you remember who Graham Hooper was?
Graham Hooper was the Security Manager, I believe, at
the time.
We see him described as CS Security Manager. Would that
be Customer Support Security Manager?
Yes, Security came under Customer Support.
Okay. So would he have been a manager of you at the
87
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
oP
16 July 2024
between 3 and 4 calls a month which is average for this
size post office. 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.”
I think that must mean "nor would they affect the
working order of the counters".
So, I think, in fact, you did provide a very short
witness statement that just gave the number and the
opinion, rather than any more information; is that
right?
It appears so, yes. Yeah.
Thank you. Was that a standard approach to provide
a summary of the number and an explanation of what HSH
was and then put the opinion at the bottom, and then
wait to see what happened?
There was no standard approach. I mean, once we had
received a request from the Post Office for Helpdesk
calls, there would have been a discussion or a request
of what they wanted at the time. So it would have been
on their request of what was supplied.
We saw earlier, in Mr Hosi's case, you provided
a summary --
Yes.
-- that ended up being a 13-page witness statement and
86
time?
Yes.
Thank you. We know who Graham Ward is in the Post
Office:
"Graham [I think that’s Graham Hooper],
"Just a quick note to thank you for the above in
relation to the Horizon system ... This evidence was
allowed to form part of the case and the defendant was
ultimately found guilty of 8 false accounting charges
and 1 theft charge. I appreciate the fact you supplied
the statement, especially given the short notice you
received."
Then scroll up, please. Mr Hooper forwards that on
to Martin Riddell; who was he?
Not sure.
Was he in Fujitsu?
Yes, I believe so, yes.
Are all the other people on the copy list there in
Fujitsu?
Yes.
He, Graham Hooper, says:
another good result supported by Horizon
evidence."
You're included.
Mm-hm.
88
(22) Pages 85 - 88
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
>
The Post Office Horizon IT Inquiry
Then if we scroll up, Martin Riddell replies to everyone
saying:
“Well done to everyone involved. If I was a caring,
sharing manager I would buy a drink for everyone
involved.
“But I'm not.
"So I won't."
Were you involved at this early stage, 2002 --
September 2002 -- in the provision of witness statements
for the purposes of Horizon-based prosecutions?
I don't know. I know I started on the Post Office
Account in 2002. I don't know when or how long I'd been
working on the account at that time, and I can't --
This -- I'm so sorry.
No, I can't recall if I was involved in that.
At this stage, September 2002, was there a standard form
witness statement in use within the Security Team?
I can't remember. I believe so but I can't remember.
Do you always, throughout your time over the years,
remember using standard form witness statements?
Yes.
Can we turn, please, to FUJ00152205.
Thank you. We can see, on the top right, this is
an earlier copy of the Fujitsu policy concerning
Prosecution Support for Network Banking; can you see
89
Yes.
It's asterisked, which suggests that Mr Ward did indeed
return a comment as a reviewer; can you see that?
Yes.
Again, there's a passage in the body of the document
which refers to a template witness statement of fact
being annexed as an Appendix 2. Can we turn to that
Appendix 2, please, which on page 27. Can we see that,
over that page, Appendix 2, "Witness Statement of Fact",
and if we just scroll on, quite quickly if we can.
Thank you. Just on that page and then the next page.
It goes right up until page 32. Can you see, again,
each paragraph is headed by a capital letter?
Yes.
Yes. Thank you very much. If we just quickly go back
to page 21. If we look, please, at paragraph 7.2.4.1,
third paragraph:
"The statement shall follow the standard format and
layout for witness statements of fact provided in
evidence. Contents of witness statements of fact are
flexible depending on the specific requirements of each
case and the knowledge of the witness giving the
statement. An example of a witness statement of fact is
provided in Appendix 2."
Did you know about this policy, that the company had
1
ONOaARWN
©
1
12
13
14
15
16
17
18 AL
19 Q
20
21
22
23
24 A.
2 a
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22 A.
23
24 Q.
25 A.
16 July 2024
that?
Yes.
It's dated 26 November 2002. Remember, the other one we
looked at was dated 29 February 2005, earlier on.
Incidentally on that, there is no need for people to
write in to the Inquiry to say that the 29 February 2005
didn't exist because it wasn't a leap year. We've had
lots of emails over the course of the Inquiry pointing
that out. Thank you to everyone!
You can see that the abstract is again of a similar
type:
"This document outlines the end-to-end procedures
required to manage and deliver Network Banking
Prosecution Support ..."
We can see who the contributors were: this time your
manager, Mr Hooper: Jan Holmes; and Richard Laking. Can
you help --
No, I don't recall.
If we look, please, at the approval authorities on
page 2, and scroll down, please. I think we can see
that, in the box in the middle of the page there, under
"Optional Review", one of the options was Graham Ward;
can you see that?
Yes.
He being a Post Office manager, yes?
90
produced a policy saying an example of a witness
statement of fact is provided in Appendix 2 and
a template witness statement was provided in Appendix 2?
This was in the year that joined. I don't know whether
I was actually given this document to read. I don't
remember seeing this, no.
Can we go back, please, to page 31 within the template
witness statement. Page 31, the foot of the page,
paragraph Q. You'll see that the boilerplate paragraph
Qis:
"There is no reason to believe that the information
in this statement is inaccurate because of the improper
use of the computer. To the best of my knowledge and
belief at all material times the computer was operating
properly, or if not, any respect in which it was not
operating properly, or was out of operation was not such
as to effect the information held on it. I hold
a responsible position in relation to the working of the
computer."
Were you required to say that -- what's in that
paragraph Q -- in each and every case?
Was I required? I don't know what the requirements
were.
In all of your witness statements we see that paragraph?
Yes.
92
(23) Pages 89 - 92
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
Why did you include it?
Because it was in the witness statement template that we
had been told to use.
How did you know whether it was true or false?
These -- actually, I don't -- are these -- are you
talking about ARQ witness statements?
This appears in both species of witness statement, ARQ
and HSH.
Yeah, I mean the overall of that is to the best of my
knowledge at the time. So I believed that everything
was working as it should.
How did you know it was?
Well, in respect of ARQs, I knew that there was checks
being made every time we extracted data and, in respect
of the HSD calls, it would have been looking in the
calls and I believe it is operating as it should and as
it's expected.
What's the "it" in that sentence?
The counters and --
Stop there. You believe, when you signed a witness
statement that included that paragraph, that it was
testifying to your belief that the counters were working
properly?
Were working as expected, yes.
Sorry, I interrupted you. You said, "The counters and"?
93
Then you set it out. I'm not going to re-read it.
Over the page, please, you say in 97:
"I note that this paragraph is included in the
template witness statement appended”, the document we've
just looked at, yes?
Yes.
What was the purpose of noting that there in
paragraph 97; can you help us?
I think an example of when it was used.
You weren't saying by that paragraph that you drew that
part of the witness statement from that policy?
No, I didn't, no. I didn't.
You just took it off the template that was on the
system?
It was -- yes, it was included in the template, yes.
Thank you. At 98, you say:
"My understanding at the time was that I was
confirming that I had not improperly used the audit
extraction software to manipulate the data that was
exhibiting, and that as far as I was aware the software
had run properly when extracting the data."
You see here in this witness statement you're saying
that you believed that the boilerplate paragraph was
referring to the audit extraction software.
Yes.
95
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
Um ... well, it's trying to explain that the post -- the
branch and the counters were working as expected, as to
not to affect the integrity of the data.
So this is providing a view, an opinion, an assessment,
‘on Horizon itself, in your mind?
In respect of the branches and the integrity of the
data, yes, my opinion.
I'll ask again: how would you know whether that was true
or false?
I would have made that my opinion based on the
investigation that I carried out.
How could you tell, how could you say, that there was no
reason to believe that the information is inaccurate
because of improper use of the computer?
Again, I mean, I made my -- that assumption, my opinion,
on an individual basis of every call that I looked at,
and I was being asked for an opinion, and that was my
opinion.
Can we turn to your Inquiry witness statement, please,
your second Inquiry witness statement, at page 33 at
paragraph 96. Page 33, paragraph 96, foot of the page,
you say:
"The witness statements I supplied in respect of the
production of ARQ records contained the following (or
very similar) wording ..."
94
If we scroll down to paragraph 100, you say:
"I did not believe I was verifying that the Horizon
system as a whole was operating properly at all times,
or that there could not have been any software errors
that affected any of the information held within it."
So you're here saying, firstly, do you agree, that
when you wrote or included the paragraph in each of your
witness statements, you had a positive understanding of
what it meant and what it did not mean?
Yes.
And is that true, that you can remember that standard
paragraph Q was one that you held a belief at the
relevant time as to what it did mean and what it didn't
mean?
At the time of writing these statements, yeah, I would
have had a -- yes.
And that it was only limited to the reliability or
improper use of the audit extraction software and not
relating to Horizon as a whole?
Yes.
Are you sure that that was your contemporaneous belief
‘over each of the years when you were signing this.
template statement in prosecutions?
Yeah, I would have held that position. Yes, I would
have done.
96
(24) Pages 93 - 96
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Can we look, please, at FUJ00201401. This is
a transcript of your evidence to the High Court in the
Group Litigation. It's dated 20 March 2019. Can we go
to page 28, please -- oh, I see, we're on 28. At the
foot of the page. 28, at the foot of the page.
We can see where the transcript of your evidence
begins. You're sworn?
Yes.
Can we go forward to page 41, please. You're being
cross-examined here by Mr Miletic, and can you see in
the second question, third line, he says:
"And then paragraph 8, again, I just want to be very
precise, I want to make sure I understand exactly what
is being said in this statement, paragraph 8 begins:
"There is no reason to believe that the information
in this statement is inaccurate ...'
“Pausing here, what is ‘this statement’? Do you
mean your witness statement?
"Answer: Yes.
"Question: Okay:
“There is no reason to believe that the information
in this [witness] statement is inaccurate because of the
improper use of the system.’
"What is the 'system' there? Is that the system of
the process of strategy thing audit data, or is it
97
The questioning does continue:
“Answer: I think I was meaning about the improper
use of the audit data extraction system.
"Question: So when you say ‘system’, you mean the
process of extracting audit data?
"Answer: Yes, I do."
Then it continues:
“Question: I see, so", and then there's the quote.
Then it goes on to deal with a separate issue,
namely what "at all material times" meant.
So when you told the court that you weren't sure
what you were meaning by the boilerplate paragraph, how
is it that your memory seems to have improved five years
later, that you were definitely meaning, throughout
time, only the system used to extract audit data?
I don't know. I mean, being on -- put on the spot at
the time, I'm not sure I fully understood the question,
or whatever, but I am not sure and I can't remember what
my thought process was at the time.
Thank you. Can we turn to a separate topic, please,
South Warborough and Mrs Josephine Hamilton's case.
This is dealt with in your second witness statement in
paragraphs 183 to 189 on pages 56 onwards. I'm not
going to read what you say there though, they're for the
record but, instead, can I take you to some email
99
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
16 July 2024
something else?”
Just stopping there, you can see that you're being
asked very similar questions to the ones I've asked
already, albeit this is a different witness statement
that contains the same boilerplate paragraph. So you're
asked:
“What's the ‘system’ there? Is that the system of
the process of extracting out data, or is it something
else?
“Answer: Good question. There's no -- I'm not sure
what I was meaning by that, ‘There is no reason to
believe ..."
"Question: We will take this step by step .
Then it continues. Just stopping there, you were
saying to the court that you didn't know what you meant.
You say, "I'm not sure what I was meaning by the
‘system’ and that there is no reason to believe". How
is it had in 2019 you were saying on oath that you were
not sure what you meant by the boilerplate paragraph but
now, in your witness statement five years later, you
tell us that you knew that it meant only the audit
extraction software and not Horizon more generally?
Looking at this now and going over it, I am not sure
what I was thinking at the time or what I was trying to
remember.
98
exchanges, please, starting please with FUJ00225544.
Can we look at the bottom email first, please, we're
‘on 13 January 2007 -- if we just scroll up, thank you --
from Mr Ward to you, about a witness statement that you
had made in Josephine Hamilton's case. Mr Ward says:
"andy
"I've made one or two minor amendments ... put all
the text into the same font, spelling of South
Warnborough and also put (???) followed some acronyms so
you can explain in full ... (I know some are explained
later in the statement but to make things easier for
a barrister and jury any acronyms should be explained
the 1st time they appear in a statement). Most of the
explanations of the calls make sense to me aside from
the one below and which appears to suggest a fault ...
can you simplify what this one means?"
You'll see that he identifies a call ending 1106;
can you see that?
Yes.
If we scroll up, please. You reply later that day on
the Saturday:
"I will make the amendments on Monday, but I had
posted a copy of the statement on Friday just in case it
was okay so please ignore."
Can we look at the statement, please, the one that
100
(25) Pages 97 - 100
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
2
Pppropr
prpro
The Post Office Horizon IT Inquiry
you signed off on 14 January 2007, POL00044482. This is
your witness statement of 14 January 2007 in Josephine
Hamilton's case. Can we look at page 3, please. If we
scroll down to look for the call ending in 1106, it's in
the middle of the page there, it's got an asterisk on
it:
“New call [this is 21 April 2004] taken by Richard
Postance: Critical NT_error occurred at ... the device
... did not respond within the timeout period’...
"Resolution: An automatic error event was picked up
by the [System Management Centre] (2nd line support) and
a call was logged. The [System Management Centre]
referred to KEL (Known Error Log) ... A remote reboot of
the counter was carried out, which did not resolve the
problem. [A priority call] was raised [you give the
number] to contact and advise the [postmaster] for
a manual reboot. Call closed by Kevin Pearson ..."
So that's the one that Mr Ward was saying that that
tended to indicate a fault, yes?
Yes, that's what he was saying.
He was asking for clarification?
Yes.
You don't, I think, provide clarification here, do you?
I don't -- well, I haven't got an email with it on.
I don't know whether I spoke to him regarding that.
101
Well, the following call was raised, an A priority,
which was the next call in line, and it appears that the
reboot didn't solve the issue, so an engineer was sent
to swap over the base unit.
So you're looking at the call ending in 0123?
Yes.
So the question that was asked of you by the
Investigator was whether it disclosed a fault, and you
didn't answer it, did you?
Well, not by email, no.
Or in your witness statement?
No, because, at the time, I would have done an
investigation. The work I'd done on that -- looking
into the --
Sorry, you said you'd have done an investigation. What
investigation would you have done?
I'd have carried out the same investigation that I would
have done for any witness statement at any cause; I'd
have spoken to people, I'd have looked at things to
clarify that I was happy to make that statement.
What would you have looked at?
Anything available for me.
Such as?
I mean, that's got -- KELs -- I'd have looked in there.
You'd have looked at KELs, would you?
103
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
oP
prop
16 July 2024
Well, in the witness statement you don't, do you? If we
just carry on scrolling through to the end because
sometimes you, at the end of the witness statement, have
a mop-up paragraph dealing with any possible faults, and
so it ends. So he was saying this entry on the HSD log
is suggestive of a fault and asking whether that call
did describe a fault, and you don't address it do you?
No, not in the final witness statement, no.
Not in your email either, did you?
Not by email, I didn't -- well, it doesn't appear that
I was -- I responded back to him with it, no.
If we go back to page 3 and look at the entry, it says
that a remote reboot was carried out which didn't
resolve the problem. A priority was raised, priority
call was raised, and advice for the postmaster for
a manual reboot and then the call was closed. So, on
its face, it doesn't record that there was any
resolution to the problem, does it? Just that the call
was closed?
No, the advice was to contact -- raise another call to
get the postmaster to do a manual reboot.
Yes, and it doesn't record whether that was successful,
does it?
Not on that particular call, no.
On any other call?
102
I would have done, yes.
There are two KELs mentioned there, aren't there?
Yes.
One "rcoleman", ending in "3J", and one “pcarroll",
ending in "92", aren't there?
Yes.
So you would have gone off and searched up those two
Known Error Logs, would you?
Yes.
And, what, been satisfied that what was disclosed on
those Known Error Logs itself didn't assist in saying
that there either was or was not a fault in Josephine
Hamilton's branch being reported on this occasion?
I would -- yeah, I would have looked at each of -- both
of those KELs and, again, the same as I would have done
with the Helpdesk calls. If I didn't understand the
clarity -- I'd have got some clarity from the SSC
because the KELs are written by the SSC, to understand
what's the wording and the steps and what it's trying to
explain.
So looking at the first KEL, "rcoleman", ending in "3J",
can we look at that, please. FUJ00059070. Can we see
that's the KEL, "rcoleman", ending "3J"?
Yes.
Can you see if we scroll down, the problem:
104
(26) Pages 101 - 104
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
"NT has detected a fault on disk-drive or IDE
controller", and then there's some code.
Can you tell us what all that code means, please?
Now, no. I can't recall what everything there says or
means, no.
Would you have been able to understand all of that code
at the time?
Well, yes, I would have done. Well, I say understand,
I'd have got a knowledge of what that all meant, yes.
How would you have got a knowledge of it?
By, as I said, speaking to the -- someone within the
SSC. These are their words and there their Known Error
Logs, so they would have written them.
They're the experts, not you --
Yes.
-- and they were the experts that didn't want to give
evidence?
Yes.
"Solution -- Helpdesk
"First check for other events which may have lead to
this error, such as a bad block or corrupt storage unit
events. If such events exist follow the appropriate
KELs for those ... To test if the error is simply
a result of processor delay due to intensive processing
by the counter at the time of the event, reboot [the]
105
Riposte present ... IF NOT passed to SSC", et cetera.
So reading the entry on the Helpdesk and reading
these two KELs, which you say you would have done, how
were you able to say that what you read did not disclose
anything other than the system operating properly?
Again, from my understanding of discussing -- I mean
I would have asked -- I would that have had discussions
with someone within the SSC to explain what was going
‘on, we'd have looked at the call to see what the steps
were, and -- I mean, this is a Known Error Log so these
errors have been seen before.
Is that a good thing?
Well, there's always going to be certain errors and it's
how they're dealt with. It's how they're dealt with
that's the process.
How were you able to say that this had no affect on the
‘operation of Horizon?
No, proper affect on the counters. It's still working
as expected, there may have been faults at the counter
but, again, that's within the boundaries and integrity
of the Horizon system. I believed -- my opinion at the
time -- it was working as it should do, and there
wouldn't have been any integrity issues with the data
between the branch and Horizon.
Did you look at the data to see whether there were any
107
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
18
19
20
21
22
23
24
25
16 July 2024
counter. If the error recurs this is indication of
amore serious fault either with the computers mother
board or the affected drive. Therefore, if the message
reappears then send an engineer to replace the part at
fault."
So you can see it continues. Then if we look at the
second KEL that's referred to, FUJ00059107, the one
ending in "pcarroll ... 9Z". "Problem" -- scroll down,
please:
"Corruption on message store. Likely to be a bad
disk ... or more likely Riposte has been subjected to
an interruption whilst an indexing operation has been
taking place; if a power outage occurs during this
process it is possible for a corruption of the data
structures within Riposte ..."
"Solution ...
“A reboot can fix some of these problems so that
should be tried in the first instance, if the events
occur out of hours then ClearDesk may clear the problem.
If they persist or re-occur and the [Post Office] are
having problems, then [do something]."
Then further down, about eight lines in:
"MULTI-COUNTER SITE -- SMC must check all counters
are working okay, apart from target counter, there must
be at least one other unit with a fully functioning
106
integrity issues?
A. At the data?
Q. Yes.
A. No.
MR BEER: Thank you.
Sir, that would be an appropriate moment for lunch,
if it is acceptable to you. I wonder whether we could
break until 2.10.
SIR WYN WILLIAMS: Yes, certainly.
MR BEER: Thank you very much.
(1.19 pm)
(The Short Adjournment)
(2.10 pm)
MR BEER: Good afternoon, sir. Can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Good afternoon, Mr Dunks.
Can we move on from looking at the themes we looked
at this morning to looking at a couple of particular
prosecution cases that we've already dipped into this
morning, those of Jerry Hosi and Seema Misra, in
slightly more detail. Can we look, please, to begin
with at FUJ00083703. Can we see this is a witness
statement by you, dated 3 June 2008. If we scroll down
alittle bit, please, and a little bit further, and then
go over the page. We can see about five or six lines
108
(27) Pages 105 - 108
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
in, you say:
"I have been asked to provide details on the calls
for advice and guidance ... at Porters Avenue",
ie Mr Hosi's branch.
So this is a Jerry Hosi, Porters Avenue witness
statement; do you see that?
Yes.
‘As we have seen you say:
"I have reviewed the HSH calls [during the period
there set out] there were 33 calls from the branch to
HSH and all of the calls are of a routine nature and do
not fall out side the normal working parameters of the
system. And in my opinion would have had no affect on
any counter discrepancies."
If we just go back to page 1, please, and scroll
down to some of the boilerplate paragraphs. Can you see
the second one, you say:
"I make this witness statement from facts within my
own knowledge unless otherwise stated."
There is then something about records. You say,
four lines from the bottom, you have access to the
records, you weren't involved in any of the technical
aspects and you say, "This area is not my particular
area of expertise", and you make the witness statement
simply to clarify the call logs for the benefit of the
109
or Post Office would request things to be taken out and
put in under discussion, so most of the time it would
have been a compromise -- I say a compromise -- under
discussion of what was put in and taken out. I can't
recall what the process was or what discussions were or
reasons why that was left out.
Okay. The first line of that paragraph, which is
included, "I make this witness statement from facts
within my own knowledge unless otherwise stated", what
did you understand that to mean?
I think I said earlier that that's within my own
knowledge. I mean, “otherwise stated" -- I know you
said that I hadn't stated that I spoke to the SSC, but
I believe that I knew those facts or those -- the
knowledge was within my arena or I knew when I made the
statement.
Can you not see that, in order to make a witness
statement that includes that line “from facts within my
own knowledge”, there could never be a case where you
would include the words "unless otherwise stated"?
Sorry, say again?
Yes, in order for you to make a witness statement about
something, the something has to be within your own
knowledge, otherwise you wouldn't be able to write it
down, would you?
111
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
16 July 2024
court.
Do you see there that the boilerplate paragraph Q,
in the policy documents we looked at this morning, the
one that says, "There is no reason to believe that the
information contained in this statement is inaccurate
because of improper use of the computer", et cetera,
isn't present in this witness statement?
Correct.
It's not present if we look elsewhere in the witness
statement either?
I think I put this morning that we see that
boilerplate paragraph in all of your witness statements,
and I think you agreed with me, and I was asking you
where you got it from and why you included it in all
witness statements. I think it's right that it's in all
of the witness statements that address extraction and
explanation of ARQ data but not in witness statements
that address extraction and explanation of HSH call
logs. Why is that?
I don't know why that form of the witness statement
didn't include that.
So why was it included in the ARQ statements but not the
HSH statements?
I don't know why the two were different. They were --
the statements weren't fixed because I could add things,
110
Correct.
Given that is the case, what is the purpose of that
line? If everything is always going to be within your
knowledge, on your account, to put it in a witness
statement, what's the purpose of that line?
I don't know, to be honest with you, that's part of the
standard witness statement, I said before, that we were
told to use.
Did you not understand it to mean that, “If I don't say
anything, the things I'm speaking about are in fact
within my own knowledge, but if I identify in the
witness statement things that I've learnt from somebody
else, I'll say so” --
No, I --
-- ie unless otherwise stated?
No, that was never my understanding at the time.
Did you in fact have an understanding or did you just
include this because it was another one of the
boilerplate paragraphs?
No, Sorry, no, I had an understanding. I believed it
was within my knowledge base at the time of writing the
statement.
Okay, if that's the case, when could you ever otherwise
state?
I don't know.
112
(28) Pages 109 - 112
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
The Post Office Horizon IT Inquiry
On your explanation, that statement makes no sense, does
it? If everything is within your knowledge because
you've been told about it, you could never state
otherwise?
You could read it that way, yes but these are statements
which were written and agreed to be used.
Can we go back to page 2, please, and look at the second
paragraph down:
"I have reviewed the HSH calls ... there are 33 ...
all of the calls are of a routine nature and do not fall
‘outside the normal working parameters of the system.
And in my opinion would have had no affect on any
counter discrepancies.”
If you had no technical expertise in Horizon, what
qualified you to make that statement?
I'm being asked my opinion and, based on the knowledge
that I had at the time, that I am making that statement
based on my opinion at the time, and that's -- that's
what it says.
Can we move on, please, to FUJ00083704. This appears to
be substantially the same statement, dated two days
later, 5 June 2008. If we go to the second page and
look at the second paragraph, that appears to be exactly
the same, except that, in the previous edition, 3 June,
the last sentence of the second paragraph said "would
113
Because I'm aware or was under the opinion that, if
a call was passed to the NBSC for a business issue or
user guide -- or user error, that it was resolved to
a satisfactory resolution and --
Satisfactory to who?
To all parties.
So the postmasters were always happy, were they, in your
opinion, when things got referred to the NBSC?
I have to believe that, yes.
Where did you get that information from, the postmasters
were always happy when they got referred to the NBSC?
Well, we never saw the call come back, so I have to make
an assumption that the calls were resolved.
Is that the foundation on which you built your evidence
to a criminal court: assumption?
That the calls had been resolved, yes.
You didn't know one way or the other, did you?
That the -- it was a Helpdesk to deal with those issues,
yes.
But I think you told us in the morning session that you
had no access to NBSC records and didn't know what
happened once a case had been referred to the NBSC?
Mm-hm, yes.
So why did you write a witness statement including
reference to this call -- and there are lots and lots of
115
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prop
16 July 2024
have had no effect", E-F-F-E-C-T, and now that's been
changed to "affect", A-F-F-E-C-T; can you see that?
Yes.
So the overall opinion is still included in this
version, correct?
Correct.
Can we look at the substantive comments that you make
about the calls and look at page 3, please, and look at
call number 3. Thursday, 10 November 2008, a call
ending in 152:
"New call taken ... [postmaster] is not in the right
CA (Cash Account) period and has not rolled over this
morning."
"Resolution" over the page: referred to NBSC; call
closed."
So there was a report that the subpostmaster had
a problem with his cash account, yes --
Yes.
-- and that's passed to the NBSC?
Yes.
You said that what is reported there would have had no
affect on any counter discrepancies. This was the
system operating as intended and does not fall outside
the normal working parameters of the system. How were
you able to say that?
114
these, let me tell you, that are referred to the NBSC --
saying that this was of a routine nature, it doesn't
fall outside the normal parameters of the system and
wouldn't have had an effect on any counter
discrepancies; how can you say that?
Because if it's passed to the NBSC, it was a business
issue.
Firstly, do you agree that involves a significant
assumption, that the person in the HSH has rightly
categorised it as a business issue?
The first port of call, yes.
That it involves an assumption by you that the HSH
person has got it right?
Correct.
Even if the postmaster was saying it's a system issue,
you took from the fact that it was in fact passed to the
NBSC that it was a business or user issue?
Yes, because if it was then thought to be -- or needed
further investigation to see if it was a technical
issue, or software issue, that call would have been
passed back to Horizon to investigate it.
Are you therefore making the second assumption that,
because the call was not passed back to HSH by NBSC,
that it must have been a business or user issue?
Yes.
116
(29) Pages 113 - 116
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
2
The Post Office Horizon IT Inquiry
Can we look, please, at call number 8 on page 5, thank
you. If we scroll down, 5 January, ending in 008:
“New call ... Critical event ... ‘An unexpected
error occurred whilst attempting to insert a message.
Timeout occurred waiting for lock ...
"Outcome
“An automatic error was picked up by the SMC ...
a call was logged. The SMC referred to [Known Error
Log]", and it's the JSimpkins338Q one.
"The KEL recommends a remote counter reboot which
fixed the problem and no further events were seen."
If we carry on and look at 9 and then over the page
to 10, please, and then down to Number 10 and then
quickly read 11, screen freeze:
[Postmaster] contacted the Helpdesk as the screen
had frozen ... advised to reboot ... then continued to
operate as normal."
12, over the page, please.
13, barcode reader not working.
14, barcode reader not working.
15, keyboard not accepting swipe cards.
16, PIN pad not working.
Over the page, 17, flooding and rewiring needed.
18, more flooding.
19, no online services.
117
were back working again.
Did the calls record how long the call handler waited to
review whether there were any problems, ie whether
further issues were seen?
I'm not sure. I don't know.
Do the call records record whether there was any later
impact on balancing of the NT events which occurred,
irrespective of the system being back up and running and
stable, whether it had an impact on balancing; do the
call records record that?
Well, it doesn't -- no, it doesn't state that, no.
So you wouldn't know one way or the other?
Well, if there were no calls or -- raised about that
issue, I don't know how long they looked at the events.
So are you saying that because the subpostmaster didn't
call back in and say, "I've got an existing or
continuing balancing problem", you assumed that there
had been a solution --
Um --
-- that had been effective?
Well, yes, I mean the fault had been fixed at that time,
so yes, I do.
Do you know what the NBSC habitually advised the
subpostmasters as to their responsibility for settling
discrepancies, irrespective of the cause of them?
119
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
prop
16 July 2024
Then 20, please, if we come to 20:
"Critical NT_Error occurred ... remote procedure
call failed ...
"An automatic error event was picked up by the SMC
... a call was logged. The SMC referred to ...
MWright1245K. The KEL recommends a remote counter
reboot which fixed the problem and no further events
were seen. This was due to the KMRX service ... failing
to respond."
If we go forward, please, to page 13 and scroll
down, you say in relation to those two that I've
highlighted, the calls ending 970, and 008:
"The term ‘critical’ is the comparative level of
attention required", et cetera.
Reading on:
"These critical events occurred outside the post
office opening times and a standard action of a reboot
... as undertaken and repaired the problem and
confirmed stability of the system ... this is not my
particular area of expertise. I have a general
knowledge of the procedures and have made comments to
aid the court."
How would a reboot confirm the stability of the
system?
Confirmed that -- well, it confirmed that the counters
118
I had no knowledge of that, no.
When you compiled summaries like this, would you
habitually interrogate the KELs?
Yes, I would have looked at KELs. I'd have looked at
anything available.
Why would you look for the KELs?
Because it's mentioned in the call logs, within the
details of the call.
Do you ever set out what the KEL says in your witness
statements, concerning HSH?
No. I don't believe I did no.
Did you ever find anything relevant in the KELs then?
I can't remember.
If you had have found something relevant in a KEL, would
you have included it in the witness statement?
I don't know. I was trying to give an overview -- as my
statement says an overview of the call, of what -- it
was opened, what was happened and what the outcome was.
Did you have firsthand technical knowledge that would
enable you to dissect or to understand the impact of any
particular critical error or the implications of
a reboot?
As I said, no but, at the time, by the time I'd done my
work and written the witness statement, I believe
I understood and had a better picture, and understood
120
(30) Pages 117 - 120
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
that.
Did you ask anyone else within Fujitsu about the KELs
referred to in these call logs?
If I didn’t understand them, yes, I would have done.
I'd have spoken to whoever -- well, the SSC someone
within the SSC. Someone who had better technical
knowledge than I did at the time.
The Inquiry has heard evidence for example, about the
Riposte lock problem and the Callendar Square problem,
and has heard evidence about problems arising because
counters were told reboot the system, or were rebooting
the system in the face of errors that were in fact
unresolved; do you know about any of that?
No, I wasn't aware of -- you mention the Callendar
Square -- no, I wasn't aware of that particular problem.
So you weren't told by anyone in the SSC that the act of
being told to reboot a system in the face of a critical
NT error might itself be the cause of yet further
problems?
I don't believe that was ever mentioned, otherwise
I would have known about a bug or an issue that may have
caused some of these problems. No, I don't believe
\ did.
So we've seen that the call log mentioned the
JSimpkins338Q KEL, yes; we saw that earlier?
121
the morning. If the event is seen at a multi-counter to
is during the working hours of the [post office], or up
to 6.00 on a weekday (in case they are balancing out of
hours), RING THE OFFICE AND GET THEM TO REBOOT the
eventing counter. If they are in the process of
balancing, it is strongly advised that they reboot
before continuing with balancing as they are at risk of
producing an incorrect balance. Warn the [postmaster]
that if transactions appear to be missing, they should
not be reentered -- they will become visible after the
counter has been rebooted. If a reboot/ClearDesk does
not resolve the problem, send the call over for further
investigation -- SSC can rebuild the messagestore on the
affected counter ... If the message was seen on
a Correspondence server and the source of the message is
Riposte then raise a PEAK call and route it to SSC to
stop and restart the Riposte under Operational Change
Procedure. If the errors are seen on more than one
Correspondence server at the same time then further
investigations should be carried out."
There is nothing in your witness statement, in
particular your summary of the call logs, that
acknowledges that an imbalance could result from this
event, is there?
No, there isn't, no.
123
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
p>po>
16 July 2024
Yes.
You said you would have gone off and looked at that?
I believe I would have done, yes.
Can we look, please, at the JSimpkins KEL. FUJ00083720.
It's quite a short KEL, restricted to a page.
"Problem":
"The events started ... on 1 May after the counter
was rebooted. The counter produced one of these
messages every 10 seconds throughout the night until
ClearDesk restarted Riposte ... This cleared the lock
and the system has been fine since. We are seeing a few
of these each week, on Wednesdays during balancing.
This can lead to problems if the [postmaster] is
balancing on the counter creating events, as it may not
have a full view of transactions done on other counters
... This event can also give rise to Transfer problems,
where the eventing Node was not replicated and so
allowed Clerk to Transfer In of a [transaction] which
had already been TI on another Node for the second time
... This problem is still occurring every week, in one
case on the same site on 2 consecutive weeks ... Sent to
development.”
Then "Solution":
"This problem seems to be cleared by either
rebooting the effective counter or ClearDesk running in
122
Or that this is something that had been happening for
years, since at least May 2002, is there?
But it's seen as a -- I see that as part of the routine
handling of calls, and it's a known error that's
being -- and has got a resolution to it and how to deal
with that type of call.
How could you tell which of the multiple different
resolutions in the solution applied in this case?
On this one, “If the event is seen as ... during working
hours", I don't believe this one was during working
hours the call was raised. So that would have been my
first port of call.
I'm thinking, for example, “If reboot does not resolve
the problem, send the call over for further information.
SSC can rebuild the message store"?
Yes.
“If the message was seen on the Correspondence server
then raise a PEAK call, route it to SSC. If the errors
are seen on more than one correspondence server ..
What you don't seem to have done, is this right,
Mr Dunks, is looked at the possible different
manifestations of this problem and seen which applied in
this branch on this occasion.
I can't remember how -- what I can see is there's a set
of instructions to check and what the resolution was
124
(31) Pages 121 - 124
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
prpero
>
p>po>
The Post Office Horizon IT Inquiry
each time. I can't remember what I did and how
I balanced the two up, but"... if the event is seen
during working hours". I believe this one wasn't during
working hours.
It was at 01.15, I think.
In the morning? Yes.
In the morning.
So it's an automated event being picked up by the SMC.
That's the first part of the solution. I'm looking at
the later parts of the solution?
Yes, but there's a resolution for each step. I can't
remember what -- how far it got, or what the -- that
type -- those steps were and, like I say, how I balanced
that up to come to my solution but --
Putting it frankly, Mr Dunks, did you carry out
an investigation, come to a resolution, balance things
up, or did you cut and paste extracts from call logs and
add a generalised opinion in each and every one of these
Horizon Helpdesk witness statements?
No, not at all. That wasn't my way of working.
You carried out proper investigations --
Yes.
-- in every case to see whether there was any
possibility of an effect on balancing for alll of the
multiple calls in question, did you?
125
please, FUJ00083683, and put alongside it the June 2008
one, FUJ00083703. Thank you.
So the witness statement on the right in Mr Hosi's
case, 24 July 2007, which I believe is the witness
statement that Lisa Allen was referring to, and then the
revised witness statement of 3 June, the date of the
email on the left-hand side. Can we go to page 2 on
each statement, please, and look at the second paragraph
on each statement. Thank you. You see on the
right-hand side, the July '07 witness statement is three
lines long:
"I have reviewed the calls ... [they were all] of
a routine nature and do not fall outside the normal
working parameters of system".
Then the 3 June witness statement, on the left-hand
side adds:
"And in my opinion, would have had no affect [sic]
‘on any counter discrepancies.”
Can you see that's been added?
Yes.
So, in short, Ms Allen has asked you to provide a new
witness statement that adds in a line that, in your
opinion it would have had no effect on any counter
discrepancy and, within an hour, you do so. Correct?
On that email, yes. But I think the email states "As
127
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
propre
oP
oP
prop,
16 July 2024
And to give my opinion, I had to do that to satisfy
myself that I was happy to put that statement down in
a witness statement, yes.
That's a lot of work in each case, isn't it?
Absolutely, yes.
Hours and hours?
It could be, yes.
Can we look, please, at FUJ00083702. You remember this
email, 3 June 2008; can you see that?
Yes.
The bottom email, in fact, 9.29, in which Lisa Allen
asks you to provide another statement, including the
outcome of faults reported and that it would have had no
effect on counter discrepancy; can you see that?
Yes.
So she's asking you to provide a new statement with
a phrase "This had no effect on counter discrepancy”
added, yes?
Yes.
Can you see that you appear to have replied -- the date
has been Americanised -- on the 3 June at 10.23?
Yes.
Can you see that?
Yes.
Can we look at an early draft of your witness statement,
126
discussed". So you're trying to say that there wasn't
a lot of time in between the two. I think a lot of the
time any changes that needed or were requested would
have been via an email or had to have an email, as
a form of audit trail. So we'd have discussed this
already, so I'd probably have done that work previously
on that.
You replied within an hour with a revised statement,
adding the words "in my opinion, the calls would have
had no affect on any counter discrepancies” or the
matters mentioned in the calls --
Yeah.
-- "would have had no effect on any counter
discrepancies". Was that an opinion you formed quickly
and with ease?
It wouldn't have been quickly, no. That's something
that would have been discussed previously and it says
discussed in the email. It's something we would have
spoken about and I don't know when that discussion took
place. So I'd have already done the work and she was
just confirming what she'd requested.
You remember that, do you?
No, I don't remember the jumping around and what -- how
the sequences worked but any changes would have been
discussed and agreed before they were put in.
128
(32) Pages 125 - 128
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
What additional work would you have had to carry out in
relation to the 33 calls logged from Porters Avenue to
form the opinion that none of them would have had any
effect on counter discrepancies?
I can't remember the work I put in. I mean, looking at
that, again, I see that as a further to, to describe
that the system was -- well, the counters and everything
that I -- was working as expected. And it's a further
explanation to that.
It's an additional point, isn't it, it's rather more
than saying that the calls themselves are of a routine
nature. I mean, something can be very serious --
Sorry?
Something can be very serious but be of a routine nature
because it happens frequently, can't it?
Sorry, say that again?
Something can be very serious but can be of a routine
nature because it happens frequently?
Yes, well, I think so, yes. Yes.
You say that they do not fall outside the normal working
parameters of the system. That itself does not say,
does it, whether the subject matter of the calls caused
counter discrepancies, does it?
I'm sorry can you repeat the question?
Yes, it's saying that the subject matter of these
129
Avenue. The top email, the date has again been
Americanised, I think, printed as 5 June, in fact 6 May.
If we look at the bottom email first, 6 May:
"... please provide me with a further statement
exhibiting the 33 calls logged and can you send a copy
of the exhibit with a ... label. I apologise for the
short notice ...
"There's a mention at court tomorrow ..."
Can you see that?
Yes.
Then, at the top of the page, again, you reply quite
quickly, 11.07 through to 12.41:
“Let me know if this is okay."
Can you see that?
Yes.
When you produced that statement, did you go back and
look at the KELs?
I think that is a request -- "As discussed, can you
please provide me with a further statement exhibiting
those 33 calls". I think that was to supply the full
call details.
Okay, so this is a bit like in Misra, where you started
off with a summary, and then were asked to produce
a witness statement simply exhibiting the calls, the
call logs?
131
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
33 calls does not fall outside the normal working
parameters of the system?
Mm-hm.
It does not say one way or the other whether the subject
matter of the calls had any effect on counter
discrepancies?
That would have been my opinion at the time, if asked.
It's trying to describe that the system was working as
expected.
But what you've added is an opinion that the subject
matter of the calls would, in fact have had no effect on
counter discrepancies. So it's a material addition,
isn't it?
Yes.
Can we go back to the email, FUJ00083702. You're
referring in the bottom message to the "As discussed"?
Yes.
So are you telling us that the subject matter of the
entirety of that bottom email had been discussed, you
had carried out the work before the email of 3 June had
been received and that's why you were able to turn it
around so quickly on that Tuesday morning?
I would like to think so, yes.
Can we move forwards, please, to FUJ00083729. We're now
in 2010 -- 6 May 2010 -- still concerning Porters
130
It appears to be that type of thing, yes.
So you wouldn't have to conduct any extra analysis, is
that right, in order simply to exhibit?
If I'm just supplying the call data, no.
Thank you. Can we move on, please, to look at Seema
Misra's case. That can come down, thank you.
You made, I think, three witness statements in the
case of Seema Misra. Can we look at one of them,
please, the one dated 29 January 2010. POL00058448.
It's obviously a rogue reference. It's attaching
a witness statement by email, dated 29 January 2010,
from Mr Longman to Phil Taylor in the Post Office and
two lawyers -- one solicitor, one counsel -- attaching
your witness statement, "which deals with all the
Helpline calls regarding the Horizon system", and asking
for it to be served on the defence.
Can we look at what happened after that, please.
FUJ00152990. This is an email exchange between Anne
Chambers and Gareth Jenkins and, just staying on the top
part of it first, we can see that this email exchange is
sent to you by Penny Thomas. Okay?
Yes.
If we scroll down, please, to page 2, and scroll on
alittle further. Thank you. So this is 25 January,
after you'd signed off your first witness statement --
132
(33) Pages 129 - 132
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
>
The Post Office Horizon IT Inquiry
Sorry, 25 February, after you'd signed off your
first witness statement at the ending of January. It's
about witness statement support for West Byfleet and
Ms Chambers says to Mr Jenkins:
"... sending just to you initially.
"_. my involvement has always been unofficial and
on the basis that I had time to do it. If I need to do
more detailed analysis on this (and I'm not sure what
I would be able to find, without knowing what their
specific problem was) it will have to be agreed
officially with my manager ... I don't think I can keep
volunteering.
"There are several entries on the 1 SYSMAN2 tab
which require some further investigation. I've added
some highlighting.
"Counter 1 [the dates in May '06 and February '08]
I don't know whether the counter was replaced, or
whether the message store was deleted. The PowerHelp/
TFS calls may illuminate this.
"I don't know if the counter was used whilst these
errors were occurring -- it may have been. If they have
complaints specific to these [items], perhaps they
should be checked out???
"There are some isolated timeout waiting for lock
messages, but in general these appear to be associated
133
against the calls in your witness statement."
Did you do so?
I'd like to think I did. I wouldn't have just ignored
that email.
You tell us in your witness statement, I'm not going to
turn it up, paragraph 204 on page 61: "I've no
recollection of this email or what precisely I did in
relation to it.”
Does that remain the case? You don't know whether
you did anything as a result of ~
No, I can't remember what I did.
Can you remember whether you did anything?
Again, it's that long ago, I can't remember what I did.
I'd like to think I didn't ignore that, so I would have
done something but I can't remember.
You say, in your witness statement:
"I would have satisfied myself at the time that the
system events did not affect the integrity of data."
What did you do to satisfy yourself that the system
events did not affect the integrity of the data?
Again, based around what I learned from my
investigations.
A bit more specific than that, Mr Dunks?
Well, I don't know. I can't remember what I did.
What could you have done, in the light of the three
135
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
16 July 2024
with checksums being written. To be on the safe side,
it could be checked whether anyone was logged on [on
certain dates and times by reference to those two
counters].
"It is notable that the branch does not have the
repeated lock messages which were a feature of the
Callendar Square problem."
Over the page:
"... as far as I know [that error message] hasn't
been investigated but ... no one has complained of
a problem linked to it. I'll try to check it out."
If we scroll up, please, and keep going, Gareth
Jenkins says:
"Anne has looked at the events logs.
"She's identified number of things below to check
out.
“Are you able to check out the specific times she
has indicated, firstly to see if anyone was Logged on
and secondly against Andy Dunk's call logs."
Then up the page, Penny says to you:
"I requested the events to be checked to support
your witness statement; I've had a chat with Gareth this
morning and as no transaction date has been requested,
it is pointless going further ...
"However, you might like to check Anne's comments
134
suggestions that Anne Chambers was making, to satisfy
yourself that the system events did not affect the
integrity of the data?
Well, the system events are the ones that are picked up
by the SMC. So I would have looked at those -- those
calls. I'd like to think I did.
Did you understand what she was referring to or what she
would have been looking for in PowerHelp?
Sorry, whereabouts? No, I can't remember what -- as
I said, I can't remember the details of this specific
Did you have access to PowerHelp?
Yes, I did.
Do you understand what she would have been looking for
in order to look in TfS call records?
Well, PowerHelp and TfS were different versions of the
Helpdesk calls.
You don't record in your witness statements that
followed this that you did anything in particular in
your subsequent witness statements in the Seema Misra
case?
No, because I -- no, I didn't, no.
And why not?
Well, what investigations took place? No, I didn't,
because I was looking at the calls as a whole.
But here you had somebody from SSC, who you've told us
136
(34) Pages 133 - 136
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
pProrop
The Post Office Horizon IT Inquiry
earlier that you relied on as a technical expert,
suggesting that three things need to be done.
Yeah.
So this isn't one of those conversations over the phone
or where you went up to the sixth floor and we've got no
record of it. This is one of those occasions where we
have got a record of what the person in the SSC said
needs to be done and I'm asking, in your following
witness statements, there is no record of you doing
anything in response to Anne Chambers’ suggestions; why
is that?
Well, I wouldn't have thought that it would have been --
after I'd looked at these, if my opinion hadn't changed,
after looking at these, there wouldn't have been any
need to add that statement, as you're saying.
Is that the basis on which you operated consistently
when working for Fujitsu, that if you investigate
something but in your own mind it doesn't alter your
opinion, there's no need to record that you had
conducted that investigation, whether in a witness
statement or otherwise?
I don't think at any stage I was required or asked to
put down what investigative work that I carried out.
These were an overview of the calls and then I was asked
for my opinion, based on that.
137
an NBSC issue"?
Looking at that now, I don't know, I would assume it's
been passed to the NBSC and advised it's an NBSC issue.
It's either passed to the NBSC or advised that -- for
the user to speak to the NBSC.
But you reading this on its face without more, you'd say
this is down to the postmaster and the way she operates
her branch, nothing to do with the system?
At that point in time, yes --
How can you tell that -—
-- because it has to be --
-- from that record?
Sorry?
How can you tell that from that record: this is down to
the postmaster or postmistress and the way she runs her
branch; this doesn't indicate that there was anything
wrong with the system; it was operating as intended?
It's a business or a user issue. It has to be -- that
has to be investigated first by the NBSC, because it
looks like it's a balancing issue or advice -- for them
to sort out or look into or offer advice and guidance.
Okay, over the page, please. Then scroll down to the
second call, 10.45, Seema Misra again, three minutes
later:
[Postmaster] states that showing £6,000 down from
139
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
2
16 July 2024
Can we look, please, at the call records. POL00061793.
These are the call records that you exhibited. Can we
look at page 22, please, and we should see an entry --
if we scroll down, please, thank you, and a bit
further -- an entry of 20 February -- can you see
that --
Yes.
-- 2006, Mrs Misra, the postmaster saying, under "Call
problem":
[Postmaster] states that she is showing £6,000 down
from balance."
Yes?
Yes.
Then the call was closed within two minutes of it being
opened. The call handler said it's an NBSC issue; can
you see that?
Yes.
So, in your world, this is good evidence that this is
nothing to do with the system, it's a business or user
error?
At first, to be investigated, yes.
Well, where does it say it's to be investigated?
Well, it's being -- it's passed for the NBSC for them to
look into and deal with that issue.
Is it passed to the NBSC or is Mrs Misra told "This is
138
balance. Advised NBSC issue. [Postmaster] stated she
was talking to the NBSC and got cut off."
Then under "Call closure":
"I advised [postmaster] I would put her through
[postmaster] was happy with this.”
Then scroll down, and over the page, 3.40 the same
day, Seema Misra calling:
"[Postmaster] stating in that her system is showing
different values for certain products."
Then this one says, "Postmaster transferred", scroll
down a little bit -- again, within two minutes.
Then next call, please. Next day:
“[Postmaster] states that the last couple of weeks
they have had problems with the Horizon kit and it is
always showing they're down in money."
Over the page, "Call closed":
"She has been advised by the NBSC, advised
[postmaster] to follow this, [reference] offered.”
Then scroll down, 23 February:
[Postmaster] states that she has losses every week
in two stock units.
"Call closed ... advised that the NBSC take a 2nd
look as [the] stock units appear to be in a mess."
Over the page. Keep going, please. Then Anne
Chambers gets a hold of it. Just stop there.
140
(35) Pages 137 - 140
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
So a postmistress repeatedly calling in to the
Helpdesk, being directed to the NBSC and, on the basis
of those call records, you say this is the system
operating as intended, this is all routine, and this is
down to the postmistress not the system. Correct?
If it's passed to the NBSC to be investigated, yes.
Can we look at page 26, please, and this is the third
entry:
"NBSC states that on the CC stock unit postmasters
rolled over with a £1,500 loss. JSA stock unit
postmaster has rolled over with a £200 loss. NBSC
states that on 18 February postmaster declared her cash
and she has a £900 loss up until Saturday and then when
the postmaster declared her overnight cash on Saturday
at 1.00 pm, went back to £200 loss. NBSC also states
that her AA stock unit has a £6,000 loss. Postmaster
has rolled this over as well."
Then if we scroll down, please, and then scroll over
and keep going:
"Anne Chambers says she has checked very carefully
and can see no indication that the continuing
discrepancies are due to a system problem."
Then over the page, and just stop there. The last
five lines, she says:
"This may be to do with how the discrepancies have
144
she has losses every week in two stock units.
"Resolution: 3 March ...
"Call closed ... [postmaster] was getting
discrepancies, SSC have investigated and advised that
the NBSC take a 2nd look as the office stock units
appear to be in a mess.
"Outcome
"SSC ... advice that call be passed back to NBSC for
further investigation."
So that entire call you've summarised in this way.
How were you able to say that this call was of a routine
nature and the contents of the call would not affect the
working order of the counter?
Through -- well, again, through my investigation.
I mean, the call -- I would have said routine nature,
there were calls where postmasters had a discrepancy of
some sort and they were investigated routinely, as they
would be, and resolved. So these are routine calls.
Was everything that happened in the decades of you
working for Fujitsu routine? Nothing ever happened out
of the routine?
I don't know but I'm basing this witness statement on my
knowledge at the time that -- I'd seen numbers of these
type of calls and they're dealt with routinely.
But what was the outcome; what happened?
143
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
been accounted for. I do not really understand this ...
I recommend that this call is passed back to NBSC Tier 2
for further investigation, since there is no evidence
that the discrepancies are being caused by a system
problem. If you want the above information in an email,
let me know."
So when you were providing a witness statement
saying that all of the calls are of a routine nature and
do not fall outside the normal working parameters of the
system, were you relying on the accuracy and truth of
what's written, for example, here?
A. I believe so. Well, not just the written word. I'd
have probably spoken to somebody about what was going on
there as I would do normally. But --
Q. Who would you have spoken to?
A. I could quite easily have spoken to Anne herself.
I don't recall.
Q. Allof this entry here, leading up to this point, if we
go to your witness statement, please, at POL00167135.
This is your witness statement of 29 January 2010. Can
we look, please, at page 8 and, if we scroll down,
please, and a little further -- thank you -- that call
that we've just looked at is number 29. You summarise
that episode by saying:
“Annetee NBSC -- [postmaster] states every week that
142
A. Sorry?
What was the outcome?
A. The NBSC investigated so I have to believe that the NBSC
had resolved the issue.
Q. How did you believe that the NBSC had resolved the
issue?
2
A. Because the call didn't come back to Fujitsu for further
investigation.
Q. What about if the NBSC were telling the postmasters,
"We've taken it as far as we can go, it's now your job
to pay up. You owe that £6,000. It says so in your
contract"?
A. I know nothing about that.
MR BEER: No.
Thank you very much, Mr Dunks. You've been very
helpful indeed.
Sir, those are the only questions that I ask. There
are some questions from Core Participants. I wonder
whether we might have a ten-minute break so that they
can organise themselves.
SIR WYN WILLIAMS: Yes, by all means. What time shall we
resume?
MR BEER: 3.25, I think, sir.
‘SIR WYN WILLIAMS: = Okay, fine.
(3.13 pm)
144
(36) Pages 141 - 144
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
(A short break)
(3.25 pm)
MR BEER: Good afternoon, sir, can you still see and hear
us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BEER: Thank you very much, sir. There are two sets of
questions from Core Participants: about 15 to 20 minutes
from Ms Page and about five minutes or so from Mr Stein,
in that order.
SIR WYN WILLIAMS: All right, fine.
Questioned by MS PAGE
MS PAGE: Mr Dunks, I ask questions on behalf of some of the
oP
2
prop,
rPOoOPrPO>P
subpostmasters in this Inquiry, including both
Mr Castleton and Mrs Misra.
Mr Dunks, you were very loyal to Fujitsu, weren't
you?
Loyal?
You'd been with the business, man and boy, yes?
Man -- for, yes, almost 30 years, now, yes.
You would do or say pretty much anything to protect the
Fujitsu name; is that right?
No, that's not true.
Let's have a look at FUJ00154750. This is an email
chain that the Inquiry has seen before, between you and
your boss, Peter Sewell, and it was before you were due
145
integrity.
Let's look at your reply, if we go up, please.
"Thank you for those very kind and encouraging
words, I had to pause halfway through reading it to wipe
away a small tear ...
"Bless you all.
"andy."
What did that mean, Mr Dunks?
I got on very well with Pete at the time, Mr Sewell. He
was trying to put me at ease, so I'm just saying thank
you for that, I believe in their support.
Are you honestly trying to suggest that that was.
a genuine reply, rather than an obviously sarcastic
response?
Sorry, say that again?
Well, are you suggesting that you really did have to
pause halfway through reading that email to wipe away
asmall tear?
No.
Is that what you're saying, Mr Dunks?
No.
No. It was sarcasm, wasn't it, Mr Dunks?
It was between myself and Pete -- you say sarcasm,
possibly. But that was -- yeah, there was no real bad
intention about that. It was just the type of
147
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
pProPro
16 July 2024
to give evidence against Lee Castleton. If we scroll
down to Mr Sewell's email, thank you:
"See you in court then. Fetter Lane is where they
used to hang people out to dry. I don't suppose that
type of thing happens any more though.
"That Castleton is a nasty chap and will be out to
rubbish the FJ name, it's up to you to maintain absolute
strength and integrity no matter what the prosecution
throw at you. WE will all be behind you, hoping you
come through unscathed. Bless you."
You were going to be loyal to Fujitsu, weren't you,
no matter what?
Mmm, that's not what that says, no.
That's the culture; that's the mindset, isn't it,
Mr Dunks?
No, I read that as trying to give me support and
confidence to go in because I think that was the first
time I was being called to court as a witness.
The way that he chose to give you confidence was by
describing the person whose trial it was as a "nasty
chap"; do you see that?
Ido, yes.
He was going to be out to rubbish the Fujitsu name, and
it was up to you to stop that, wasn't it, Mr Dunks?
No, it was up to me to be strong and deal with that with
146
relationship Pete and I had at the time.
The sort of relationship where you and your manager, in
Litigation Support, joke about the fact that you're
going to give evidence against a man whose future was on
the line?
No, we weren't joking. No. I don't see that as that
and I don't see that we were joking about what we were
doing and, as you said, some -- a person's reputation
and that, were on the line. That's not something to
joke about. I don't read it as that. I can't remember
how --
Banter, isn't it, Mr Dunks?
It could have been.
"They used to hang people out to dry. Oh, I don't
suppose they do that sort of thing any more."
"Oh, I had to wipe away a small tear."
Banter, wasn't it?
Possibly it was, yes. It was trying to put me at ease
because I knew what -- it was the first time.
This was copied in to Penny Thomas and Neneh Lowther?
Yes.
This was a team email; is that fair?
Yes.
This was the culture you all worked in, wasn't it,
deeply, deeply partisan? You were all there to make
148
(37) Pages 145 - 148
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
sure that the nasty postmasters did not rubbish the
Fujitsu name. That's what your team was doing, wasn't
it
No --
-- as led by the man you got along with very well,
Mr Sewell?
No, that wasn't the culture at all. I don't know why he
used those words down the bottom. I've got no idea but
it was more, as I said, trying to put me at ease, to try
and relax and tell me that they'd got my support and my
backing.
Thank you. Let's turn to Mrs Misra and an email that
you were looking at with Mr Beer earlier on but which
I'd like to ask some different questions on.
FUJ00152990, please. This is the set of emails which
were forwarded to you. They were originally between
Anne Chambers and Gareth Jenkins, and they were
forwarded to you, as we can see at the top there, by
Penny Thomas.
Now, if we just look at this top right-hand corner
of the page, we see page 1 of 4. As we scroll down --
oh, actually, before we scroll down we can see there
that it's got Penny Thomas above the fact that it’s from
her. Do you see that in -- there we are, highlighted.
It's got that line, and "Penny Thomas" above it, and
149
you'd like to be sure of that. So it looks rather like,
doesn't it, that Ms Thomas has printed out the email
chain alongside your witness statement, claiming that
all the calls were of a routine nature. Do you see
that; do you accept that?
That hasn't got her name on the top of this one so is
that part of the printed --
No, that's -- it seems to be separate because the
printed email seems to be pages 1 to 4 of this whole
five-page bundle of documents. So it looks as if we've
got a four-page email chain printed out and then,
alongside that, your one-page witness statement. Do you
see that? Does that make sense?
No, it doesn't. If you've got pages 1 to 4, that hasn't
got a number on that witness statement.
So that's right. So what I'm suggesting is it looks as
if the four-page email change has been printed out --
Yes.
-- and filed with the one-page statement from you, or
rather at least they've been put together and then
scanned and provided to the Inquiry in that way?
Okay, yes.
So your statement sits alongside the four pages of email
chain.
Okay.
151
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
oP
o>
prop
16 July 2024
then "Page 1 of 4."
As we look through the email, so as we scroll down
to page 2, we see "Page 2 of 4", and then it continues
"Page 3 of 4" and "Page 4 of 4".
Now, would you agree that that suggests that Penny
Thomas printed off that email chain? That's often the
format we see, isn't it, when people print off an email
and it comes out with their name at the top?
To be honest with you, I don't know. If that's the
format, I'll take your word for it. I'm not 100 per
cent sure on that.
Allright. Well, the final page that is part of this
document is a short statement from you and, if we can go
to that, please, page 5. So there we have "Page 4 of
4", that's the email and then we have this witness
statement from you, and it's really just that, it's that
‘one liner, and it's dated and apparently signed, the
signature has got the marker over it saying, "GRO" which
means that it has been signed but it doesn't show.
The statement really simply says:
“Further to my statement dated 29 January 2010,
I can confirm that all the calls mentioned from West
Byfleet Post Office to the Horizon System Helpdesk are
of a routine nature."
That's all there is to it. We can scroll down if
150
On the one hand, your statement is saying that all the
calls are of a routine nature, but the heart of the
email chain is the Anne Chambers email in which, by
contrast, she makes it absolutely clear that the calls
required some technical investigation and some
cross-checking to find out what lay behind them and
whether they were indeed quotes "routine". Do you
accept that?
Can we go up --
It was read out to you earlier, we can go up to the
email from Anne Chambers.
Oh, yes, yes, I remember --
Yes?
Mm-hm.
So she's basically saying that there needs to be further
investigation into these calls?
Yes.
Yeah? That's been filed alongside your statement saying
"No, no, they're all routine", yeah? You're nodding so
I'm taking that as a yes for the transcript.
Yes, sorry. Yes.
Now, would you accept that when you were sent this email
chain, it put a burden on you to check your witness
statements and make sure that what you'd said in them
was correct and not misleading?
152
(38) Pages 149 - 152
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
Well, that would have been my process throughout.
So when you received an email from Anne Chambers saying
there's a whole number of technical things that need
checking, you should have done that, shouldn't you,
given that you had already signed a witness statement
that claimed that these calls were all just routine?
Well, yes, yeah. I would have done the work, yes.
So you say now, do you, that you did all the work that
was set out in Anne Chambers’ email here?
I hope to think I did. I don't remember what that
involved and what I did specifically.
Let's look at what she says needs to be done. She says,
first of all, that "The PowerHelp/TfS calls may
illuminate this". That's the middle of the page there.
Then she says:
"I don't know if the counter was used while these
errors were occurring -- it may have been. If they have
any complaints specific to these times, perhaps they
should be checked out???"
Are you saying that you did that?
I'd like to think I did, yes.
At this time, there was no ARQ data. How would you have
done it?
Well, what do you mean at this time? No, this time
I hadn't supplied the data. I'd have had the data to
153
1010 -- as far as I know this hasn't been investigated,
but on the other hand no one has complained of a problem
linked to it. I'll try to check it out."
What did you do about that?
I can't remember what I did on that. I mean, that reads
that Anne was going to try and check it out. I may have
spoken to Anne, she may have spoken to me. I can't
remember what took place.
Well, let's go up to the top of the email chain and
remind ourselves of what took place:
"I requested the events to be checked to support
your witness statement; I've had a chat with Gareth this
morning and as no transaction data has been requested
it's pointless going further with this exercise.
"... you may like to check Anne's comments against
the calls in your witness statement."
So all you had, Mr Dunks, was the call records, and
you had nothing else. You could not check out what
Mrs Chambers was saying needed to be checked out, could
you? And yet you had provided a witness statement which
claimed that all calls were routine.
I can't remember how I came to that conclusion but
I would have been happy at the time. I don't know how
I came to that conclusion. The calls may -- maybe --
that may be in the information of the calls and when the
155
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
>
16 July 2024
carry out and to be able to make that statement, so
I had the data.
You had the call records but you didn't have the ARQ
data. It hadn't yet been produced. That's actually in
the first email in this chain. We can go up to it if
you like.
But this is referring to the Helpdesk.
Yes, but how would you have known whether counters were
being used while these errors were occurring without the
ARQ data?
I don't know what the -- how I'd come to that conclusion
but it's asking me to have a look and I'd like to think
that I did.
What I'm saying to you, Mr Dunks, is that you didn't yet
have the information you needed to have a look, and yet
you had produced a witness statement in which you said
that all the calls were routine, and you did nothing to
change that, did you?
Because of what I had done to investigate it, there
wouldn't have been anything -- if I believed that there
was no more information that's needed, and my witness
statement was accurate to what I believed at the time,
there wouldn't have been needed any further changes.
Let's go down to the bottom of the email:
“Error Message: Error in node retrieval for node(s)
154
calls were logged. I -- again, I can't remember what
I would have done but I would have done something.
At the very least, your statement that had already been
signed required a qualification, did it not, saying
there are some further matters which need to be
investigated when the ARQ data has been requested and
supplied?
Clarification that I still believed that that statement
was true, yes.
You did nothing, Mr Dunks?
What do you mean, I didn't --
Well, we do not see, do we, a further witness statement
in which you qualify or say anything at all about the
statement that we've just had a look at, in which you
claimed that all the calls were routine.
If the statement didn't need updating, because that
statement was, in my opinion, still true, there was no
update needed.
How was it still true, Mr Dunks, when Mrs Chambers had
just set out all the ways in which the calls needed to
be investigated, to find out whether they were routine?
Yeah.
How could it still be true when those investigations had
not been carried out and could not be carried out?
Well, I'm sorry, but I would've done checks. I don't
156
(39) Pages 153 - 156
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
know how or what the process I did --
No, alll right --
So if nothing needed changing and I still -- that didn't
affect my opinion on the calls, I wasn't going to change
the statement.
No indeed. You told us that there was no relationship
between the fact that the SSC were protected from giving
evidence by Mik Peach and the fact that you routinely
provided witness statements based on what they told you
without revealing that they had told you what you were
saying. You said there was no relationship between
those two things earlier on, didn't you?
Did I? Yeah. I --
On the one hand, Mik Peach is over here protecting his
team, saying they're not to give any witness statements,
and, on the other hand, there's you providing witness
statements which say things that the SSC have told you
without revealing that the SSC have told you that; you
remember, you told us there was no relationship between
those two things?
Yes.
We can see the relationship in action here, can't we,
Mr Dunks? Let's go back to Mrs Chambers’ email, and
that first paragraph:
"Gareth, sending just to you initially.
157
Mr Peach that is, "Actually, you know what, Mrs Chambers
would be better placed to look into these technical
matters that she says need to be investigated.
Mrs Chambers ought to look into them and she ought to
provide a witness statement". You didn't say that, did
you?
No, I didn't. No.
You were covering for SSC because they were not prepared
to stand up and defend Horizon in court, weren't you?
No. That's not how it worked, I'm sorry. It wasn't.
Just some further questions on a different topic,
Mr Dunks. You remember in the Bates litigation, when
the boilerplate wording in your statement was put to
you, you originally claimed that you were not following
the Fujitsu "party line". Do you remember that ~
Yes, I do.
- that questioning? Later you did admit, of course,
that there was a template that you all used with the
boilerplates in it and that was something that you only
admitted when the statement from Mr Jenkins which was
identical to yours was put to you, yes; do you remember
that?
What's the word -- did you say boilerplates?
Yes, that's a word that's often used when speaking of
legal wording that's been put into cover off all
159
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
"I know you have even more on your plate than I do,
but my involvement has always been unofficial and on the
basis that I had time to do it."
Then at the very ending, she says:
"[If I am to do anything] it will have to be
officially agreed with my manager -- you can instigate
that, if you like, but I don't think I can keep
volunteering.”
That was apparently accepted by you and your team
member, Penny Thomas. You didn't press her, did you, to
give an official witness statement. You didn't press
her. You allowed her to just keep volunteering in this
unofficial way, didn't you?
Well, volunteering, yes. The same as I would speak to
anybody within the SSC or anybody who was supplying me
with information for me to do my role.
In effect, you were covering for Mrs Chambers, weren't
you?
Sorry, no. Covering for her? Covering for what?
Covering with the fact that she did not want to give
evidence, she did not want to stand up and defend
Horizon in court but you were perfectly happy to?
I wouldn't say that was covering. I was happy with the
role that I was tasked to and asked to do.
Neither you nor Ms Thomas thought to say to him —
158
eventualities; standard wording, if you like.
Is it? I've never heard of it before.
Well, it was put to you in the Bates litigation but
never mind. We don't need to worry about that. You
finally admitted that there was a Fujitsu party line,
didn't you?
Ive finally admitted -- yes, I've gone over that and
I misinterpreted what he meant by a party line. I had
an understanding of what I thought he meant by a party
line.
Yes. Well, now, of course, you are clinging to the fact
that there was a party line because what you're really
saying is, "It's not my fault that the party line was
misleading. It's not my fault I took the party line.
I was just following orders. That's what I was told to
put in witness statements and that's what I did". Yes?
That's my understanding when I first answered that
question, when I said no because that wasn't the case.
I see. So you're now saying, are you, that your process
driven witness statements which were misleading were
entirely your own work?
No, what I was saying was, when he first asked me the
question I was following the party line, I understood
that to be that -- what you just said: that we were to
all told to stick by a story and follow the party line,
160
(40) Pages 157 - 160
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
18
19
20
22
23
25
The Post Office Horizon IT Inquiry
and don't waiver from it, and we've been told what say.
That's what I, in my understanding at the time, was
answering and the answer was no. Later on in the
questioning, he mentioned or stated that, following the
party line was the use of templates. So I agreed, well,
if that was his understanding, yes, I agree with them:
we did use templates.
I wasn't trying to cover or hide anything. I just
was answering the question how I understood it.
Q. Well, you haven't been prepared to reveal who drafted
those templates, who was in charge of what was used from
those templates, how it came about that you used this
bit or that bit and so did Mr Jenkins.
A. Sorry, I don't understand that.
Q. Well, you haven't revealed anything to do with how those
templates were actually used and who was in charge of
them, have you?
‘A. How they were used? They were used by -- what do you
mean how they were used? They were used by us.
Q. Who drafted them?
Someone within Fujitsu.
Q. Someone. Well, let's look at some of the standard
paragraphs and just identify this: when Mr Jenkins was
recently asked about the standard paragraphs from the
templates and Mr Beer asked him about this paragraph,
161
>
Q. Who instigated that change?
A. I've no recollection of who instigated that change.
I can't remember.
SIR WYN WILLIAMS: Well, did you?
MS PAGE: I'm so sorry?
SIR WYN WILLIAMS: I said: did you, Mr Dunks? In other
words did you quite deliberately, on some occasions, use
the words "the computer" and on other times "the
system", or was there a different template which you
used from time to time?
A. No, I don't believe there was a different template.
I don't remember why --
‘SIR WYN WILLIAMS: I If there wasn't a different template, you
personally must have decided to substitute "the system"
for "the computer" on occasions; so I think what Ms Page
wants to know is why you did that?
A. That may have been on the request of the -- someone
within the Post Office or one of their lawyers.
I don't -- every time there was a change within
a witness statement, it was spoken about and discussed,
and then agreed on the wording. So there were many
changes. The witness statement evolved through the
years, and changes. How that was changed and the
process, and when things were changed and things taken
out, I can't remember that process and who instigated
163
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
16 July 2024
which you will no doubt recognise:
"There is no reason to believe that the information
in this statement is inaccurate, because of the improper
use of the computer. To the best of my knowledge and
belief at all material times the computer was operating
properly or, if not, any respect in which it was not
operating properly or was out of operation was not such
as to affect the information held on it."
Now, you know that wording, don't you? You use it
yourself or have used it many times?
A. Yes.
Q. But you've also used that exact same wording replacing
the words "the computer" with "the system". That also
is something you have said in many, many witness
statements.
A. Okay.
Q. What was the difference between "the computer" and "the
system"?
A. I'm not sure there -- what the difference was. It was
still trying to convey the same opinion.
Q. Whatis that opinion, then, Mr Dunks?
A. What the statement says. I don't remember why those two
words were changed, or
Q. Who instigated that change?
A. Pardon?
162
what changes.
SIR WYN WILLIAMS: So you have no recollection of any kind
as to any conversation between you and anyone which
resulted in the phrase "the computer" being changed to
the phrase "the system"; is that your evidence?
A. No, no. Even now, I would regard that meaning the
same -- trying to convey the same thing. I don't know
why those two words were changed.
SIR WYN WILLIAMS: So there's your answer, Ms Page. The
computer and the system are the same thing.
MS PAGE: Well, I wonder if I might just ask a little more
‘on that, just by putting to you what Mr Jenkins said he
thought "the computer" meant.
He said that he thought "the computer" meant the
computer that he was typing his witness statement on.
That his desktop computer that he was typing it on was
working properly. Does that make any sense to you,
Mr Dunks?
A. I don't know how or why -- how he came to that
conclusion, I don't know. No.
Q. Do you know how or why it was that he came to have that
wording at all?
In what -- sorry, in what --
How would he have come to have the template wording that
oP
your team used?
164
(41) Pages 161 - 164
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
The Post Office Horizon IT Inquiry
A. Because -- actually, I'm not sure I ever saw any of
Gareth's witness statements. I'm assuming that they
were being -- used the same sort of templates to start
off with, the witness statement templates.
Q. Was that dealt with at a level above you, Mr Dunks? Was
someone in charge of the template and how it was used?
A. If someone had -- if you're saying someone had -- if
some had more authority to me, and about those things,
yeah, I believe so, yes.
Q. Who? (Pause)
Is your loyalty getting in the way here, Mr Dunks?
A. My loyalty?
Q. Is that why you're being so cagey about who was in
charge of the standard wording in the witness
statements?
A. No, because I don't know who wrote the witness
statement. I don't know who drafted the original
witness statement.
You don't know who changed the wording --
Um --
-- from one thing to another?
Well, that would have been -- I mean, someone like --
rPOPrSO
through discussions within the Post Office. I mean,
I know that the wording at times of the ARQ witness
statements were changed, because -- and that would have
165
anyone ever tell you that it would be better not to make
sure anyone knew what "KEL" stood for?
A. Notatall. I was never told -- I honestly believed
that I -- I was never told, “Don't put this in, you
mustn't say that", and that's going back to you --
people implying that we were following a party line.
I was never under pressure to put in something that
I didn't want to put in.
MS PAGE: Thank you, sir. Those are my questions.
SIR WYN WILLIAMS: = Thank you, Ms Page.
Mr Stein?
Questioned by MR STEIN
MR STEIN: Mr Dunks, I've got two areas to ask you questions
about. I ask questions on behalf of a firm called
Howe+Co, who have instructed me on behalf of a large
number of subpostmasters. One of our clients with
an eye for detail wants to see if you can help regarding
the development of Horizon Online and its operating
system. Okay?
So this goes back to around what, 2010, and the
evidence that the Inquiry has is that whilst that was
under development, that the new operating system -- or,
sorry, the new Horizon Online system -- was using
Microsoft NT 4.0 operating system, and the reason why
was that it was regarded as being too expensive to
167
ONOaARWN
©
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
©NOORON
©
"1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
16 July 2024
been -- I'd have been involved -- I say involved,
sorry -- I'd have been informed by someone like Penny
because she ran -- she was managing the litigation so we
were told that if there were any changes, we were then
being told to use the new format.
Who chose the templates for you, Mr Dunks?
Who chose the templates? We were told which templates
to use.
By who?
Management or the -- yeah, management. Either our line
manager or the Litigation Support Manager.
Going back to your loyalty, Mr Dunks, was it your
loyalty that led you not to reveal the existence or the
content of the Known Error Logs in your witness
statements?
No, not at all, no, because I -- every witness statement
that I supplied, I was aware that, if needed -- and
which we did on many occasion -- supplied all the call
data to be seen and -- so they could see within, if they
investigated or looked at -- anybody who looked at that
would see that there were KELs and they would have been
able to request or -- that information as well. At no
time was I hiding anything because I knew that
information was available.
Did anyone ever tell you not to refer to the KELs? Did
166
upgrade to a more current technology. So our question
is this: can you help us with when Horizon Online was
updated to a newer version of an operating system?
No, I can't remember the dates when we moved from one to
another. No, I don't. I can't recall.
Was it ever updated?
Well, Horizon was updated to Horizon Online, yes.
Yes, but the operating system, being Microsoft NT 4.0,
did it move on from that point?
Oh, right. Do you know, I can't remember. I can't
remember. I believe it was changed when the new
counters were run out for HNG-X, I think, but I can't be
certain. I wasn't involved in the rollouts or updates
and things like that.
All right. If you're right about it being changed
around the time of the new counters, roughly when would
that be? So if we refer back to 2010, into the new
Horizon Online system --
No, I'm sorry. The dates of all the updates I don't
recall, sorry.
The second point is this: we know that the Post Office
is hoping to move on from the Horizon system by April
2025, and moving on from, therefore, and away from the
Horizon system. We're told by press releases from the
Post Office that the new system is going to be called
168
(42) Pages 165 - 168
ONOaARWN
1
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A
The Post Office Horizon IT Inquiry 16 July 2024
"New Branch IT". Now, you still work for Fujitsu. You
work within the Customer Service Post Office Account
Security team. Can you help us with how that's going?
Is the suggestion to move on from the Horizon system and
finish, therefore, the contractual relationship with
Fujitsu going to make it by April '25?
I'm sorry, you're asking the wrong person. I have no
idea of that level of information.
None at all? You've not been given any updates to say
that the Post Office Account is going to finish at any
time this year or it's coming to an end and there may
therefore be a change in your workplace?
I don't recall that I've seen that because -- all I know
is that the dates for the end of the contract have moved
from the original date and has been pushed back.
I don't know --
It keeps on moving and more money keeps on being paid.
We're just trying to work out when the Horizon system is
coming to an end.
As I said, you're asking the wrong person. I can't
answer that. I've got no idea.
MR STEIN: All right. Thank you, Mr Dunks.
‘SIR WYN WILLIAMS: I Is that it, Mr Beer?
MRBEER: Yes, itis. Thank you, sir.
SIR WYN WILLIAMS: Well, thank you, Mr Dunks, for making
169
INDEX
ANDREW PAUL DUNKS (re-sworn) ..
Questioned by MR BEER ...
Questioned by MS PAGE ... 145
Questioned by MR STEIN .. 167
171
a second witness statement and for giving evidence
during the course of the day. I'm grateful to you for
doing that.
So I understand, Mr Beer, that we're going to start
a little later tomorrow, at 10.05, with Mr McCall; is
that correct?
MR BEER: That's right, sir, to allow the fire alarm to
‘occur, in particular.
SIR WYN WILLIAMS: Fine. All right, then. 10.05 tomorrow.
MR BEER: Thank you, sir.
(4.04 pm)
(The hearing adjourned until 10.05 am the following day)
170
(43) Pages 169 - 171
MR BEER: [25] 1/3
1/5 1/12 1/16 3/3
51/14 51/18 51/22
51/24 83/20 84/8
84/10 84/14 84/16
108/5 108/10 108/14
108/16 144/14 144/23}
145/3 145/6 169/24
170/7 170/10
MR STEIN: [2]
167/13 169/22
MS PAGE: [4]
145/12 163/5 164/11
167/9
SIR WYN WILLIAMS:
[29] 1/4 1/10 1/13
1/20 2/19 3/1 51/17
51/23 83/23 84/2 84/4
84/6 84/9 84/15 108/9
108/15 144/21 144/24I
145/5 145/10 163/4
163/6 163/13 164/2
164/9 167/10 169/23
169/25 170/9
THE WITNESS: [2]
2/18 2/25
"05 [1] 85/23
"06 [1] 133/16
"07 [2] 41/8 127/10
"08 [3] 41/9 85/24
133/16
"25 [1] 169/6
‘All [2] 60/4 60/12
"An [4] 117/3
‘critical [2] 73/19
73/19
‘critical’ [1] 118/13
“full [2] 41/11 41/13
‘further [1] 76/5
"Horizon [1] 38/15
"In [2] 38/20 47/3
‘incident’ [1] 47/3
"major [1] 38/11
‘no [1] 67/17
"port [1] 85/14
‘Requests [1] 47/2
system’ [4] 97/24
98/7 98/17 99/4
‘the [2] 47/5 101/8
"There [3] 97/15
97/21 98/11
‘this [4] 97/17
‘unused [1] 17/4
"urgent [1] 38/12
[2] 97/16 98/12
0
008 [3] 73/18 117/2
118/12
01 [3] 68/18 83/2
83/14
01.15 [4] 125/5
01/09/05 [1] 68/15
0123 [1] 103/5
05 [1] 68/15
06 [1] 68/15
1
1 January [2] 23/8
82/21
4 May [1] 122/7
1 to [1] 77/21
1,500 [1] 141/10
1,800 [1] 79/17
4.00 [1] 141/15
1.19 [1] 108/11
10 [4] 28/4 117/13
117/13 122/9
10 August [1] 38/7
10 November [1]
114/9
10.05 [2] 170/5 170/9
10.05 am [1] 170/12
10.23 [4] 126/21
10.45 [1] 139/23
100 [4] 29/18 81/5
81/21 96/1
100 per [1] 150/10
1010 [1] 155/1
107 [10] 76/1 76/10
76/13 76/20 77/16
78/4 79/7 83/17 84/20
85/25
11 [2] 28/4 117/14
11.07 [1] 131/12
11.13 [1] 51/19
11.25 [2] 51/15 51/21
1106 [2] 100/17
101/4
115 [1] 57/24
12 [2] 63/5 117/18
12 November [1]
36/22
12.24 [1] 84/11
12.25 [1] 84/7
12.35 [4] 83/22 84/8
84/9 84/13
12.44 [1] 131/12
120 [1] 23/8
13 [4] 73/15 73/16
117/19 118/10
13 January [1] 100/3
13,000-odd [1] 79/16
14 [4] 117/20
14 January [3] 85/23
101/1 101/2
15 [2] 117/21 145/7
152 [1] 114/10
16 [2] 31/21 117/22
16 July 2024 [4] 1/4
16 March [2] 82/18
83/5
167 [1] 4/23
47 [2] 18/14 117/23
17 August [1] 28/22
48 [2] 52/3 117/24
18 February [1]
141/12
183 [1] 99/23
189 [1] 99/23
19 [3] 46/14 46/14
117/25
192 [1] 70/12
196 [1] 60/2
4st [1] 100/13
2
2.10 [2] 108/8 108/13
20 [4] 25/14 25/16
118/1 118/1
20 December [1]
40/5
20 February [1]
138/5
20 March [1] 97/3
20 minutes [1] 145/7
200 [2] 141/11
141/15
2002 [6] 89/8 89/9
89/12 89/16 90/3
124/2
2004 [3] 27/24 28/22
101/7
2005 [11] 6/20 7/21
8/21 9/12 27/24 28/23
38/9 82/22 90/4 90/6
114/9
2006 [7] 5/1 5/2 5/5
38/7 38/7 66/12 138/8
2007 [5] 47/1 100/3
101/1 101/2 127/4
2008 [4] 108/23
113/22 126/9 127/1
2009 [10] 36/2 75/3
75/10 75/12 80/23
82/22 84/18 84/25
85/6 85/7
2010 [11] 36/22
81/10 82/25 130/25
130/25 132/9 132/11
142/20 150/21 167/20
168/17
2011 [1] 37/1
2019 [2] 97/3 98/18
2021 [1] 36/14
2023 [2] 3/6 40/5
2024 [3] 1/1 3/10
5/24
2025 [1] 168/23
204 [1] 135/6
21 [2] 36/25 91/16
21 April [1] 101/7
22 [3] 10/6 15/18
138/3
22 June [1] 75/10
22 March [1] 27/24
22nd [1] 75/20
23 [2] 3/15 3/17
23 February [1]
140/19
24 [1] 28/4
24 July [1] 127/4
24 June [1] 85/5
24 May [2] 3/10 5/23
25 [1] 16/19
25 February [1]
133/1
25 January [1]
132/24
250 [4] 10/11
26 [1] 141/7
26 November [1]
90/3
27 [1] 91/8
27 September [1]
66/12
28 [3] 97/4 97/4 97/5
29 [2] 14/1 142/23
29 February [2] 6/20
90/6
29 February 2005 [1]
90/4
29 January [5] 81/10
132/9 132/11 142/20
150/21
29 July [1] 36/2
29 November [1]
38/7
29/11/06 [1] 68/15
2nd [3] 101/11
140/22 143/5
3
3 June [7] 108/23
113/24 126/9 126/21
127/6 127/15 130/20
3 March [1] 143/2
3,500 [1] 37/2
3-4 [2] 76/21 78/7
3.13 [1] 144/25
3.25 [2] 144/23 145/2
3.40 [1] 140/6
30 June [5] 75/12
79/9 84/25 85/7 85/23
30 March [1] 82/25
30 years [1] 145/19
31 [2] 92/7 92/8
31 December [1]
82/22
32 [4] 91/12
33 [12] 36/18 69/2
69/13 72/15 73/1
94/20 94/21 109/10
113/9 129/2 131/5
131/20
33 calls [1] 130/1
34 [1] 37/3
35 [4] 37/14
38 [1] 57/24
3J [3] 104/4 104/21
104/23
4
4.0 [2] 167/24 168/8
4.04 [1] 170/11
41 [1] 97/9
42 [2] 42/23 43/4
48 [1] 31/21
5
5 August [1] 37/1
5 January [1] 117/2
5 June [2] 113/22
131/2
52 [1] 4/23
53 [1] 18/15
56 [1] 99/23
57 [2] 52/3 70/12
59 [1] 60/2
6
6 May [3] 130/25
131/2 131/3
6,000 [4] 138/10
139/25 141/16 144/11
6.00 [1] 123/3
60 [1] 46/15
61 [1] 135/6
630 [1] 79/18
69 [1] 5/8
69 pages [1] 3/10
7 August [1] 47/1
7 October [1] 36/14
7.1 [1] 10/19
7.2.4 [2] 10/8 11/7
7.2.4.1 [2] 10/24
91/16
72,000 [1] 37/5
77 [A] 3/20
8
8 March [1] 3/6
8.2 [1] 16/20
89 [1] 29/17
9
9 March [1] 28/22
9.29 [1] 126/11
9.45 [1] 1/2
900 [1] 141/13
96 [2] 94/21 94/21
97 [2] 95/2 95/8
970 [2] 73/17 118/12
98 [3] 28/21 28/24
95/16
92Z [2] 104/5 106/8
A
AA [4] 141/16
ability [2] 35/3 35/22
able [16] 9/4 27/1
39/7 50/19 53/11
(44) MR BEER: - able
A
able... [11] 105/6
107/4 107/16 111/24
114/25 130/21 133/9
134/17 143/11 154/1
166/22
about [95] 2/22 5/22
16/7 16/17 17/2 21/13
21/15 21/20 22/1 22/1
22/15 22/17 22/23
24/21 26/4 29/18
29/18 29/22 32/22
33/9 33/24 34/9 35/5
37/12 37/17 38/11
39/6 39/9 39/23 42/5
42/7 44/12 44/19
44/23 45/22 49/11
51/14 52/14 55/24
56/17 57/14 58/13
60/8 61/13 63/15
63/25 64/1 64/6 67/11
69/8 77/15 77/16
77/24 81/25 84/17
87/17 91/25 93/6 99/2
100/4 106/22 108/25
109/20 111/22 112/10)
113/3 114/8 119/13
121/2 121/8 121/10
121/13 121/21 128/19)
133/3 142/13 144/9
144/13 145/7 145/8
147/25 148/3 148/7
148/10 155/4 156/13
160/4 161/12 161/24
161/25 163/20 165/8
165/13 167/14 168/15)
above [11] 10/4 14/7
14/16 67/16 74/7 76/9
88/6 142/5 149/23
149/25 165/5
absolute [1] 146/7
absolutely [5] 67/4
80/18 82/9 126/5
152/4
abstract [2] 6/21
90/10
accept [3] 151/5
152/8 152/22
acceptable [3] 46/7
50/6 108/7
accepted [2] 50/19
158/9
accepting [1] 117/21
accepts [3] 38/13
39/16 39/19
access [10] 9/4 9/4
25/25 57/7 62/8 62/11
62/14 109/21 115/21
136/11
accessed [1] 23/17
accompany [1] 15/8
accord [1] 15/25
according [1] 33/14
accordingly [2]
34/25 35/2
accords [1] 10/19
account [16] 5/11
5/19 17/7 18/4 40/8
41/20 44/3 44/5 53/14
89/12 89/13 112/4
114/12 114/17 169/2
169/10
Account's [1] 6/4
accountant's [1]
38/18
accounted [1] 142/1
accounting [2] 36/24
88/9
accuracy [1] 142/10
accurate [1] 154/22
accurately [1] 26/6
acknowledges [1]
123/23
acknowledging [1]
747
acronyms [2] 100/9
100/12
across [2] 52/8 58/8
act [1] 121/16
action [4] 73/21 74/1
118/17 157/22
actioning [1] 10/13
actions [1] 21/24
actually [16] 14/2
19/3 21/9 42/21 43/17)
54/24 55/15 65/8 66/2
92/5 93/5 149/22
154/4 159/1 161/16
165/1
AD [2] 83/2 83/14
AD/01 [2] 83/2 83/14
AD1 [1] 23/10
add [10] 4/10 23/22
74/4 77/20 78/6 78/19)
79/1 110/25 125/18
137/15
added [4] 126/18
127/19 130/10 133/14)
adding [1] 128/9
addition [3] 18/18
78/18 130/12
additional [6] 10/15
17/2 17/9 85/6 129/1
129/10
Additionally [1]
67/21
address [5] 5/17
13/24 102/7 110/16
110/18
addressed [4] 5/20
12/13 12/24 56/4
adds [2] 127/16
127/22
adjourned [2] 40/18
170/12
adjournment [2]
40/24 108/12
administrative [1]
26/11
admit [1] 159/17
admitted [3] 159/20
160/5 160/7
advice [14] 24/21
24/22 56/18 57/7
57/13 57/17 62/21
68/12 102/15 102/20
109/3 139/20 139/21
143/8
advise [1] 101/16
advised [12] 16/11
117/16 119/23 123/6
139/3 139/4 140/1
140/4 140/17 140/17
140/22 143/4
affect [18] 69/6 86/4
86/6 94/3 107/16
107/18 109/13 113/12]
114/2 114/22 127/17
128/10 135/18 135/20
136/2 143/12 157/4
162/8
affected [7] 58/2
73/12 79/21 80/16
96/5 106/3 123/14
afflicted [2] 33/8
33/12
afflictions [1] 33/16
afforded [1] 39/9
affront [1] 39/20
afraid [1] 15/17
after [14] 2/11 8/1
43/3 46/23 62/15 79/8
83/17 122/7 123/10
132/17 132/25 133/1
137/13 137/14
afternoon [4] 84/14
108/14 108/16 145/3
again [41] 9/12 20/24
26/21 30/8 30/15
30/15 31/4 31/5 41/9
43/11 46/24 62/10
62/20 67/11 70/21
78/9 81/13 87/2 87/15
90/10 91/5 91/12 94/8
94/15 97/12 104/15
107/6 107/20 111/21
119/1 129/6 129/16
131/1 131/11 135/13
135/21 139/23 140/11
143/14 147/15 156/1
against [8] 2/1 41/6
66/12 134/19 135/1
146/1 148/4 155/15
ago [2] 41/7 135/13
agree [19] 9/14 11/16
12/19 12/22 15/21
16/2 26/10 43/13
44/10 54/23 55/2 61/9
67/1 74/12 74/16 96/6
116/8 150/5 161/6
agreed [10] 16/10
55/21 78/20 110/13
113/6 128/25 133/10
158/6 161/5 163/21
agreement [2] 16/13
80/1
aid [2] 74/7 118/22
Alan [3] 8/7 8/12 8/16
alarm [1] 170/7
albeit [1] 98/4
alert [1] 2/6
alerted [1] 44/11
all [97] 2/24 9/18
13/16 20/20 24/8
24/15 30/5 34/12
36/18 39/21 42/7
42/21 50/1 50/4 53/4
59/12 59/16 59/21
60/7 63/6 63/18 63/24,
64/7 67/6 69/4 70/4
70/5 70/24 71/1 71/14
72/15 82/6 82/6 83/2
84/6 85/8 86/2 88/18
92/14 92/24 96/3
99/10 100/7 105/3
105/6 105/9 106/23
109/11 110/12 110/14}
110/15 113/10 115/6
125/20 125/24 127/12}
132/14 141/4 142/8
142/18 144/21 145/10}
146/9 147/6 148/24
148/25 149/7 150/12
150/22 150/25 151/4
152/1 152/19 153/6
153/8 153/13 154/17
155/17 155/21 156/13}
156/15 156/20 157/2
159/18 159/25 160/25]
162/5 164/22 166/16
166/18 167/3 168/15
168/19 169/9 169/13
169/22 170/9
Allan [1] 40/23
allege [1] 39/3
allegedly [1] 38/22
Allen [9] 36/1 39/24
39/25 40/15 67/10
69/10 126/11 127/5
127/21
allow [1] 170/7
allowed [4] 49/14
88/8 122/18 158/12
almost [1] 145/19
along [6] 8/1 21/4
42/12 49/7 49/8 149/5)
alongside [5] 127/1
151/3 151/12 151/23
152/18
already [7] 98/4
108/19 122/19 128/6
128/20 153/5 156/3
also [10] 26/12 39/5
ATIN7 71/24 74/2
100/9 122/16 141/15
162/12 162/13
alter [1] 137/18
Although [1] 39/5
always [15] 16/5 30/1
30/20 53/20 61/10
64/25 71/3 89/19
107/13 112/3 115/7
115/11 133/6 140/15
158/2
am [9] 1/2 23/7 51/19
51/21 98/23 99/18
113/17 158/5 170/12
Ambrose [1] 36/15
amend [2] 5/2 9/24
amendments [2]
100/7 100/22
Americanised [2]
126/21 131/2
amongst [1] 74/22
amount [5] 39/2 39/4
39/9 78/8 80/8
analyse [3] 22/13
40/19 41/19
analysed [1] 41/7
analysing [1] 52/6
analysis [16] 12/4
17/13 23/23 24/1 38/2I
38/3 41/21 44/4 47/12I
47/18 48/8 48/23 49/5)
52/1 132/2 133/8
Analyst [1] 5/25
Analysts [1] 18/16
ANDREW [6] 1/14
3/5 23/7 23/17 66/15
17112
Andy [9] 1/12 41/5
67/13 75/23 76/8
82/20 100/6 134/19
147/7
Anne [16] 46/17
46/18 132/18 134/14
136/1 137/10 140/24
141/20 142/16 149/17)
152/3 152/11 153/2
153/9 155/6 155/7
Anne's [2] 134/25
155/15
Annetee [1] 142/25
annexed [1] 91/7
annum [1] 10/12
another [15] 23/16
23/19 23/22 40/17
40/24 41/10 67/15
82/11 88/22 102/20
112/18 122/19 126/12)
165/21 168/5
answer [13] 1/21
1/24 2/9 2/9 50/8 55/8}
55/16 55/17 55/19
103/9 161/3 164/9
169/21
answered [1] 160/17
answering [3] 2/13
161/3 161/9
(45) able... - answering
A
answers [5] 81/1
81/14 81/17 81/23
81/25
anxious [1] 43/15
any [99] 1/22 2/5 2/7
2/7 2/21 4/8 4/19
10/25 13/3 13/16 18/2
20/6 21/11 21/14
22/23 23/2 24/5 24/8
24/16 26/3 32/13
32/14 33/15 33/23
34/10 34/13 36/9
38/25 46/24 48/6 49/8
49/8 49/9 50/2 51/9
57/3 57/14 57/16 58/6
59/5 64/9 66/8 66/9
67/5 67/17 68/2 69/7
72/10 72/18 72/20
73/1 74/2 86/10 87/7
92/15 96/4 96/5
100/12 102/4 102/17
102/25 103/18 103/18
107/23 107/25 109/14}
109/22 113/12 114/22)
116/4 119/3 119/6
120/20 121/13 125/23
127/18 127/23 128/3
128/10 128/13 128/24}
129/3 130/5 132/2
137/14 137/22 146/5
148/15 153/18 154/23)
157/15 162/6 164/2
164/3 164/17 165/1
166/4 169/9 169/10
any investigation [1]
49/8
anybody [6] 57/20
58/22 58/23 158/15
158/15 166/20
anyone [17] 6/11
17/6 18/4 46/6 50/6
50/15 56/18 72/20
73/1 121/2 121/16
134/2 134/18 164/3
166/25 167/1 167/2
anything [24] 17/19
18/1 21/20 35/7 35/17
35/20 58/7 103/22
107/5 112/10 120/5
120/12 135/10 135/12)
136/18 137/10 139/16
145/20 154/20 156/13}
158/5 161/8 161/15
166/23
Anyway [1] 40/15
apart [1] 106/24
APD [1] 68/18
APD/01 [1] 68/18
APD1 [1] 66/15
apologise [1] 131/6
apparent [2] 37/19
37/21
apparently [4] 9/16
33/8 150/17 158/9
Appeal [2] 36/13
36/20
appear [9] 67/18 81/7I
100/13 102/10 123/9
126/20 133/25 140/23)
143/6
appearing [3] 33/10
34/1 34/10
appears [15] 4/25
9/17 13/17 27/19
28/14 28/21 39/7
39/12 86/12 93/7
100/15 103/2 113/20
113/23 132/1
appended [1] 95/4
Appendix [9] 11/15
14/6 14/6 91/7 91/8
91/9 91/24 92/2 92/3
Appendix 2 [2] 91/8
91/9
applied [3] 16/16
124/8 124/22
appreciate [1] 88/10
approach [8] 31/15
52/13 52/18 60/1
64/23 70/21 86/13
86/17
appropriate [6] 2/24
15/8 48/24 83/21
105/22 108/6
approval [3] 50/24
51/3 90/19
approve [2] 20/6 51/2!
approved [2] 17/7
20/9
approximate [1]
79/15
approximately [1]
76/21
April [4] 27/24 101/7
168/22 169/6
are [83] 2/7 2/15 3/11
5/11 9/18 11/11 12/23)
13/13 13/18 17/16
20/11 20/12 23/12
41/18 41/20 42/8
43/25 49/23 51/1
60/12 63/24 64/8
66/22 69/4 72/16
74/22 78/24 81/5
81/21 81/25 86/2
88/18 91/20 93/5 93/5)
96/21 100/10 104/2
104/18 105/12 106/20)
106/24 109/11 112/10)
113/5 113/9 113/10
115/25 116/1 116/22
119/15 122/11 123/3
123/5 123/7 123/18
124/19 129/11 130/18)
133/13 133/24 134/17)
136/4 136/4 138/2
141/22 142/4 142/8
143/18 144/17 144/18}
145/6 147/12 147/16
149/24 150/23 152/2
153/20 156/5 160/11
160/19 164/10 167/9
area [6] 53/8 74/5
74/18 109/23 109/24
118/20
areas [3] 43/20 43/25
167/13
aren't [3] 51/8 104/2
104/5
arena [2] 21/1 111/15
arises [1] 2/20
arising [1] 121/10
around [6] 8/14
128/23 130/22 135/21
167/20 168/16
ARQ [31] 3/23 4/6
4/17 8/1 10/18 11/5
12/4 12/4 15/8 19/5
21/16 24/25 29/3
29/23 31/24 32/7 33/2
33/25 35/6 38/6 80/1
93/6 93/7 94/24
110/17 110/22 153/22)
154/3 154/10 156/6
165/24
ARQs [9] 10/11 11/25
12/12 16/16 30/16
34/3 79/16 80/2 93/13
arrange [1] 79/19
arranged [1] 38/1
as [197]
ascertain [1] 39/1
aside [1] 100/14
ask [16] 1/5 1/17
1/17 2/8 65/11 65/12
84/23 87/8 94/8 121/2
144/17 145/12 149/14
164/11 167/13 167/14)
asked [37] 4/25
19/25 29/8 31/1 42/16
48/15 49/10 57/14
68/11 68/21 69/10
72/2 78/14 80/14 81/2
81/18 84/17 84/21
85/17 85/20 94/17
98/3 98/3 98/6 103/7
107/7 109/2 113/16
127/21 130/7 131/23
137/22 137/24 158/24)
160/22 161/24 161/25)
asking [14] 49/4 59/6
61/18 71/18 81/22
101/21 102/6 110/13
126/16 132/15 137/8
154/12 169/7 169/20
asks [1] 126/12
aspect [2] 60/1 80/13
aspects [1] 109/23
assessment [1] 94/4
assigned [2] 18/18
58/4
assist [2] 2/20
104/11
assistance [1] 48/15
assisted [1] 18/16
associated [1]
133/25
assume [3] 41/21
61/21 139/2
assumed [1] 119/17
assuming [5] 61/19
61/22 83/6 83/15
165/2
assumption [8] 61/9
61/12 94/15 115/13
115/15 116/9 116/12
116/22
assurance [2] 8/12
58/25
assurances [1] 59/7
assured [2] 20/21
64/3
asterisk [1] 101/5
asterisked [1] 91/2
at [280]
at page 2 [1] 72/12
attached [1] 75/15
attaching [3] 68/4
132/10 132/13
attachment [2] 67/10
68/8
attempting [1] 117/4
attention [5] 73/21
73/22 73/23 73/24
118/14
attributed [1] 45/11
audit [15] 8/13 8/16
11/4 12/5 12/7 37/4
95/18 95/24 96/18
97/25 98/21 99/3 99/5)
99/15 128/5
August [5] 5/1 28/22
37/1 38/7 47/1
authorities [1] 90/19
authority [1] 165/8
automated [1] 125/8
automatic [3] 101/10
4117/7 118/4
available [9] 9/7 29/7
43/4 66/8 67/6 83/10
103/22 120/5 166/24
Avenue [11] 36/2
36/5 67/12 68/16
68/20 72/15 84/3
109/3 109/5 129/2
131/1
average [1] 86/1
aware [30] 10/2
13/25 14/20 17/14
17/19 18/1 18/10 24/8
30/6 42/15 50/18
50/22 50/25 51/4
54/18 54/22 56/10
56/11 57/1 57/8 57/9
57/10 57/11 57/20
72/5 95/20 115/1
121/14 121/15 166/17)
away [5] 36/11 147/5
147/17 148/16 168/23}
back [51] 7/16 8/21
8/21 9/1 9/13 12/16
15/18 38/9 39/23 40/4)
40/17 41/2 41/7 41/9
41/24 43/6 43/10
46/13 53/16 62/1
63/14 71/23 72/3
72/11 77/17 81/15
85/9 91/15 92/7
102/11 102/12 109/15)
113/7 115/12 116/21
116/23 119/1 119/8
119/16 130/15 131/16)
141/15 142/2 143/8
144/7 157/23 166/12
167/5 167/20 168/17
169/15
background [1] 5/17
backing [1] 149/11
bad [3] 105/21
106/10 147/24
Bailey [1] 46/20
Bains [8] 31/23 32/1
32/2 32/3 32/20 33/4
33/9 43/15
balance [5] 60/17
123/8 125/16 138/11
140/1
balanced [2] 125/2
125/13
balancing [10] 119/7
119/9 119/17 122/12
122/14 123/3 123/6
123/7 125/24 139/20
balancing’ [2] 38/11
38/16
Banking [4] 6/16
6/23 89/25 90/13
Banter [2] 148/12
148/17
barcode [2] 117/19
117/20
barrister [3] 76/14
84/22 100/12
base [2] 103/4
112/21
based [21] 11/18
19/18 21/7 45/4 45/8
45/21 46/1 53/24 56/8)
57/18 64/22 74/18
80/2 83/11 89/10
94/10 113/16 113/18
135/21 137/25 157/9
basically [2] 16/18
152/15
basing [3] 16/9 65/23)
143/22
(46) answers - basing
B
basis [7] 19/10 62/3
94/16 133/7 137/16
141/2 158/3
Bates [2] 159/12
160/3
be [163] 2/14 3/16
6/2 7/17 7/19 9/10
10/12 10/17 11/1 11/5)
11/17 11/23 12/6
12/13 12/20 12/24
15/22 16/3 16/14
16/25 17/4 17/8 17/10}
17/18 18/8 18/22
20/13 21/22 23/14
23/16 23/19 23/22
25/19 25/20 26/1
26/18 26/22 27/1
27/19 28/17 29/11
29/14 30/18 31/12
32/13 33/13 34/6
34/19 36/10 41/17
42/15 42/23 42/24
43/25 44/2 44/12
44/18 47/8 50/23 51/5)
51/6 54/6 54/6 54/20
60/23 61/2 64/2 65/12
66/20 69/16 73/24
75/12 76/1 76/2 76/2
76/3 76/6 77/22 78/5
81/7 81/8 82/8 87/23
97/12 100/12 106/10
106/18 106/25 107/13
108/6 111/1 111/19
111/23 111/24 112/3
112/6 113/6 113/21
113/23 116/18 121/18}
122/24 123/9 123/10
123/20 126/7 129/12
129/14 129/14 129/17)
129/17 132/1 132/16
133/9 133/10 133/23
133/25 134/1 134/2
134/21 137/2 137/8
138/21 138/22 139/11
139/18 139/19 140/23}
141/6 141/25 143/6
143/8 143/18 146/6
146/9 146/11 146/23
146/25 150/9 151/1
151/8 151/9 152/15
153/12 153/19 154/1
155/11 155/19 155/25}
156/5 156/21 156/23
156/24 158/5 159/2
159/3 160/24 166/19
167/1 168/12 168/17
168/25 169/12
because [81] 5/4 8/8
17/24 19/12 19/23
20/24 22/24 24/14
32/16 34/4 35/17 36/8
36/19 37/20 39/2 39/4
43/11 44/25 49/14
50/20 53/18 53/25
55/5 55/15 56/2 59/3
59/11 61/22 64/18
69/23 69/25 71/15
71/16 71/25 73/4
78/14 78/18 79/1
84/22 90/7 92/12 93/2
94/14 97/22 102/2
103/12 104/18 110/6
110/25 112/18 113/2
115/1 116/6 116/18
116/23 119/15 120/7
121/10 129/15 129/18)
136/21 136/24 139/11
139/19 144/7 146/17
148/19 151/8 154/19
156/16 159/8 160/12
160/18 162/3 165/1
165/16 165/25 166/3
166/16 166/23 169/13)
become [3] 8/6 37/16
123/10
been [148] 4/5 4/16
8/3 8/4 8/15 8/20 9/7
13/8 16/10 17/24 19/2
19/8 19/10 20/3 20/3
23/12 23/21 27/23
28/5 29/10 29/20
29/21 30/9 31/9 31/10
31/11 38/2 38/23
38/24 39/1 39/12
40/18 40/23 42/16
43/5 46/21 52/6 53/11
56/11 58/6 61/4 61/16
61/21 61/23 61/24
62/1 63/13 63/14 65/9)
68/11 68/21 69/24
69/25 71/3 71/8 71/20
71/21 72/9 82/5 83/4
83/13 83/15 84/20
84/24 84/25 85/17
85/20 86/19 86/20
87/25 89/12 93/3
93/15 96/4 104/10
105/6 106/11 106/12
107/11 107/19 107/23)
109/2 111/3 113/3
114/1 115/16 115/22
116/20 116/24 119/18)
119/20 119/21 122/11
122/19 123/11 124/1
124/11 126/21 127/19)
128/4 128/16 128/17
128/24 130/7 130/19
130/21 131/1 133/6
133/21 134/10 134/23}
136/8 136/13 137/12
137/14 139/3 140/17
142/1 144/15 145/18
148/13 150/19 151/17)
151/20 152/18 153/1
153/17 154/4 154/20
154/23 155/1 155/13
155/23 156/3 156/6
156/24 158/2 159/25
161/1 161/10 163/17
165/22 166/1 166/1
166/2 166/21 169/9
169/15
BEER [8] 1/15 1/16
3/2 149/13 161/25
169/23 170/4 171/4
before [26] 1/17 2/4
3/7 28/8 29/6 29/9
36/8 36/9 37/9 38/9
52/8 54/21 56/13 58/8
61/25 83/16 83/23
107/11 112/7 123/7
128/25 130/20 145/24)
145/25 149/22 160/2
begin [2] 6/2 108/21
begins [2] 97/7 97/14
behalf [5] 1/17 46/7
145/12 167/14 167/15)
behind [2] 146/9
152/6
being [51] 24/6 32/17
32/22 35/6 43/2 44/11
50/12 50/13 50/25
51/7 52/11 53/9 54/24
55/3 58/1 58/10 60/25
62/4 63/18 64/1 64/7
86/25 90/25 91/7
93/14 94/17 97/9
97/14 98/2 99/16
104/13 113/16 119/8
121/17 124/5 125/8
134/1 138/14 138/23
141/2 142/4 146/18
154/9 164/4 165/3
165/13 166/5 167/25
168/8 168/15 169/17
belief [6] 5/13 92/14
93/22 96/12 96/21
162/5
believe [59] 6/10 8/1
8/14 9/6 15/11 15/14
16/9 19/4 21/17 23/5
26/25 27/7 32/14
43/23 47/19 47/22
49/7 51/12 59/15
64/16 75/8 77/12
78/11 78/13 79/6
79/24 80/4 84/5 87/20
88/17 89/18 92/11
93/16 93/20 94/13
96/2 97/15 97/21
98/12 98/17 110/4
111/14 115/9 120/11
120/24 121/20 121/22)
122/3 124/10 125/3
127/4 142/12 144/3
144/5 147/11 162/2
163/11 165/9 168/11
believed [10] 53/10
61/5 93/10 95/23
107/21 112/20 154/20}
154/22 156/8 167/3
below [9] 11/17
12/20 15/22 81/1
81/13 81/17 81/23
100/15 134/15
benefit [1] 109/25
best [6] 5/12 35/3
35/21 92/13 93/9
162/4
better [6] 52/10
58/10 120/25 121/6
159/2 167/1
between [23] 23/9
28/22 51/7 72/15
79/11 82/17 83/3
83/18 85/23 85/24
86/1 87/18 107/24
128/2 132/18 145/24
147/23 149/16 157/7
157/11 157/19 162/17,
164/3
beyond [1] 43/17
big [1] 64/14
Bill [1] 8/2
bit [16] 7/3 7/17
32/17 33/17 52/17
73/17 80/22 81/14
108/24 108/24 131/22}
135/23 138/4 140/11
161/13 161/13
bits [3] 34/9 35/19
87/1
blamed [2] 37/22
37/25
Bless [2] 146/10
147/6
block [2] 40/10
105/21
blurring [2] 45/23
46/4
board [1] 106/3
body [3] 14/4 14/7
91/5
boilerplate [12]
85/10 87/12 92/9
95/23 98/5 98/19
99/12 109/16 110/2
110/12 112/19 159/13}
boilerplates [2]
159/19 159/23
boss [1] 145/25
both [8] 8/8 19/8
39/19 46/19 47/10
93/7 104/14 145/13
bottom [18] 15/19
35/25 39/24 57/25
67/12 80/21 82/16
85/10 86/15 87/16
100/2 109/21 126/11
130/16 130/19 131/3
149/8 154/24
boundaries [1]
107/20
box [2] 28/14 90/21
boy [1] 145/18
branch [18] 23/9
25/23 37/4 37/6 37/10)
37/15 60/17 69/2 94/2
104/13 107/24 109/4
109/10 124/23 134/5
139/8 139/16 169/1
branches [2] 76/23
94/6
break [8] 51/15 51/20I
83/22 83/22 84/12
108/8 144/19 145/1
breakdown [3] 76/15
79/17 79/18
Brian [1] 57/5
brought [2] 3/16 5/11
Budd [8] 36/2 38/3
39/15 39/25 40/6
41/25 43/15 44/11
Budd's [1] 43/6
bug [1] 121/21
bugs [1] 25/7
built [1] 115/14
bullet [5] 11/22 11/24)
12/3 12/13 12/23
bundle [1] 151/10
burden [2] 43/21
152/23
business [13] 37/13
61/17 61/23 62/5
69/24 115/2 116/6
116/10 116/17 116/24}
138/19 139/18 145/18)
but [92] 8/23 9/7 14/3
14/22 15/24 17/15
21/16 26/12 28/11
29/22 31/6 32/9 32/22
33/17 34/18 39/11
40/8 42/3 42/11 43/15
43/25 44/17 45/11
46/20 47/17 49/5 50/3)
50/17 53/20 54/12
56/8 57/8 64/1 69/9
69/20 71/5 76/13
76/20 78/15 89/6
89/18 98/19 99/18
99/25 100/11 100/22
107/20 110/17 110/22)
111/13 112/11 113/5
115/20 120/23 124/3
125/2 125/11 125/14
127/25 128/24 129/14)
129/17 130/10 133/25]
134/10 135/15 136/25)
137/18 139/6 142/14
143/22 143/25 147/24)
149/8 149/13 150/19
152/2 154/3 154/7
154/8 154/12 155/2
155/22 156/2 156/25
158/2 158/7 158/22
160/3 162/12 168/8
168/12
buy [1] 89/4
(47) basis - buy
B
Byfleet [5] 75/16 83/3
85/23 133/3 150/23
Co
CA [1] 114/12
cagey [1] 165/13
call [145] 1/12 19/7
19/14 21/18 25/25
31/1 33/25 35/7 47/21
52/19 52/20 52/23
53/17 55/25 58/4
58/14 58/19 59/8
59/13 59/18 60/8
60/15 61/4 61/5 61/10
61/16 61/25 62/1 62/9
62/12 63/14 64/23
64/25 65/12 66/7
66/19 66/22 66/23
67/2 67/7 67/22 68/17
68/22 69/16 70/5 70/7;
70/24 72/3 72/4 72/20
75/1 76/16 76/23 77/4
79/18 81/3 81/4 81/19)
81/20 82/3 83/10
83/16 83/17 87/1
94/16 100/17 101/4
101/7 101/12 101/15
101/17 102/6 102/15
102/16 102/18 102/20}
102/24 102/25 103/1
103/2 103/5 107/9
109/25 110/18 114/9
114/9 114/11 114/14
115/2 115/12 115/25
116/11 116/20 116/23}
4117/1 117/3 117/8
118/3 118/5 119/2
119/6 119/10 119/16
120/7 120/8 120/17
121/3 121/24 123/12
123/16 123/22 124/6
124/11 124/12 124/14)
124/18 125/17 131/21
131/25 132/4 134/19
136/14 138/1 138/2
138/8 138/14 138/15
139/23 140/3 140/12
140/16 140/22 141/3
142/2 142/22 143/3
143/8 143/10 143/11
143/12 143/15 144/7
154/3 155/17 166/18
call’ [1] 85/15
Call-type [1] 79/18
called [8] 17/8 17/10
39/13 48/12 59/22
146/18 167/14 168/25
Callendar [3] 121/9
121/14 134/7
calling [2] 140/7
141/1
calls [154] 19/23
21/13 21/21 21/25
22/2 23/4 23/8 23/18
23/23 24/5 25/22 26/3
26/8 26/25 27/3 27/6
27/6 27/11 30/25 34/3
38/15 47/21 48/9 52/5)
52/15 52/25 53/4 53/5)
53/7 55/6 57/22 60/4
60/12 60/13 60/16
60/21 61/2 63/18
63/22 63/23 63/24
64/1 64/2 64/4 64/7
64/7 64/9 64/13 64/15
64/18 64/20 64/21
68/12 69/1 69/2 69/4
69/13 70/15 71/4 71/7,
72/14 72/16 72/21
73/1 73/16 73/18
74/21 75/16 76/1
76/10 76/13 76/16
76/20 76/21 77/2 77/4
77/6 77/7 77/10 7/11
77/16 78/4 78/6 78/9
78/15 78/23 79/7
79/17 82/21 83/2
84/20 85/22 85/24
85/25 86/1 86/2 86/19
93/15 93/16 100/14
104/16 109/2 109/9
109/10 109/11 113/9
113/10 114/8 115/13
115/16 118/12 119/2
119/13 124/4 125/25
127/12 128/9 128/11
129/2 129/11 129/22
130/1 130/5 130/11
131/5 131/20 131/24
132/15 133/19 135/41
136/6 136/16 136/24
137/24 142/8 143/16
143/18 143/24 150/22)
151/4 152/2 152/4
152/16 153/6 153/13
154/17 155/16 155/21
155/24 155/25 156/1
156/15 156/20 157/4
calls' [1] 47/2
came [11] 16/13 41/9
47/25 69/8 75/12
87/24 155/22 155/24
161/12 164/19 164/21
can [227]
can't [60] 8/23 9/1
19/24 21/16 28/10
29/21 30/19 31/9
35/20 40/2 42/3 44/9
44/15 50/3 51/12
53/18 54/3 57/11
69/25 73/2 73/2 73/4
73/11 74/9 74/10 79/2
79/5 89/13 89/15
89/18 89/18 99/18
105/4 111/4 120/13
124/24 125/1 125/11
129/5 129/15 135/11
135/13 135/15 135/24
136/9 136/10 148/10
155/5 155/7 155/22
156/1 157/22 163/3
163/25 168/4 168/5
168/10 168/10 168/12
169/20
capable [2] 47/11
47N7
capital [5] 13/12 14/8
14/15 14/16 91/13
cards [1] 117/21
careful [3] 37/12
44/11 44/12
carefully [1] 141/20
caring [1] 89/3
carried [18] 7/25
44/20 45/2 52/24 53/1
58/3 62/17 80/5 94/11
101/14 102/13 103/17]
123/20 125/21 130/20
137/23 156/24 156/24
carry [9] 43/20 43/24
69/12 77/19 102/2
117/12 125/15 129/1
154/1
carrying [1] 34/23
case [57] 5/25 11/12
16/7 17/24 21/23
27/22 36/8 36/11
36/15 36/19 36/20
39/17 39/18 39/22
41/6 46/23 53/20
65/16 65/17 66/23
67/11 69/12 70/4 70/6
70/11 70/14 70/19
75/4 75/25 80/20
83/23 83/25 84/1
84/19 86/22 88/8
91/22 92/21 99/21
100/5 100/23 101/3
111/19 112/2 112/23
115/22 122/21 123/3
124/8 125/23 126/4
127/4 132/6 132/8
135/9 136/20 160/18
cases [6] 17/2 24/16
30/12 66/1 66/3
108/19
cash [8] 37/20 37/21
39/2 42/22 114/12
114/17 141/12 141/14]
Castleton [5] 46/21
66/13 145/14 146/1
146/6
Castleton's [1] 70/6
categorisation [1]
62/4
categorised [2]
38/15 116/10
category [1] 69/23
cause [8] 41/12 42/2
42/8 44/22 52/21
103/18 119/25 121/18
caused [3] 121/22
129/22 142/4
caution [1] 37/7
CC [1] 141/9
CD [11] 68/18 68/21
68/23 70/7 70/24 81/5)
81/11 81/21 82/7 83/2
83/13
cent [1] 150/11
centralised [1] 9/2
Centre [3] 52/10
101/11 101/12
certain [4] 107/13
134/3 140/9 168/13
certainly [2] 42/11
108/9
cetera [5] 60/19
85/15 107/1 110/6
118/14
chain [15] 75/3 75/6
79/10 80/12 81/8
87/16 145/24 150/6
151/3 151/11 151/24
152/3 152/23 154/5
155/9
Chairman [1] 1/18
challenge [3] 17/24
38/17 59/13
challenged [2] 16/25
59/18
Chambers [17] 46/17
46/19 46/23 132/19
133/4 136/1 140/25
141/20 149/17 152/3
152/11 153/2 155/19
156/19 158/17 159/1
159/4
Chambers’ [3]
137/10 153/9 157/23
chance [1] 65/19
change [10] 32/9
123/17 151/17 154/18}
157/4 162/24 163/1
163/2 163/19 169/12
changed [12] 53/19
114/2 137/13 162/23
163/23 163/24 164/4
164/8 165/19 165/25
168/11 168/15
changes [8] 72/10
128/3 128/24 154/23
163/22 163/23 164/1
166/4
changing [1] 157/3
chap [2] 146/6
146/21
charge [5] 88/10
161/11 161/16 165/6
165/14
charges [1] 88/9
charging [1] 80/5
chat [3] 50/13 134/22
155/12
check [17] 4/8 4/18
29/9 69/19 79/4
105/20 106/23 124/25)
134/11 134/15 134/17)
134/25 152/23 155/3
155/6 155/15 155/18
checked [11] 28/14
29/1 29/11 29/17
133/23 134/2 134/21
141/20 153/19 155/11
155/19
checking [3] 29/1
152/6 153/4
checks [4] 29/3 29/5
93/13 156/25
checksums [1] 134/1
choices [1] 80/16
chose [3] 146/19
166/6 166/7
cited [4] 47/23
civil [3] 66/23 66/23
70/4
claim [1] 66/12
claimed [4] 153/6
155/21 156/15 159/14)
claiming [2] 62/25
151/3
clarification [3]
101/21 101/23 156/8
clarify [2] 103/20
109/25
clarity [2] 104/17
104/17
classed [2] 18/8 21/5
Clause [1] 63/5
Clause 12 [1] 63/5
clear [4] 38/13 38/20
106/19 152/4
ClearDesk [4] 106/19
122/10 122/25 123/11
cleared [2] 122/10
122/24
Clerk [1] 122/18
clerks [1] 85/13
clients [1] 167/16
clinging [1] 160/11
closed [8] 101/17
102/16 102/19 114/15)
138/14 140/16 140/22!
143/3
closure [1] 140/3
clue [2] 45/22 87/7
Co [1] 167/15
code [4] 68/16 105/2
105/3 105/6
colleague [2] 40/7
40/8
colleagues [3] 52/8
55/24 58/8
column [6] 28/1
28/11 28/12 28/22
30/7 30/10
come [23] 5/15 6/15
13/10 18/12 18/14
(48) Byfleet - come
Cc
come... [18] 21/4
24/23 42/5 52/8 58/8
71/23 72/3 81/15 85/9
115/12 118/1 125/14
125/16 132/6 144/7
146/10 154/11 164/24}
comes [1] 150/8
coming [2] 169/11
169/19
comment [4] 9/24
76/5 76/8 91/3
comments [5] 74/6
114/7 118/21 134/25
155/15
commercial [5]
60/23 60/24 61/17
62/5 69/24
commissioned [1]
44/2
communicating [1]
26/4
communications [1]
71/25
company [2] 21/15
91/25
comparative [2]
73/20 118/13
compiled [1] 120/2
complained [4] 37/17
39/9 134/10 155/2
complaining [3] 39/6
61/14 63/9
complaints [2]
133/22 153/18
complete [7] 10/8
43/14 66/7 77/21 81/3
81/19 82/2
completed [2] 11/5
11/6
complexity [1] 16/24
comprise [2] 17/6
18/4
compromise [2]
111/3 111/3
computer [17] 92/13
92/14 92/19 94/14
110/6 162/4 162/5
162/13 162/17 163/8
163/15 164/4 164/10
164/13 164/14 164/15)
164/16
computers [1] 106/2
conceivable [1]
16/23
concentrating [1]
18/22
concern [1] 52/20
concerning [8] 26/8
36/2 46/17 75/3 84/18
89/24 120/10 130/25
concerns [1] 33/9
conclusion [4]
154/11 155/22 155/24)
164/20
condition [2] 85/18
85/21
conduct [1] 132/2
conducted [1]
137/20
confidence [2]
146/17 146/19
confident [1] 33/18
confirm [9] 6/7 15/24
26/6 58/4 81/3 81/19
82/2 118/23 150/22
confirmed [4] 74/3
118/19 118/25 118/25)
confirming [2] 95/18
128/21
confiscation [1] 37/1
confused [1] 8/8
consecutive [1]
122/21
consider [2] 2/12
2/23
considerable [1]
5/21
consideration [3]
21/11 21/14 77/15
considerations [1]
80/16
considered [2] 49/20
61/2
consist [1] 53/2
consistently [1]
137/16
constitute [1] 17/3
constitutes [1] 85/22
consult [4] 2/22 52/7
53/10 58/7
consulting [1] 18/25
contact [2] 101/16
102/20
contacted [1] 117/15
contained [2] 94/24
110/5
containing [2] 82/21
83/2
contains [1] 98/5
contemporaneous
[1] 96/21
content [5] 24/5
31/19 33/20 78/17
166/14
contents [8] 5/12
11/11 64/13 64/21
67/7 81/24 91/20
143/12
context [2] 66/23
80/20
continue [3] 32/12
32/25 99/1
continued [1] 117/16
continues [6] 10/24
11/8 98/14 99/7 106/6
150/3
continuing [3]
119/17 123/7 141/21
continuity [1] 10/14
contract [4] 62/24
63/5 144/12 169/14
contractors [1] 17/7
contractual [1] 169/5
contrast [1] 152/4
contribute [2] 7/13
9/16
contributed [1] 20/21
contributions [1]
9/25
contributors [5] 7/18
7/21 9/14 9/18 90/15
controller [1] 105/2
controls [1] 12/1
conversation [8]
32/22 42/10 42/12
54/9 54/15 56/22
71/13 164/3
conversations [5]
42/11 45/4 54/13 71/1
137/4
convey [2] 162/20
164/7
conveying [1] 63/24
convicted [1] 36/23
Conviction [1] 39/21
copied [3] 75/24
87/17 148/20
copy [7] 3/18 47/1
67/19 88/18 89/24
100/23 131/5
Core [2] 144/18
145/7
corner [1] 149/20
correct [30] 4/12
4/21 7/15 10/5 15/25
19/17 22/3 25/5 25/8
25/12 25/13 41/16
47/12 55/20 61/8 62/4
65/14 73/7 73/10
80/10 83/19 110/8
112/1 114/5 114/6
116/14 127/24 141/5
152/25 170/6
correction [5] 1/8
3/24 4/4 4/13 4/22
corrections [2] 3/11
5/11
correctly [3] 2/15
29/3 41/23
correspondence [5]
39/6 123/15 123/19
124/17 124/19
corrupt [1] 105/21
corruption [2] 106/10]
106/14
cost [4] 79/21 79/23
79/24 80/5
costed [1] 80/8
could [61] 3/16 17/6
17/8 17/10 18/3 18/7
20/1 21/4 23/6 23/7
23/14 23/16 29/20
29/21 30/18 30/19
31/9 31/10 31/11 35/4)
37/16 43/17 43/22
44/13 44/13 46/2
47/24 52/6 53/14 55/3)
58/2 59/8 61/23 65/7
71/20 71/21 72/24
76/3 76/15 78/6 94/12,
94/12 96/4 108/7
110/25 111/19 112/23}
113/3 113/5 123/23
124/7 126/7 134/2
135/25 142/16 148/13
155/18 155/19 156/23
156/24 166/19
couldn't [6] 23/7
44/22 44/25 54/23
55/10 55/21
counsel [3] 1/22 17/1
132/13
count [1] 36/23
counted [1] 28/21
counter [41] 42/22
67/18 68/2 69/7 72/18}
85/13 101/14 105/25
106/1 106/23 106/24
107/19 109/14 113/13}
114/22 116/4 117/10
118/6 122/7 122/8
122/14 122/25 123/1
123/5 123/11 123/14
126/14 126/17 127/18}
127/23 128/10 128/13
129/4 129/23 130/5
130/12 133/16 133/17
133/20 143/13 153/16
counters [26] 41/7
41/11 41/14 41/16
42/1 42/7 43/9 44/21
44/24 81/25 86/5 86/7)
93/19 93/22 93/25
94/2 106/23 107/18
118/25 121/11 122/15}
129/7 134/4 154/8
168/12 168/16
counts [2] 36/24
39/21
couple [6] 31/11
31/11 41/7 46/19
108/18 140/13
course [5] 51/17 90/8)
159/17 160/11 170/2
court [47] 32/14
32/17 33/11 33/15
33/19 33/21 34/1
34/10 35/14 35/19
36/13 36/20 36/22
38/2 41/6 46/22 46/24
46/25 47/18 49/2
49/16 49/24 50/2 50/7
50/13 50/15 51/9
54/21 56/8 57/19 64/3
65/2 65/7 71/16 74/7
76/6 97/2 98/15 99/11
110/1 115/15 118/22
131/8 146/3 146/18
158/22 159/9
court’ [1] 47/4
cover [4] 37/21 76/16
159/25 161/8
covered [7] 11/17
11/23 12/20 15/22
16/3 16/14 80/1
covering [6] 158/17
158/19 158/19 158/20)
158/23 159/8
create [3] 19/21
19/25 21/3
created [2] 20/22
68/17
creating [1] 122/14
criminal [2] 54/21
115/15
critical [9] 73/20
73/23 73/25 101/8
117/3 118/2 118/16
120/21 121/17
cross [2] 97/10 152/6)
cross-checking [1]
152/6
cross-examined [1]
97/10
Crown [1] 36/22
CS [1] 87/22
CSPOA [2] 4/6 5/19
culture [3] 146/14
148/24 149/7
currency [1] 69/20
current [1] 168/1
Customer [4] 5/18
87/23 87/24 169/2
cut [5] 16/7 23/18
87/1 125/17 140/2
cutting [1] 77/22
D
data [79] 11/4 12/2
12/5 13/5 15/9 16/16
17/13 22/4 22/13 24/6)
24/18 24/25 26/12
29/4 29/4 29/5 31/24
33/3 33/4 33/7 33/25
34/19 35/7 38/6 47/2
47/11 47/17 47/18
47/21 52/7 57/23 58/2
58/12 58/14 58/15
58/19 58/20 59/1 59/9I
59/14 59/19 59/23
63/20 66/7 66/9 71/19I
82/4 82/8 82/10 82/21
83/11 93/14 94/3 94/7I
95/19 95/21 97/25
98/8 99/3 99/5 99/15
106/14 107/23 107/25)
108/2 110/17 132/4
135/18 135/20 136/3
(49) come... - data
D
data... [9] 153/22
153/25 153/25 154/2
154/4 154/10 155/13
156/6 166/19
Database [1] 12/7
date [10] 6/19 23/9
69/14 76/16 83/9
126/20 127/6 131/1
134/23 169/15
dated [16] 3/10 5/5
6/19 36/14 47/1 66/11
82/25 90/3 90/4 97/3
108/23 113/21 132/9
132/11 150/17 150/21
dates [11] 12/5 27/20
29/5 72/15 83/3 83/18
133/16 134/3 168/4
168/19 169/14
daunting [1] 32/18
Dave [5] 75/6 75/7
75/14 79/11 79/14
day [13] 3/6 8/21
19/10 19/10 36/24
40/9 40/9 51/2 100/20)
140/7 140/12 170/2
170/12
days [5] 42/23 43/4
46/19 77/21 113/21
deal [7] 3/14 58/4
99/9 115/18 124/5
138/24 146/25
dealing [3] 24/17
77/4 102/4
dealings [2] 40/9
53/25
deals [1] 132/14
dealt [6] 55/6 99/22
107/14 107/14 143/24}
165/5
decades [2] 59/22
143/19
December [3] 40/5
80/23 82/22
December 2009 [1]
80/23
decide [1] 50/6
decided [2] 15/3
163/14
declared [2] 141/12
141/14
decline [1] 1/21
decode [1] 43/1
deduce [1] 43/3
deeply [2] 148/25
148/25
defects [1] 25/8
defence [21] 16/25
38/8 38/17 39/5 39/7
39/8 40/19 40/25
41/18 43/12 44/3 65/2
65/7 71/18 72/1 76/14,
76/17 78/4 83/10
84/22 132/16
defend [2] 158/21
159/9
defendant [4] 64/3
64/3 65/21 88/8
defer [1] 56/2
deferred [1] 48/1
definitely [1] 99/14
delay [1] 105/24
deleted [1] 133/18
deliberately [1] 163/7I
deliver [3] 6/23 8/19
90/13
Delivery [1] 8/15
demands [1] 2/3
demonstrate [1]
52/15
denied [1] 37/22
Department [2]
58/24 59/7
depend [1] 56/18
depended [1] 71/1
dependent [1] 65/9
depending [4] 11/12
71/25 82/12 91/21
deployed [1] 58/6
depository [1] 9/3
depth [1] 71/7
describe [8] 18/10
26/15 52/14 58/13
70/13 102/7 129/6
130/8
described [8] 6/2
8/11 8/12 10/19 17/16
52/2 87/12 87/22
describes [1] 47/3
describing [2] 26/10
146/20
descriptions [3] 19/1
19/15 19/19
desktop [1] 164/16
detail [10] 5/21 17/2
17/14 36/8 53/4 70/15
77/24 85/9 108/21
167/17
detailed [2] 84/24
133/8
detailing [1] 67/21
details [10] 68/11
72/3 72/4 78/4 79/2
83/2 109/2 120/8
131/21 136/10
detected [1] 105/1
determined [5] 38/21
58/5 65/15 70/21 87/2
development [4]
40/11 122/22 167/18
167/22
device [1] 101/8
dictation [1] 4/2
did [189]
didn't [85] 7/13 14/22
22/4 22/6 22/8 22/9
22/11 22/12 22/14
22/15 22/19 22/22
22/23 23/1 26/18
26/22 33/13 33/14
33/15 33/17 40/9
40/12 49/25 51/5 53/8
53/22 54/13 54/19
54/22 55/7 55/16
55/17 55/18 55/19
57/15 59/10 59/20
59/24 59/25 59/25
62/14 62/14 63/19
65/8 73/6 73/9 77/5
77/18 78/12 78/16
80/15 90/7 95/12
95/12 96/13 98/15
102/10 102/13 103/3
103/9 104/11 104/16
105/16 110/21 115/17
115/21 119/15 121/4
135/14 136/21 136/23}
144/7 154/3 154/14
156/11 156/16 157/3
157/12 158/10 158/11
158/13 159/5 159/7
160/6 167/8
difference [3] 78/10
162/17 162/19
different [17] 19/8
23/6 24/15 28/21
29/14 51/15 98/4
110/24 124/7 124/21
136/15 140/9 149/14
159/11 163/9 163/11
163/13
rently [1] 35/20
icult [1] 14/18
di
diligence [4] 52/6
52/14 52/23 52/24
dipped [1] 108/19
disclose [2] 56/23
107/4
disclosed [8] 19/10
27/18 38/7 38/14 65/2
76/2 103/8 104/10
disclosure [4] 39/6
65/6 71/19 72/2
discredit [1] 17/1
discrepancies [20]
37/15 60/17 69/7
72/18 109/14 113/13
114/22 116/5 119/25
127/18 128/10 128/14
129/4 129/23 130/6
130/12 141/22 141/25]
142/4 143/4
discrepancy [10]
42/2 42/9 44/23 61/13
62/24 68/2 126/14
126/17 127/24 143/16
discrepancy’ [2]
41/12 67/18
discrimination [1]
2/20
discussed [10] 67/14
128/1 128/5 128/17
128/18 128/25 130/16)
130/19 131/18 163/20}
discussing [1] 107/6
discussion [6] 42/5
82/3 86/19 111/2
111/4 128/19
discussions [6]
50/21 71/2 71/6 107/7,
111/5 165/23
disk [4] 67/21 82/20
105/1 106/11
disk-drive [1] 105/1
dissect [1] 120/20
distributed [2] 8/24
9/1
do [123] 2/9 2/24
2/25 3/22 4/4 5/2 5/3
9/23 19/4 20/23 23/6
24/9 24/10 24/18 26/2
27/1 30/16 30/20
31/19 32/14 32/22
32/24 34/23 34/24
35/2 35/10 39/10
41/25 43/1 44/25
46/16 47/25 50/3
50/20 53/22 54/1
54/19 64/4 65/15 67/1
68/23 69/4 70/5 71/9
72/16 74/12 75/7 78/4
78/13 79/19 80/14
81/4 81/20 81/24 82/5)
82/10 83/23 86/3
87/19 89/19 96/6
97/17 99/6 101/23
102/1 102/7 102/21
106/21 107/22 109/6
109/11 110/2 113/10
116/8 119/6 119/9
119/22 119/23 120/9
121/13 126/1 127/13
127/24 128/22 129/20}
133/7 133/7 135/2
135/19 136/13 138/19}
139/8 141/25 142/1
142/9 142/14 145/20
146/21 146/22 148/15)
149/24 151/4 151/5
151/12 152/7 153/8
153/24 155/4 156/11
156/12 156/12 158/1
158/3 158/5 158/16
158/24 159/15 159/16}
159/21 161/15 161/18)
164/21 168/10
document [21] 5/4
6/14 6/16 7/2 8/18
8/20 9/9 9/15 10/6
14/19 15/16 21/19
23/2 27/23 28/8 68/4
90/12 91/5 92/5 95/4
150/13
documentation [1]
50/22
documents [15] 7/14
8/24 9/5 10/2 18/20
19/2 19/8 19/21 20/11
20/20 20/25 35/23
49/9 110/3 151/10
does [27] 5/25 8/13
13/18 21/14 38/5
53/16 69/19 82/4 82/6I
83/9 99/1 102/18
102/23 113/1 114/23
123/11 124/13 129/21
129/22 129/23 130/1
130/4 134/5 135/9
138/22 151/13 164/17
doesn't [13] 51/2
80/12 102/10 102/17
102/22 116/2 119/11
119/11 137/18 139/16)
150/19 151/2 151/14
doing [18] 23/11
23/14 23/19 23/22
45/25 50/5 50/19
50/23 51/4 51/5 51/6
57/1 70/3 79/25 137/9I
148/8 149/2 170/3
don't [146] 7/4 7/7
8/22 9/6 12/25 13/16
13/20 14/18 14/18
15/15 16/9 16/12
17/19 18/1 19/20
19/20 20/7 20/10
21/17 23/5 24/20
29/20 30/12 30/15
30/19 31/5 31/9 31/12)
32/21 34/17 40/2 42/6I
42/10 43/23 44/7 44/7)
44/15 47/19 47/119
47/21 48/5 48/6 49/2
49/7 49/24 50/1 51/12)
51/12 54/5 55/1 55/5
56/25 57/12 58/22
58/23 59/15 62/15
62/18 64/16 65/23
65/24 66/6 71/13
71/25 76/17 77/12
77/14 78/13 79/1 79/5I
79/6 79/11 79/24 80/3}
84/5 85/1 89/11 89/12I
90/18 92/4 92/5 92/22I
93/5 99/16 101/23
101/24 101/25 102/1
102/7 110/20 110/24
112/6 112/9 112/25
119/5 119/14 120/11
120/16 121/20 121/22)
124/10 124/20 128/19)
128/23 133/11 133/17)
133/20 135/9 135/24
136/17 137/22 139/2
142/17 143/22 146/4
148/6 148/7 148/10
148/14 149/7 150/9
153/10 153/16 154/11
(60) data... - don't
D
don't... [22] 155/23
156/25 158/7 160/4
161/1 161/14 162/9
162/22 163/11 163/12
163/19 164/7 164/19
164/20 165/16 165/17
165/19 167/4 168/5
168/19 169/13 169/16}
done [43] 19/24
29/12 35/3 39/1 53/19
53/19 56/14 66/20
70/15 72/23 77/2 77/3
77/22 89/3 96/25
103/12 103/13 103/15
103/16 103/18 104/1
104/15 105/8 107/3
120/23 121/4 122/3
122/15 124/20 128/6
128/20 135/15 135/25}
137/2 137/8 153/4
153/7 153/12 153/23
154/19 156/2 156/2
156/25
Donna [1] 57/5
double [1] 29/9
doubt [2] 76/14 162/1
down [66] 3/20 5/15
7/16 8/11 10/7 14/1
14/3 15/19 18/12
24/23 28/13 31/13
35/25 36/14 36/17
43/6 45/19 66/20 68/9)
68/25 72/13 73/17
75/5 75/19 81/12
82/15 82/24 85/7
87/15 90/20 96/1
101/4 104/25 106/8
106/22 108/23 109/16}
111/25 113/8 117/2
117/13 118/11 126/2
132/6 132/23 137/23
138/4 138/10 139/7
139/14 139/22 139/25
140/6 140/11 140/15
140/19 141/5 141/18
142/21 146/2 149/8
149/21 149/22 150/2
150/25 154/24
download [1] 22/7
downloading [1]
21/25
dozen [1] 30/18
draft [1] 126/25
drafted [8] 14/21
14/21 14/22 19/5
21/20 161/10 161/20
165/17
drafting [2] 19/18
21/11
drew [1] 95/10
drink [1] 89/4
drive [5] 16/15 30/21
38/2 105/1 106/3
driven [2] 18/20
160/20
dropdown [4] 28/3
28/15 28/15 30/9
dropdowns [1] 67/5
dry [2] 146/4 148/14
due [8] 52/5 52/14
52/23 52/24 105/24
118/8 141/22 145/25
Dunk's [4] 134/19
Dunks [50] 1/5 1/8
1/12 1/14 1/16 1/20
2/24 3/4 3/5 15/24
18/23 23/7 23/17
25/20 51/25 55/2
61/18 66/16 83/24
84/17 108/16 124/21
125/15 135/23 144/15)
145/12 145/15 146/15)
146/24 147/8 147/20
147/22 148/12 154/14)
155/17 156/10 156/19)
157/23 159/12 162/21
163/6 164/18 165/5
165/11 166/6 166/12
167/13 169/22 169/25)
171/2
during [13] 2/21 27/5
48/3 68/15 106/13
109/9 122/12 123/2
124/9 124/10 125/3
125/3 170/2
duty [1] 54/6
a
E-F-F-E-C-T [1]
114/1
each [26] 11/12
11/15 12/18 14/7
14/15 15/20 19/4
27/22 30/9 52/25
68/17 69/13 70/14
91/13 91/21 92/21
96/7 96/22 104/14
122/12 125/1 125/11
125/18 126/4 127/8
127/19
earlier [13] 10/19
14/2 37/9 83/11 86/22
89/24 90/4 111/11
121/25 137/1 149/13
152/10 157/12
early [2] 89/8 126/25
ease [4] 128/15
147/10 148/18 149/9
easier [2] 21/4
100/11
easily [1] 142/16
Edem [3] 37/6 37/8
37/9
edition [1] 113/24
effect [19] 34/23
48/18 67/17 68/2
72/18 80/7 85/3 92/17
114/1 116/4 125/24
126/14 126/17 127/23
128/13 129/4 130/5
130/11 158/17
effective [2] 119/20
122/25
effectively [1] 51/10
eg [1] 4/9
eg FUJ00186421 [1]
49
eight [1] 106/22
either [16] 7/8 13/22
23/23 27/3 49/2 57/22
58/5 71/2 71/20 102/9
104/12 106/2 110/10
122/24 139/4 166/10
element [1] 85/12
else [9] 33/2 33/6
57/21 74/13 98/1 98/9
112/13 121/2 155/18
else's [1] 74/19
elsewhere [1] 110/9
email [74] 36/1 36/1
36/12 39/23 39/24
40/15 41/18 42/3 42/4
44/11 47/1 47/6 47/23
67/9 67/10 67/12
68/21 71/10 75/3 75/6
82/16 82/17 83/5
84/18 87/17 99/25
100/2 101/24 102/9
102/10 103/10 126/9
126/11 127/7 127/25
127/25 128/4 128/4
128/18 130/15 130/19!
130/20 131/1 131/3
132/11 132/18 132/20}
135/4 135/7 142/5
145/23 146/2 147/17
148/22 149/12 150/2
150/6 150/7 150/15
151/2 151/9 151/11
151/17 151/23 152/3
152/3 152/11 152/22
153/2 153/9 154/5
154/24 155/9 157/23
emailing [1] 75/6
emails [4] 13/21 38/9
90/8 149/15
embedded [1] 6/11
employed [1] 5/24
employees [2] 9/19
9/19
enable [1] 120/20
encouraging [1]
147/3
end [11] 6/22 6/22
23/22 68/1 90/12
90/12 102/2 102/3
169/11 169/14 169/19}
ended [2] 47/4 86/25
ending [15] 73/16
73/18 100/17 101/4
103/5 104/4 104/5
104/21 104/23 106/8
114/10 117/2 118/12
133/2 158/4
endorsed [1] 42/24
ends [1] 102/5
engaged [1] 25/2
engaging [1] 71/10
engineer [4] 40/11
44/17 103/3 106/4
engineers [1] 58/4
enough [4] 26/25
27/2 27/5 27/7
enquire [1] 77/24
enquiries [1] 40/19
ensure [1] 12/1
enterprise [1] 25/1
entire [1] 143/10
entirely [1] 160/21
entirety [2] 83/16
130/19
entity [1] 6/7
entries [5] 24/4 48/17
49/3 49/4 133/13
entry [9] 22/16 87/3
102/5 102/12 107/2
138/3 138/5 141/8
142/18
entry-level [1] 87/3
episode [1] 142/24
equates [2] 76/20
85/25
equipment [3] 40/20
41/19 42/22
Er [1] 53/18
error [30] 60/24 61/6
61/7 61/14 61/15
61/17 101/8 101/10
101/13 104/8 104/11
105/12 105/21 105/23}
106/1 107/10 115/3
117/4 117/7 117/8
118/2 118/4 120/21
121/18 124/4 134/9
138/20 154/25 154/25]
166/14
Error’ [1] 73/20
errors [11] 25/7 26/4
96/4 107/11 107/13
121/12 123/18 124/18}
133/21 153/17 154/9
especially [1] 88/11
essential [1] 39/18
essentially [9] 28/19
46/7 50/7 54/16 68/13)
69/9 70/13 81/11 83/4
estimate [3] 79/15
79/19 80/5
et [5] 60/19 85/15
107/14 110/6 118/14
et cetera [4] 60/19
85/15 107/1 110/6
even [6] 54/20 59/18
59/22 116/15 158/1
164/6
event [13] 3/22 39/14
48/6 101/10 105/25
117/3 118/4 122/16
123/1 123/24 124/9
125/2 125/8
event' [1] 73/19
eventing [2] 122/17
123/5
events [21] 4/7 4/18
73/25 105/20 105/22
105/22 106/18 117/11
118/7 118/16 119/7
119/14 122/7 122/14
134/14 134/21 135/18)
135/20 136/2 136/4
155/11
eventualities [1]
160/1
eventually [2] 14/25
75/11
ever [26] 14/19 16/6
17/19 18/7 32/21
49/22 49/22 57/13
57/16 59/12 59/16
59/21 59/22 60/8 66/1
79/24 80/4 112/23
120/9 120/12 121/20
143/20 165/1 166/25
167/1 168/6
every [16] 51/2 60/8
72/23 76/24 92/21
93/14 94/16 122/9
122/20 125/18 125/23)
140/20 142/25 143/1
163/19 166/16
everyone [4] 89/1
89/3 89/4 90/9
everything [7] 67/2
93/10 105/4 112/3
113/2 129/7 143/19
evidence [55] 2/4 3/6
10/14 11/11 12/9
13/15 13/16 17/9 18/8)
25/1 33/10 34/14 35/5
35/9 35/10 35/14
35/19 38/17 38/18
39/11 39/15 39/17
40/4 41/21 44/5 46/20)
46/23 49/16 50/7 50/9)
51/10 52/14 57/18
76/2 76/3 83/25 85/7
88/7 88/23 91/20 97/2
97/6 105/17 115/14
121/8 121/10 138/18
142/3 146/1 148/4
157/8 158/21 164/5
167/21 170/1
evolved [1] 163/22
exact [1] 162/12
exactly [5] 68/23
74/10 83/6 97/13
113/23
examine [3] 62/9
(61) don't... - examine
E
examine... [2] 62/12
69/8
examined [2] 58/2
97/10
example [15] 11/14
14/5 17/11 28/4 28/13}
62/19 69/22 70/7
73/23 91/23 92/1 95/9
121/8 124/13 142/11
except [1] 113/24
exchange [4] 41/3
84/18 132/18 132/20
exchanges [1] 100/1
exercise [1] 155/14
exhibit [17] 22/6
23/10 23/10 64/25
66/2 66/11 66/15
67/21 68/18 68/21
68/23 70/5 70/7 70/23,
81/11 131/6 132/3
exhibited [3] 64/24
65/13 138/2
exhibiting [7] 65/16
66/19 66/23 95/20
131/5 131/19 131/24
exist [2] 90/7 105/22
existence [1] 166/13
existing [1] 119/16
expand [1] 71/24
expected [8] 9/4
41/17 93/17 93/24
94/2 107/19 129/8
130/9
expensive [1] 167/25
experience [1] 20/22
experienced [1]
37/15
expert [17] 16/20
17/6 17/10 17/17
17/25 18/3 18/8 18/11
38/17 39/5 39/11
40/19 40/25 41/19
43/12 44/2 137/1
expertise [8] 26/19
26/23 45/16 74/5
74/18 109/24 113/14
118/20
experts [2] 105/14
105/16
explain [11] 49/2
52/13 52/18 56/6
71/11 74/25 77/9 94/1
100/10 104/20 107/8
explained [4] 46/10
46/11 100/10 100/12
explaining [2] 11/3
20/25
explanation [7] 22/18}
22/20 86/14 110/17
110/18 113/1 129/9
explanations [1]
100/14
explicit [1] 50/24
explored [1] 38/24
extent [8] 9/23 21/7
24/24 24/25 26/7
51/25 73/11 80/15
extra [2] 77/24 132/2
extract [7] 19/7 21/12!
33/7 38/3 38/5 47/16
99/15
extracted [4] 23/8
24/25 29/4 93/14
extracting [6] 11/25
26/12 33/25 95/21
98/8 99/5
extraction [17] 10/21
11/4 12/5 21/18 22/2
29/12 33/3 33/5 34/2
35/6 95/19 95/24
96/18 98/22 99/3
110/16 110/18
extractions [3] 19/6
31/24 32/7
extracts [1] 125/17
eye [1] 167/17
eyes [1] 29/8
F
face [8] 38/12 38/12
44/17 73/5 102/17
121/12 121/17 139/6
facility [4] 17/17 62/8
62/11 67/1
fact [45] 2/6 7/12
10/9 10/11 11/2 11/10
11/11 11/14 11/18
11/24 12/21 15/23
16/25 17/17 17/23
22/21 27/14 34/14
45/3 47/6 56/8 63/13
72/25 86/8 88/10 91/6
91/9 91/19 91/20
91/23 92/2 112/10
112/17 116/16 116/16)
121/12 126/11 130/11
131/2 148/3 149/23
157/7 157/8 158/20
160/11
facts [5] 46/2 109/18
111/8 111/14 111/18
FAD [1] 68/16
failed [1] 118/3
failing [2] 69/20
118/8
fair [1] 148/22
fairness [1] 2/3
fall [12] 69/5 69/22
72/16 86/3 109/12
113/10 114/23 116/3
127/13 129/20 130/1
142/9
false [5] 36/24 55/22
88/9 93/4 94/9
familiar [3] 7/17 8/20
8/22
far [11] 10/12 10/17
18/10 30/4 30/6 56/2
95/20 125/12 134/9
144/10 155/1
father [3] 37/6 37/9
37/11
fault [16] 58/6 62/25
63/6 69/25 100/15
101/19 102/6 102/7
103/8 104/12 105/1
106/2 106/5 119/21
160/13 160/14
faults [4] 67/16 102/4
107/19 126/13
feature [1] 134/6
February [8] 6/20
90/4 90/6 133/1
133/16 138/5 140/19
141/12
February '08 [1]
133/16
feel [1] 41/23
felt [1] 43/10
Fetter [1] 146/3
few [2] 41/6 122/11
fifth [2] 12/3 68/10
figures [1] 37/20
file [1] 12/7
filed [2] 151/19
152/18
files [4] 41/16
fill [2] 15/8 47/24
final [2] 102/8 150/12
finally [2] 160/5
160/7
financial [3] 4/8 4/19
80/16
find [9] 20/19 80/12
81/1 81/17 81/23
120/12 133/9 152/6
156/21
fine [10] 1/10 42/21
75/24 76/13 77/23
84/6 122/11 144/24
145/10 170/9
finish [2] 169/5
169/10
fire [1] 170/7
firm [1] 167/14
first [44] 3/14 4/24
11/21 17/12 17/23
25/14 38/25 61/22
67/9 68/1 69/16 70/22
71/6 71/21 71/21 72/9
75/3 75/6 75/11 79/3
84/24 85/14 87/3
100/2 104/21 105/20
106/18 111/7 116/11
124/12 125/9 131/3
132/20 132/25 133/2
138/21 139/19 146/17]
148/19 153/13 154/5
157/24 160/17 160/22
firsthand [1] 120/19
firstly [8] 25/3 33/19
43/16 56/10 70/4 96/6
116/8 134/18
five [10] 11/21 37/9
38/9 85/16 98/20
99/13 108/25 141/24
145/8 151/10
five-page [1] 151/10
fix [2] 58/6 106/17
fixed [4] 110/25
117/11 118/7 119/21
FJ [4] 146/7
flexible [2] 11/12
91/21
flooding [2] 117/23
117/24
floor [2] 53/24 137/5
focused [1] 19/3
focusing [1] 25/20
fold [1] 15/11
folder [1] 15/12
follow [6] 11/9 83/9
91/18 105/22 140/18
160/25
followed [3] 18/20
100/9 136/18
following [11] 4/4
85/22 94/24 103/1
137/8 159/14 160/15
160/23 161/4 167/6
170/12
font [1] 100/8
foot [7] 41/2 41/3
70/12 92/8 94/21 97/5)
97/5
foreign [1] 69/19
form [10] 2/1 12/4
54/16 82/11 88/8
89/16 89/20 110/20
128/5 129/3
formal [4] 20/20 29/8
39/11 79/19
format [5] 11/9 91/18
150/7 150/10 166/5
formed [2] 73/12
128/14
forward [4] 40/21
42/13 97/9 118/10
forwarded [4] 41/4
82/1 149/16 149/18
forwards [6] 14/1
16/19 82/14 82/23
88/13 130/24
found [3] 80/9 88/9
120/14
foundation [1]
115/14
four [8] 12/17 37/9
39/21 76/24 109/21
151/11 151/17 151/23
four-page [1] 151/17
fourth [1] 11/22
frame [1] 76/21
frankly [1] 125/15
freeze [1] 117/14
frequency [8] 63/25
64/6 77/6 77/8 77/10
77/13 78/12 78/14
frequently [5] 60/14
64/13 64/15 129/15
129/18
Friday [1] 100/23
front [3] 3/18 3/19
7/4
frozen [1] 117/16
FUJ00059070 [1]
104/22
FUJ00059107 [1]
106/7
FUJ00083683 [1]
127/1
FUJ00083702 [3]
67/8 126/8 130/15
FUJ00083703 [4]
68/8 72/12 108/22
127/2
FUJ00083704 [1]
113/20
FUJ00083720 [1]
122/4
FUJ00083729 [1]
130/24
FUJ00122673 [1]
80/19
FUJ00152205 [1]
89/22
FUJ00152209 [1]
6/14
FUJ00152990 [2]
132/18 149/15
FUJ00153059 [1]
82/14
FUJ00154750 [1]
145/23
FUJ00155555 [1]
87/14
FUJ00186421 [1]
FUJ00201401 [1]
97/1
FUJ00225544 [1]
100/1
FUJ00225644 [2]
35/24 39/24
Fujitsu [45] 5/18 5/24I
6/9 9/15 9/18 13/22
13/22 16/2 16/13
17/21 18/25 19/15
19/18 20/12 21/8
27/20 31/16 33/23
34/11 38/1 38/4 40/7
57/7 57/10 57/13 62/3
76/23 79/12 88/16
88/19 89/24 121/2
137/17 143/20 144/7
145/15 145/21 146/11
146/23 149/2 159/15
160/5 161/21 169/1
169/6
Ce)
(52) examine... - Fujitsu
F
42/8 43/9 44/22 66/6
function [4] 26/15
26/16 35/9 48/25
functioning [1]
106/25
funding [1] 40/20
further [39] 28/12
40/18 61/24 62/1
82/17 83/1 106/22
108/24 116/19 117/11
118/7 119/4 121/18
129/6 129/8 131/4
134/24 138/5 142/3
142/22 143/9 144/7
155/14 156/5 156/12
159/11
future [2] 67/25
148/4
G
gain [1] 56/11
gained [2] 27/7 46/12
gap [1] 47/25
Gareth [9] 39/10
42/25 47/24 132/19
134/12 134/22 149/17)
155/12 157/25
Gareth's [1] 165/2
gave [9] 3/6 24/25
34/15 40/4 45/3 70/14}
70/22 77/17 86/9
general [3] 74/5
118/20 133/25
generalised [1]
125/18
generally [3] 48/11
74/20 98/22
generate [1] 73/21
generated [1] 14/21
generating [1] 34/18
genuine [1] 147/13
get [14] 8/7 22/17
22/20 29/8 36/8 36/18
40/20 74/8 77/22
77/25 78/19 102/21
115/10 123/4
gets [1] 140/25
getting [3] 40/17
143/3 165/11
give [31] 2/4 3/4 4/9
13/16 32/3 34/13
35/14 35/19 44/23
46/23 50/24 56/18
58/25 59/7 65/6 68/16)
full [14] 3/4 32/4 42/2
67/7 67/15 68/22 72/2
100/10 122/15 131/20}
fully [2] 99/17 106/25
63/12 74/2 78/4 81/14
123/12 123/19 124/14}
131/19 132/24 133/14)
150/21 152/15 154/23)
69/13 76/8 83/24
122/16 126/1 146/1
146/16 146/19 148/4
given [17] 1/9 6/21
9/23 13/8 16/23 21/11
21/14 46/6 48/24
51/11 62/23 71/8
88/11 92/5 112/2
153/5 169/9
gives [1] 67/1
giving [9] 11/13
33/10 46/19 51/10
78/11 80/4 91/22
157/7 170/1
glance [1] 61/22
go [68] 5/7 7/16 8/10
9/13 10/6 11/22 12/16)
14/1 14/12 15/18
18/12 22/1 22/17
27/16 28/3 28/11 30/7
31/13 33/19 33/20
36/11 39/23 41/2 43/6)
43/16 46/13 46/25
49/2 49/24 50/1 50/12
51/8 52/21 53/16
53/23 54/3 57/19
66/18 68/9 72/11
73/15 75/19 80/19
82/23 91/15 92/7 97/3)
97/9 102/12 108/25
109/15 113/7 113/22
118/10 127/7 130/15
131/16 142/19 144/10)
146/17 147/2 150/13
152/9 152/10 154/5
154/24 155/9 157/23
goes [4] 50/25 91/12
99/9 167/20
going [60] 4/2 5/17
13/10 14/2 18/22
24/14 25/19 25/20
32/17 33/15 35/14
35/19 36/18 38/9
41/22 43/7 44/2 44/5
44/18 45/3 45/19 46/8
47/6 53/9 53/12 54/16
54/20 66/20 66/21
67/9 69/8 77/20 79/10
81/6 85/9 95/1 98/23
99/24 107/8 107/13
112/3 134/12 134/24
135/5 140/24 141/19
142/13 146/11 146/23)
148/4 155/6 155/14
157/4 166/12 167/5
168/25 169/3 169/6
169/10 170/4
gone [6] 42/24 50/14
72/22 104/7 122/2
160/7
good [12] 1/3 1/16
51/22 84/14 84/16
101/15 105/16 120/16)
157/15 158/11 158/20)
88/22 98/10 107/12
145/3
8/8 19/12 20/11 28/8
61/19 61/20 62/24
74/10 74/12 79/2
101/5 101/24 103/24
104/17 105/9 105/10
110/14 115/8 115/11
116/13 119/16 124/5
125/12 137/5 137/7
140/2 147/9 149/5
149/8 149/10 149/23
149/25 150/18 151/6
167/13 169/21
grading [1] 73/22
Graham [7] 87/19
87/20 88/3 88/5 88/5
88/21 90/22
granular [1] 17/2
grateful [1] 170/2
greater [4] 51/9 52/9
56/3 58/9
green [1] 76/8
GRO [1] 150/18
ground [1] 2/9
Group [1] 97/3
guessing [3] 31/12
82/4 83/15
guidance [6] 24/21
24/22 46/6 68/12
109/3 139/21
guide [2] 13/3 115/3
guilty [1] 88/9
H
habitually [2] 119/23
120/3
had [174] 8/6 16/10
19/2 20/3 20/20 25/7
25/10 25/11 26/3
26/25 27/5 27/23
28/23 29/4 29/11
32/21 33/4 34/2 34/3
34/15 34/19 37/9
37/12 37/14 37/15
37/18 37/19 37/25
38/10 38/21 40/17
40/23 42/5 42/12 45/5
45/9 45/22 46/1 46/6
46/10 46/10 46/12
47/16 48/18 49/11
50/8 50/14 50/20 52/8
52/9 53/25 54/9 55/1
55/6 56/2 56/6 56/9
56/10 56/12 56/16
56/21 57/18 58/5 58/6
58/8 58/9 58/12 58/12
58/22 59/2 59/4 59/8
61/4 61/16 61/21
108/14 108/16 138/18
got [50] 3/18 3/19 5/5
32/15 35/25 41/8 56/2
63/1 65/22 72/23 74/9
151/11 151/14 151/15)
71/16 72/2 72/18
72/19 72/25 83/10
84/19 84/20 84/24
84/25 86/17 90/7
91/25 93/3 95/18
95/21 96/8 96/16
98/18 100/5 100/22
107/7 107/16 109/13
112/20 113/12 113/14}
113/17 114/1 114/16
114/21 115/16 115/21
115/22 116/4 117/16
119/9 119/18 119/20
119/21 120/1 120/14
120/25 121/6 122/19
124/1 126/1 126/13
126/17 127/17 127/23}
128/4 128/10 128/13
129/1 129/3 130/5
130/11 130/19 130/20}
130/20 133/7 134/22
136/25 137/19 140/14)
143/16 144/4 144/5
147/4 148/1 148/16
153/5 153/25 154/2
154/3 154/16 154/19
155/12 155/17 155/18}
155/20 156/3 156/14
156/19 156/23 157/10
158/3 160/8 165/7
165/7 165/8
hadn't [6] 45/1 45/1
111/13 137/13 153/25]
154/4
half [2] 3/6 30/18
halfway [2] 147/4
147/17
Hamilton's [4] 99/21
100/5 101/3 104/13
hand [12] 37/20 39/3
47/17 62/5 127/7
127/10 127/15 149/20}
152/1 155/2 157/14
157/16
handing [1] 66/2
handler [2] 119/2
138/15
handling [1] 124/4
hang [2] 146/4
148/14
happened [20] 10/3
10/3 15/25 16/9 36/10}
36/19 54/6 62/12
62/15 63/1 63/11
70/10 79/8 86/16
115/22 120/18 132/17,
143/19 143/20 143/25}
happening [3] 20/7
49/4 124/1
happens [3] 129/15
129/18 146/5
happy [16] 31/18
33/19 33/19 34/20
62/15 67/17 68/1 69/6
41/12 41/25 43/7 76/6
103/20 115/7 115/11
126/2 140/5 155/23
158/22 158/23
hard [3] 3/18 37/12
38/1
has [55] 1/21 5/4
13/11 28/5 38/24 39/1
40/18 42/15 46/25
47/10 58/23 61/19
61/20 105/1 106/11
106/12 111/23 114/12)
116/9 116/13 121/8
121/10 122/11 123/11
124/5 126/21 127/21
131/1 133/6 134/10
134/14 134/18 134/23)
139/11 139/18 139/19)
140/17 140/20 141/11
141/13 141/16 141/17)
141/20 143/1 145/24
150/18 150/19 151/2
151/17 155/2 155/13
156/6 158/2 167/21
169/15
hasn't [5] 1/9 134/9
151/6 151/14 155/1
have [304]
haven't [5] 19/12
81/15 101/24 161/10
161/15
having [4] 42/10
71/13 72/1 106/21
he [67] 1/9 36/25
37/5 37/11 37/12
37/14 37/15 37/16
37/17 37/18 37/19
37/19 37/20 37/21
38/12 39/13 40/7 40/8)
40/11 42/17 42/19
43/7 43/7 43/9 43/10
43/16 43/17 43/22
4A4IT 44/8 44/8 44/20
44/25 45/1 45/1 47/3
75/8 82/4 82/5 82/6
82/7 87/25 88/14
88/16 88/21 90/25
97/11 100/17 101/20
101/21 102/5 146/19
146/23 147/9 149/7
160/8 160/9 160/22
161/4 164/12 164/14
164/14 164/15 164/16)
164/19 164/21 164/24)
he'd [2] 77/15 78/14
he's [3] 43/24 44/25
50/12
head [5] 41/6 41/24
43/11 57/6 83/24
headed [1] 91/13
heading [1] 16/21
hear [5] 1/3 51/22
84/14 108/14 145/3
heard [3] 121/8
(53) full - heard
H
heard... [2] 121/10
160/2
hearing [3] 40/18
40/24 170/12
heart [1] 152/2
held [6] 25/3 92/17
96/5 96/12 96/24
162/8
help [17] 8/10 8/13
15/15 20/8 21/20 30/1
32/1 53/11 53/15
70/21 81/22 83/13
90/17 95/8 167/17
168/2 169/3
help’ [1] 38/12
Helpdesk [27] 21/13
21/21 21/25 22/2
25/11 26/8 26/25
27/11 48/2 58/20
76/24 77/4 79/17
82/21 84/20 85/14
86/18 104/16 105/19
107/2 115/18 117/15
125/19 136/16 141/2
150/23 154/7
helpful [2] 36/10
144/16
Helpline [2] 37/18
132/15
her [21] 8/5 32/3 32/3
32/16 32/22 40/2 40/3
40/15 139/8 139/15
140/4 140/8 141/12
141/14 141/16 149/24}
151/6 158/10 158/12
158/12 158/19
here [25] 3/19 19/13
20/16 21/19 25/3 36/1
52/23 58/13 66/2
66/19 66/22 70/3
71/24 95/22 96/6
97/10 97/17 101/23
136/25 142/11 142/18}
153/9 157/14 157/22
165/11
herself [1] 142/16
Hi [2] 75/14 80/25
hidden [2] 67/5 67/5
hide [1] 161/8
hiding [1] 166/23
high [6] 46/22 71/4
73/23 78/8 78/25 97/2
high’ [1] 39/4
highlight [1] 74/2
highlighted [3] 15/19
118/12 149/24
highlighting [1]
133/15
him [14] 1/22 37/10
39/13 40/9 42/5 42/11
43/21 77/17 79/3
87/22 101/25 102/11
158/25 161/25
himself [1] 43/22
hiring [4] 41/18
his [22] 1/6 1/8 37/5
37/6 37/9 37/11 37/14
40/10 43/3 43/10 44/4
46/24 50/4 50/12 51/8)
75/20 75/25 114/17
157/14 161/6 164/15
164/16
historic [1] 25/25
hm [10] 9/11 13/2
34/22 68/3 75/22 83/8)
88/25 115/23 130/3
152/14
HNG [1] 168/12
HNG-X [1] 168/12
hold [3] 66/1 92/17
140/25
Holmes [6] 8/7 8/7
8/11 8/12 8/16 90/16
honest [2] 112/6
150/9
honestly [4] 30/19
73/2 147/12 167/3
Hooper [7] 87/18
87/19 87/20 88/5
88/13 88/21 90/16
hope [1] 153/10
hoping [2] 146/9
168/22
Horizon [59] 11/4
16/24 17/4 24/6 25/4
25/8 26/19 26/23 27/3
27/10 37/18 37/23
37/25 38/18 39/17
48/19 56/1 58/15
58/20 59/1 59/9 59/14
59/19 59/23 63/20
64/9 69/25 85/13
85/14 85/18 85/21
88/7 88/22 89/10 94/5
96/2 96/19 98/22
107/17 107/21 107/24)
113/14 116/21 125/19)
132/15 140/14 150/23}
158/22 159/9 167/18
167/23 168/2 168/7
168/7 168/18 168/22
168/24 169/4 169/18
Horizon-based [1]
89/10
Hosi [14] 36/6 36/16
36/23 37/6 37/8 37/14)
37/25 38/10 38/15
38/21 39/19 84/2
108/20 109/5
Hosi's [10] 36/11
36/19 37/4 39/22
67/11 72/11 83/25
86/22 109/4 127/3
hour [2] 127/24
128/8
hours [9] 106/19
123/2 123/4 124/10
124/11 125/3 125/4
126/6 126/6
how [84] 8/24 9/1
14/20 14/21 19/4 19/7I
20/12 20/25 21/12
22/1 24/21 30/13
30/17 31/4 37/16 52/2
52/11 53/9 53/13 54/4
58/11 69/8 70/14 71/9
78/24 79/5 79/6 81/3
81/19 82/2 82/7 84/23
89/12 93/4 93/12 94/8
94/12 94/12 98/17
99/12 105/10 107/3
107/14 107/14 107/16}
114/24 116/5 118/23
119/2 119/14 124/5
124/7 124/24 125/1
125/12 125/13 128/23}
139/10 139/14 141/25)
143/11 144/5 148/11
153/22 154/8 154/11
155/22 155/23 156/19}
156/23 157/1 159/10
161/9 161/12 161/15
161/18 161/19 163/23}
164/19 164/19 164/21
164/24 165/6 169/3
Howe [1] 167/15
however [4] 2/6
32/13 47/25 134/25
HSD [36] 19/7 19/23
21/17 22/16 23/4
23/10 24/18 25/11
25/22 25/25 30/25
33/25 34/3 35/7 48/9
48/17 52/1 52/5 52/15
59/18 60/14 60/16
60/22 61/4 61/10
61/19 62/3 62/16
64/23 64/25 66/19
66/22 68/13 70/15
93/15 102/5
HSH [15] 68/12 69/1
75/16 85/23 86/14
93/8 109/9 109/11
110/18 110/23 113/9
116/9 116/12 116/23
120/10
l accessed [1] 23/17
ladvised [1] 140/4
l agree [2] 74/16
161/6
l agreed [1] 161/5
lam [5] 23/7 98/23
99/18 113/17 158/5
l analysed [1] 41/7
land [1] 18/16
l apologise [1] 131/6
l appear [1] 67/18
I appreciate [1]
88/10
l approve [1] 51/2
lask [6] 1/5 1/17
1/17 144/17 145/12
167/14
lasked [1] 84/17
lassume [1] 41/21
I balanced [2] 125/2
125/13
I begin [1] 6/2
I believe [22] 6/10
8/1 8/14 15/11 15/14
19/4 26/25 27/7 75/8
78/11 87/20 88/17
89/18 93/16 111/14
120/24 122/3 125/3
142/12 147/11 165/9
168/11
I believed [6] 53/10
93/10 107/21 112/20
154/20 154/22
Icall [4] 1/12
I came [2] 155/22
155/24
lean [11] 1/4 2/23
20/22 25/18 43/3 79/4
124/24 133/11 145/5
150/22 158/7
I can't [50] 8/23 9/1
19/24 21/16 28/10
29/21 31/9 35/20 40/2
42/3 44/9 50/3 51/12
53/18 57/11 73/2 74/9)
74/10 79/2 79/5 89/13
89/15 89/18 89/18
99/18 105/4 111/4
120/13 124/24 125/1
125/11 129/5 135/11
135/13 135/15 135/24}
136/9 136/10 155/5
155/7 155/22 156/1
163/3 163/25 168/4
168/5 168/10 168/10
168/12 169/20
I carried [3] 80/5
94/11 137/23
I chat [1] 50/13
I considered [1]
49/20
I could [3] 35/4
110/25 142/16
I created [1] 20/22
I did [30] 35/20 41/13
47/22 53/18 56/3 57/8
57/9 59/15 73/2 77/12,
84/5 96/2 120/11
121/7 121/23 125/1
135/3 135/7 135/11
135/13 135/24 136/6
136/12 153/10 153/11
153/21 154/13 155/5
157/1 160/16
I didn't [28] 33/17
40/9 49/25 53/8 53/22)
54/13 54/22 55/17
55/18 57/15 59/10
59/20 59/24 59/25
77/18 78/12 78/16
95/12 95/12 102/10
104/16 121/4 135/14
136/21 136/23 156/11
159/7 167/8
Ido [13] 2/25 3/22
5/3 32/14 32/22 46/16I
50/3 99/6 119/22
142/1 146/22 158/1
159/16
I don't [126] 7/4 7/7
8/22 9/6 12/25 13/16
13/20 14/18 14/18
15/15 16/9 17/19 18/1
19/20 19/20 20/7
20/10 21/17 23/5
24/20 29/20 30/12
30/15 30/19 31/5 31/9I
31/12 32/21 34/17
40/2 42/10 43/23 44/7
44/7 44/15 47/19
47/19 47/21 48/5 49/7
51/12 51/12 54/5 55/1
55/5 56/25 57/12
58/22 58/23 59/15
62/18 64/16 65/23
65/24 66/6 71/13
71/25 77/12 77/14
78/13 79/1 79/5 79/6
79/11 79/24 80/3 84/5I
89/11 89/12 90/18
92/4 92/5 92/22 93/5
99/16 101/24 101/25
110/20 110/24 112/6
112/9 112/25 119/5
119/14 120/11 120/16)
121/20 121/22 124/10)
128/19 128/23 133/11
133/17 133/20 135/24I
137/22 139/2 142/17
143/22 146/4 148/6
148/7 148/10 148/14
149/7 150/9 153/10
153/16 154/11 155/23)
156/25 158/7 161/14
162/22 163/11 163/12
163/19 164/7 164/19
164/20 165/16 165/17)
168/5 168/19 169/13
169/16
lever [5] 14/19 32/21
79/24 80/4 165/1
l examined [1] 58/2
I exhibit [1] 23/10
l extracted [1] 23/8
I feel [1] 41/23
first [1] 160/17
I fully [1] 99/17
I gained [2] 27/7
46/12
I get [1] 8/7
(64) heard... -I get
I got [4] 32/15 74/9
74/10 147/9
Ihad [22] 26/25 27/5
34/3 46/10 46/12
49/11 53/25 55/1
58/22 95/18 100/22
112/20 113/17 120/1
133/7 147/4 148/1
148/16 154/2 154/19
158/3 160/8
I hadn't [2] 111/13
153/25
Ihave [20] 4/5 4/16
30/18 44/19 67/19
69/1 72/14 74/5 85/17
85/20 85/24 109/2
109/9 113/9 115/9
115/12 118/20 127/12
144/3 169/7
I haven't [4] 101/24
I hiding [1] 166/23
I hold [4] 92/17
I honestly [3] 30/19
73/2 167/3
I hope [1] 153/10
lidentify [1] 112/11
interrupted [1]
93/25
I just [5] 35/21 41/19
77/16 97/12 161/8
I knew [8] 49/21
56/17 66/6 93/13
111/14 111/15 148/19
166/23
I know [11] 1/6 50/25
89/11 100/10 111/12
134/9 144/13 155/1
158/1 165/24 169/13
Ilearned [1] 135/21
Hook [1] 60/1
I looked [1] 94/16
I made [2] 94/15
111/15
I make [2] 109/18
111/8
I may [4] 53/19 53/19
54/11 155/6
I mean [27] 24/1
32/10 34/19 42/3
50/20 50/24 51/4 55/7
57/4 64/21 74/25 80/3
86/17 93/9 94/15
99/16 103/24 107/6
107/10 111/12 119/21
129/5 129/12 143/15
155/5 165/22 165/23
I meant [1] 60/13
I might [1] 164/11
I misinterpreted [1]
160/8
I need [1] 133/7
I needed [2] 54/12
54/22
I never [2] 79/23 80/3
I note [3] 60/15 60/21
95/3
I now [2] 4/11 4/19
lor [2] 33/2 33/6
I possibly [1] 72/24
I probably [1] 43/5
I produce [1] 68/18
I provide [1] 83/1
I provided [1] 41/14
I put [2] 110/11 129/5
Iread [3] 14/19 56/13
146/16
I recall [2] 31/23
46/18
I recommend [1]
142/2
I remember [5] 29/3
31/6 57/5 71/13
152/12
I remind [1] 2/3
I requested [2]
134/21 155/11
I required [1] 92/22
I responded [1]
102/11
I said [10] 56/13
105/11 111/11 112/7
120/23 136/10 149/9
160/18 163/6 169/20
I satisfied [1] 59/25
I saw [3] 49/7 49/7
59/10
I say [7] 46/11 50/14
50/24 105/8 111/3
125/13 166/1
I see [5] 97/4 99/8
124/3 129/6 160/19
I should [5] 19/12
51/5 67/10 74/4 75/10)
I shouldn't [1] 51/6
I sort [1] 34/4
I spoke [2] 101/25
111/13
I started [1] 89/11
I stated [2] 60/4
60/12
I still [2] 156/8 157/3
I summarise [1] 61/3
I supplied [3] 79/3
94/23 166/17
I suppose [2] 55/14
55/23
I take [3] 2/3 54/19
99/25
I then [2] 49/20 82/1
I therefore [1] 25/25
I think [49] 2/15 3/10
8/9 10/19 13/12 15/24
28/8 33/17 36/5 36/9
36/12 40/10 42/15
42/18 50/21 55/21
57/4 57/11 60/7 61/25
66/16 75/5 78/17
81/23 83/12 85/19
86/6 86/8 88/5 90/20
95/9 99/2 110/11
110/13 110/15 111/11
115/20 125/5 127/25
128/2 129/19 131/2
131/18 131/20 132/7
168/12
I thought [2] 46/20
160/9
I took [3] 34/18 44/15
160/14
Iturn [2] 24/24 51/25
l understand [3] 2/15)
97/13 170/4
I understood [4]
79/25 120/25 160/23
161/9
lused-on [1] 19/10
I want [2] 31/17
97/13
Iwas [54] 4/25 7/24
17/19 19/25 25/21
26/2 27/13 30/24
33/17 34/19 41/12
50/19 50/19 51/4 57/1
57/11 58/7 59/11
65/23 77/8 77/15
78/11 79/25 89/3
89/15 92/5 94/17
95/17 95/20 96/2
98/11 98/16 98/24
98/24 99/2 102/11
103/20 110/13 120/16
126/2 136/24 137/22
137/24 146/18 158/23}
158/24 160/15 160/15}
160/22 160/23 166/17
167/3 167/4 167/7
I wasn't [11] 14/20
54/18 54/22 56/10
57/8 57/9 121/14
121/15 157/4 161/8
168/13
I will [4] 2/12 40/21
77/24 100/22
I won't [1] 89/7
I wonder [4] 83/22
108/7 144/18 164/11
I would [63] 8/22
19/23 26/1 35/3 42/3
42/11 50/20 50/23
51/3 52/7 52/24 53/10)
53/23 55/6 55/13
56/16 56/25 57/3 58/7
59/2 60/14 60/22
60/24 61/16 61/21
63/12 72/22 77/1 77/2
77/3 89/4 94/10 96/15)
96/24 96/24 103/12
103/17 104/1 104/14
104/14 104/15 105/8
144/23 146/17 163/15}
107/7 107/7 120/4
121/4 121/21 122/3
130/23 133/9 135/14
135/17 136/5 139/2
140/4 142/14 143/15
153/7 155/23 156/2
156/2 158/14 164/6
I would've [1] 156/25
I wouldn't [5] 33/17
62/22 135/3 137/12
158/23
I wrote [1] 19/6
I'd [37] 31/12 53/4
53/5 53/22 56/2 56/11
56/14 59/4 64/18
64/22 77/14 89/12
103/13 103/17 103/18}
103/19 103/24 104/17}
105/9 120/4 120/23
121/5 128/6 128/20
135/3 135/14 136/6
137/13 142/12 143/23}
149/14 153/21 153/25)
154/11 154/12 166/1
166/2
Vl [10] 16/7 75/2
75/17 76/5 78/19 94/8
112/13 134/11 150/10}
155/3
I'm [78] 4/2 5/17 6/10
8/5 12/25 13/25 14/1
15/17 16/7 16/9 18/1
18/10 18/22 20/19
23/17 25/3 25/20 30/6
32/21 34/3 35/10
36/18 41/23 43/23
44/7 44/16 44/18
44/21 47/6 48/10
49/23 50/13 57/8 57/9
57/20 59/6 61/18 66/1
66/3 69/8 72/5 82/4
83/6 83/15 83/15 89/6
89/14 95/1 98/10
98/16 99/17 99/23
112/10 113/16 115/1
119/5 124/13 125/9
129/24 132/4 133/8
135/5 137/8 143/22
147/10 150/10 151/16
152/20 154/14 156/25}
159/10 162/19 163/5
165/1 165/2 168/19
57/14 61/25 64/12
65/23 68/11 75/24
77/2 80/3 87/12 98/3
100/7 112/12 118/11
119/16 133/14 134/22)
135/6 149/8 155/12
160/2 160/7 160/7
163/2 167/13 169/13
169/7 170/2 4/19 41/13 43/8
I've [35] 3/19 10/1 I 120/21
20/13 21/8 21/9 23/18] implying [2] 64/8
29/25 49/10 57/4 167/6
169/21
IDE [1] 105/41
idea [11] 10/1 21/9
29/25 30/18 32/17
33/14 65/18 65/23
149/8 169/8 169/21
identical [1] 159/21
identified [3] 37/4
54/4 134/15
identifies [1] 100/17
identify [3] 53/13
112/11 161/23
identifying [1] 12/12
ie [17] 12/13 25/1
26/12 39/3 44/23 49/2
52/19 56/19 58/20
60/8 64/2 71/15 76/24I
87/3 109/4 112/15
119/3
ie as [1] 39/3
ie every [1] 60/8
ie extracting [1]
26/12
ie first [1] 87/3
ie give [1] 44/23
ie Mr Hosi's [1]
109/4
ie nearly [1] 76/24
ie the [1] 25/1
ie they [1] 49/2
ie unless [1] 112/15
ie what [2] 52/19
58/20
ie whether [3] 56/19
71/15 119/3
ie which [1] 12/13
if [230]
ignore [2] 100/24
135/14
ignored [2] 38/23
135/3
illuminate [2] 133/19
153/14
imbalance [2] 39/2
123/23
immediately [1] 2/11
impact [13] 34/15
52/7 57/23 58/5 58/12
58/15 58/19 58/25
59/5 59/8 119/7 119/9I
120/20
implications [5] 4/8
important [3] 13/15
22/24 85/12
impossible [1] 77/22
impression [1] 32/15
imprisonment [1]
36/25
improper [7] 92/12
94/14 96/18 97/23
(65) I got - improper
I
improper... [3] 99/2
110/6 162/3
improperly [1] 95/18
improved [1] 99/13
inaccurate [6] 92/12
94/13 97/16 97/22
110/5 162/3
Incidentally [1] 90/5
include [12] 11/21
11/24 13/4 13/17
13/23 68/1 76/15
76/17 93/1 110/21
111/20 112/18
included [14] 14/4
16/1 74/22 85/1 88/24
93/21 95/3 95/15 96/7,
110/14 110/22 111/8
114/4 120/15
includes [2] 79/11
111/18
including [6] 4/7 4/17
67/16 115/24 126/12
145/13
inconclusive [1] 38/5
incorporated [1] 76/4I
incorrect [1] 123/8
incriminate [2] 1/25
2/10
incrimination [1] 2/2
indeed [4] 91/2
144/16 152/7 157/6
indexing [1] 106/12
indicate [6] 4/5 4/16
28/9 38/10 101/19
139/16
indicated [1] 134/18
indication [2] 106/1
141/21
indictment [1] 38/10
individual [5] 11/5
79/17 79/23 79/24
94/16
infer [1] 38/4
inflated [1] 37/20
influenced [1] 73/13
influencing [1] 87/8
informal [1] 19/1
information [47] 7/9
10/25 11/25 15/8
21/10 21/13 53/15
68/11 71/12 71/17
71/18 72/23 74/8
74/10 74/12 75/25
76/18 77/20 79/20
80/9 81/4 81/7 81/20
84/22 85/17 85/20
85/22 86/10 92/11
92/17 94/13 96/5
97/15 97/21 110/5
115/10 124/14 142/5
154/15 154/21 155/25)
158/16 162/2 162/8
166/22 166/24 169/8
informed [1] 166/2
infrequent [1] 30/6
infrequently [2] 30/3
30/16
initially [2] 133/5
157/25
initiative [2] 19/22
19/25
input [1] 28/24
inquiry [19] 1/17 1/21
1/22 2/16 3/8 13/21
19/11 27/18 40/4
46/25 90/6 90/8 94/19
94/20 121/8 145/13
145/24 151/21 167/21
insert [2] 69/10 117/4
instance [2] 71/6
106/18
instead [6] 20/16
21/1 45/14 49/3 50/13
99/25
instigate [1] 158/6
instigated [4] 162/24
163/1 163/2 163/25
instructed [3] 39/5
39/10 167/15
instructing [1] 43/12
instruction [8] 18/20
19/6 20/1 21/12 24/8
24/11 24/12 24/16
instructions [15]
19/1 19/5 19/9 19/14
20/6 20/9 20/17 20/23
21/2 21/3 21/6 21/16
23/13 24/20 124/25
integrity [26] 12/1
16/24 17/3 24/6 52/7
52/16 57/23 58/12
58/15 58/19 58/25
59/9 59/14 59/19
59/23 63/19 94/3 94/6
107/20 107/23 108/1
135/18 135/20 136/3
146/8 147/1
intended [4] 87/13
114/23 139/17 141/4
intensive [1] 105/24
intention [1] 147/25
interacting [1] 46/16
interest [1] 76/14
internal [1] 9/15
interrogate [3] 26/19
26/23 120/3
interrupt [1] 30/4
interrupted [2] 3/7
93/25
interruption [1]
106/12
interview [1] 37/14
interviewed [1] 37/7
interviews [1] 38/20
into [26] 5/11 15/3
21/12 22/24 23/3
23/18 34/23 36/8
41/24 43/10 52/1
59/22 63/1 77/14 78/6
87/1 100/8 103/14
108/19 138/24 139/21
152/16 159/2 159/4
159/25 168/17
intranet [1] 9/2
investigate [3]
116/21 137/17 154/19]
investigated [14]
56/15 134/10 138/21
138/22 139/19 141/6
143/4 143/17 144/3
155/1 156/6 156/21
159/3 166/20
investigating [2]
26/3 27/6
investigation [27]
40/1 40/6 49/8 52/24
53/2 53/2 55/17 59/24
61/24 62/2 63/12
94/11 103/13 103/15
103/16 103/17 116/19}
123/13 125/16 133/14
137/20 142/3 143/9
143/14 144/8 152/5
152/16
investigations [7]
43/21 58/3 123/20
125/21 135/22 136/23}
156/23
investigative [1]
137/23
Investigator [3] 71/2
75/8 103/8
Investigators [3]
37/8 37/8 38/1
involve [3] 63/19
64/4 64/9
involved [12] 43/5
61/9 61/12 89/3 89/5
89/8 89/15 109/22
153/11 166/1 166/1
168/13
involvement [2]
133/6 158/2
involves [2] 116/8
116/12
irrespective [4]
62/25 63/6 119/8
119/25
is [278]
isn't [15] 1/5 16/6
23/11 55/8 63/24
74/18 110/7 123/25
126/4 129/10 130/13
137/4 146/14 148/12
150/7
isolated [1] 133/24
issue [40] 2/19 24/24
31/14 47/8 51/25
52/16 55/25 58/1
60/23 61/23 62/2 63/9
63/13 64/4 64/9 64/14
69/24 77/13 87/10
99/9 103/3 115/2
116/7 116/10 116/15
116/17 116/20 116/20
116/24 119/14 121/21
138/15 138/24 139/1
139/3 139/18 139/20
140/1 144/4 144/6
issued [1] 7/9
issues [16] 5/20 6/3
52/8 52/11 54/1 56/19
58/8 58/10 60/25 62/4I
64/2 74/2 107/23
108/1 115/18 119/4
it [441]
it'll [2] 6/15 18/14
it's [82] 3/9 3/10 4/2
13/15 14/18 22/16
25/19 30/5 36/8 36/14
36/15 36/19 49/5
49/19 57/24 62/25
66/15 68/7 73/4 75/10
82/7 82/8 83/24 87/17,
87/18 90/3 91/2 93/17)
94/1 97/3 101/4 101/5
104/19 107/13 107/14
107/18 110/9 110/15
110/15 116/6 116/15
117/9 120/7 122/5
124/3 124/4 125/8
128/18 129/8 129/10
129/10 129/25 130/8
130/12 132/10 132/10
133/2 135/13 138/15
138/19 138/22 138/23}
138/23 139/2 139/3
139/4 139/18 139/20
141/6 144/10 146/7
149/23 149/23 149/25)
150/16 150/16 150/17,
154/12 155/14 160/13
160/14 169/11
items [1] 133/22
iteration [1] 14/2
its [12] 17/7 41/6
62/3 62/4 80/9 80/12
81/5 81/21 83/7
102/17 139/6 167/18
itself [5] 67/3 94/5
104/11 121/18 129/21
J
Jan [4] 8/7 8/11 8/15
90/16
January [14] 23/8
81/10 82/21 85/23
100/3 101/1 101/2
117/2 132/9 132/11
132/24 133/2 142/20
150/21
Jason [1] 1/16
Jenkins [11] 39/10
47/24 48/1 132/19
133/4 134/13 149/17
159/20 161/13 161/23)
164/12
Jerry [5] 36/6 67/11
84/2 108/20 109/5
job [1] 144/10
jobs [1] 8/2
joined [4] 92/4
joke [2] 148/3 148/10
joking [2] 148/6
148/7
Jon [7] 75/24 76/5
76/7 78/1 79/12 80/24I
80/25
Josephine [4] 99/21
100/5 101/2 104/12
JSA [1] 141/10
JSimpkins [1] 122/4
JSimpkins338Q [2]
117/9 121/25
judgment [1] 36/13
July [5] 1/1 36/2 41/8
127/4 127/10
July '07 [1] 127/10
jumping [1] 128/23
June [18] 41/9 75/10
75/12 79/9 84/25 85/5
85/7 85/23 108/23
113/22 113/24 126/9
126/21 127/1 127/6
127/15 130/20 131/2
jury [1] 100/12
just [103] 7/3 8/10
9/12 10/7 10/16 11/21
12/16 16/14 20/13
21/8 27/24 28/3 28/14I
28/15 30/7 32/19
35/21 36/14 36/18
41/10 41/19 41/23
42/6 42/13 43/6 46/11
47/6 53/14 55/13 60/6)
62/19 63/15 65/3 65/5
65/11 65/23 66/3
66/19 66/20 67/8
67/25 71/20 73/17
75/5 76/22 77/8 77/15
77/16 78/11 79/6
80/11 80/14 80/22
81/12 81/15 82/7
82/15 85/1 85/7 86/9
87/2 87/16 88/6 91/10I
91/11 91/15 95/5
95/13 97/12 98/2
98/14 100/3 100/23
102/2 102/18 109/15
112/17 128/21 132/4
132/19 133/5 135/3
140/25 141/23 142/12)
142/23 147/10 147/25)
149/20 150/16 153/6
156/14 156/20 157/25)
158/12 159/11 160/15)
160/24 161/8 161/23
164/11 164/12 169/18)
(66) improper... - just
J
justice [1] 39/20
K
keep [13] 14/14 21/2
43/7 66/20 66/21
79/10 81/6 133/11
134/12 140/24 141/19)
158/7 158/12
keeps [2] 169/17
169/17
KEL [12] 101/13
104/21 104/23 106/7
117/10 118/6 120/9
120/14 121/25 122/4
122/5 167/2
KELs [15] 103/24
103/25 104/2 104/15
104/18 105/23 107/3
120/3 120/4 120/6
120/12 121/2 131/17
166/21 166/25
kept [2] 15/10 62/19
Kevin [1] 101/17
key [2] 20/24 21/1
keyboard [1] 117/21
kind [8] 7/14 9/9 9/25
27/19 44/10 47/9 147/3
164/2
kit [1] 140/14
KMRX [1] 118/8
knew [14] 49/21
56/17 66/6 71/10
79/23 79/24 80/4
93/13 98/21 111/14
111/15 148/19 166/23
167/2
know [112] 1/6 3/22
8/22 9/23 12/25 13/1
19/20 19/20 20/10
29/20 30/15 31/5 31/9
31/12 32/21 36/5 40/2
41/25 43/1 44/7 44/7
44/15 50/25 54/14
55/1 55/5 55/7 55/10
55/16 55/17 55/19
56/6 56/25 57/12
62/15 62/20 63/1 63/4
63/10 63/17 65/15
65/23 65/24 68/7 71/9
71/25 75/17 77/14
79/5 80/15 82/10 88/3,
89/11 89/11 89/12
91/25 92/4 92/22 93/4
93/12 94/8 98/15
99/16 100/10 101/25
110/20 110/24 111/12)
112/6 112/25 115/17
115/21 119/5 119/12
119/14 119/23 120/16}
121/13 128/19 131/13)
133/17 133/20 134/9
135/9 135/24 139/2
142/6 143/22 144/13
149/7 150/9 153/16
154/11 155/1 155/23
157/1 158/1 159/1
162/9 163/16 164/7
164/19 164/20 164/21
165/24 168/10 168/21
169/13 169/16
knowing [1] 133/9
knowledge [55] 5/13
27/1 27/2 27/5 27/7
43/19 44/19 45/15
46/3 46/12 47/10
47/16 48/22 49/13
49/15 49/19 52/9
53/14 55/7 56/3 56/8
56/12 56/14 56/16
57/16 58/9 74/6 74/15
77/4 91/22 92/13
93/10 105/9 105/10
109/19 111/9 111/12
111/15 111/19 111/24}
112/4 112/11 112/21
113/2 113/16 118/21
120/1 120/19 121/7
143/23 162/4
known [12] 1/25
63/12 101/13 104/8
104/11 105/12 107/10)
117/8 121/21 124/4
154/8 166/14
label [1] 131/6
lack [3] 37/17 47/8
47/15
Laking [1] 90/16
Lane [1] 146/3
language [1] 17/21
large [2] 31/6 167/15
last [10] 3/6 5/7 5/21
17/13 52/17 82/16
87/2 113/25 140/13
141/23
lastly [1] 12/8
later [17] 33/5 69/8
76/5 76/18 78/5 85/10)
98/20 99/14 100/11
100/20 113/22 119/6
125/10 139/24 159/17,
161/3 170/5
law [1] 1/20
lawyer [1] 71/3
lawyers [9] 2/8 2/16
2/22 57/10 57/13
70/16 72/1 132/13
163/18
lay [1] 152/6
layout [2] 11/10
91/19
lead [2] 105/20
122/13
165/16 165/17 165/19)
11/13 11/18 25/4 25/7)
leading [1] 142/18
leap [1] 90/7
learned [1] 135/21
learnt [1] 112/12
least [6] 44/10 83/9
106/25 124/2 151/20
156/3
led [2] 149/5 166/13
Lee [3] 46/21 66/12
146/1
left [4] 62/15 111/6
127/7 127/15
left-hand [2] 127/7
127/15
legal [7] 1/6 1/23
1/25 40/22 47/12 57/7I
159/25
Leighton [1] 82/1
less [1] 29/21
let [6] 68/7 75/17
76/5 116/1 131/13
142/6
let's [11] 23/3 40/15
78/3 145/23 147/2
149/12 153/12 154/24
155/9 157/23 161/22
letter [4] 13/12 14/8
14/15 91/13
letters [1] 14/16
letting [1] 50/12
level [19] 7/12 7/24
8/4 10/1 10/4 12/25
52/20 65/21 71/4
73/20 73/22 73/23
73/24 79/20 80/7 87/3
118/13 165/5 169/8
library [1] 9/2
light [3] 48/23 76/8
135/25
like [30] 8/14 15/16
17/20 18/1 21/8 33/14
43/14 49/25 71/13
120/2 125/13 130/23
131/22 134/25 135/3
135/14 136/6 139/20
149/14 151/1 151/1
153/21 154/6 154/12
155/15 158/7 160/1
165/22 166/2 168/14
likely [5] 46/21 54/8
60/22 106/10 106/11
limited [5] 25/3 25/7
26/16 26/17 96/17
line [29] 4/24 8/3
57/1 68/1 68/10 69/9
97/11 101/11 103/2
1114/7 111/18 112/3
112/5 127/22 148/5
148/9 149/25 159/15
160/5 160/8 160/10
160/12 160/13 160/14
160/23 160/25 161/5
166/10 167/6
liner [1] 150/17
lines [13] 12/17
28/22 42/12 45/23
46/4 49/7 49/8 85/16
106/22 108/25 109/21
127/11 141/24
linked [2] 134/11
155/3
Lisa [6] 36/1 39/24
39/25 67/10 126/11
127/5
list [4] 88/18
listed [5] 11/17 12/20
12/24 15/22 57/4
listen [1] 48/10
literature [1] 49/9
litigation [12] 4/25
8/6 15/7 16/11 18/17
46/17 97/3 148/3
159/12 160/3 166/3
166/11
little [12] 7/3 7/17
73/17 80/22 82/17
108/24 108/24 132/24}
140/11 142/22 164/11
170/5
lives [1] 34/16
local [13] 18/20 19/1
19/5 19/6 19/9 19/14
20/6 20/9 20/17 21/3
21/5 21/12 21/16
lock [5] 117/5 121/9
122/10 133/24 134/6
log [14] 4/7 4/18
22/16 47/21 52/20
53/17 67/2 69/16 76/1
101/13 102/5 107/10
117/9 121/24
logged [12] 68/12
75/16 83/2 85/22
101/12 117/8 118/5
129/2 131/5 134/2
134/18 156/1
logs [30] 3/22 17/12
38/14 48/2 48/17 52/1
59/8 64/23 64/25
65/12 66/24 67/22
68/22 70/24 83/16
83/17 87/2 104/8
104/11 105/13 109/25
110/19 120/7 121/3
123/22 125/17 131/25}
134/14 134/19 166/14}
London [1] 51/2
long [8] 3/10 4/3
42/24 89/12 119/2
119/14 127/11 135/13}
longer [2] 43/4 50/8
Longman [7] 75/25
78/1 78/18 79/12
80/24 82/17 132/12
Longman's [1] 76/12
look [92] 3/17 6/14
7/3 TIT 13/11 14/2
16/19 25/14 25/16
28/1 28/14 28/15 30/7
30/8 31/20 35/23
35/24 36/12 36/17
50/11 52/1 52/25
57/21 57/24 60/1 65/8
66/10 67/8 67/9 67/9
68/7 68/8 70/11 72/12I
72/12 75/2 75/15 79/8)
80/21 82/15 85/4
87/13 90/19 91/16
97/1 100/2 100/25
101/3 101/4 102/12
104/22 106/6 107/25
108/21 110/9 113/7
113/23 114/7 114/8
1414/8 117/1 117/12
120/6 122/4 126/8
126/25 127/8 131/3
131/17 132/5 132/8
132/17 136/14 138/1
138/3 138/24 139/21
140/23 141/7 142/21
143/5 145/23 147/2
149/20 150/2 153/12
154/12 154/15 156/14)
159/2 159/4 161/22
looked [33] 7/25
15/16 29/5 36/9 36/20
44/1 64/18 71/22
72/13 77/2 77/3 90/4
94/16 95/5 103/19
103/21 103/24 103/25)
104/14 107/9 108/17
110/3 119/14 120/4
120/4 122/2 124/21
134/14 136/5 137/13
142/23 166/20 166/20}
looking [21] 3/15
9/13 26/1 27/6 35/24
53/7 93/15 98/23
103/5 103/13 104/21
108/17 108/18 125/9
129/5 136/8 136/13
136/24 137/14 139/2
149/13
looks [5] 75/24
139/20 151/1 151/10
151/16
loss [5] 141/10
141/11 141/13 141/15)
141/16
losses [7] 37/17
37/19 37/21 37/22
63/6 140/20 143/1
lot [10] 20/12 53/22
53/23 53/25 76/20
77/16 78/15 126/4
128/2 128/2
lots [4] 54/1 90/8
115/25 115/25
low [1] 39/3
Lowther [2] 7/24
148/20
loyal [3] 145/15
(67) justice - loyal
L
loyal... [2] 145/17
146/11
loyalty [4] 165/11
165/12 166/12 166/13
lunch [1] 108/6
Machin [1] 82/1
machine [1] 62/20
made [27] 11/7 13/1
17/19 25/22 27/9
30/25 37/1 38/15
42/15 54/11 56/11
57/8 60/14 60/16 64/1
64/7 74/6 77/16 80/17,
93/14 94/10 94/15
100/5 100/7 111/15
118/21 132/7
main [4] 20/23 31/23
32/6 32/11
maintain [1] 146/7
make [36] 1/8 3/11
3/24 4/4 4/13 27/8
37/12 41/19 43/15
52/19 54/9 54/13
54/14 56/5 56/21 78/9
97/13 100/11 100/14
100/22 103/20 109/18
109/24 111/8 111/17
111/22 113/15 114/7
115/12 148/25 151/13}
152/24 154/1 164/17
167/1 169/6
makes [2] 113/1
152/4
making [7] 23/16
27/14 33/9 113/17
116/22 136/1 169/25
man [4] 145/18
145/19 148/4 149/5
manage [3] 6/23 8/19
90/13
managed [1] 34/4
management [9]
6/17 20/24 21/1 56/25
57/1 101/11 101/12
166/10 166/10
manager [26] 8/3 8/4
8/6 8/12 8/15 18/17
18/19 19/25 20/4 20/8
40/1 40/6 42/17 50/11
87/20 87/22 87/23
87/25 89/4 90/16
90/25 133/11 148/2
158/6 166/11 166/11
managers [3] 20/6
57/3 57/16
managing [1] 166/3
mandatory [1] 7/8
manifestations [1]
124/22
manipulate [1] 95/19
manual [3] 101/17
102/16 102/21
many [16] 13/1 13/1
18/24 20/23 20/23
30/17 31/4 31/7 51/1
63/8 78/24 162/10
162/14 162/14 163/21
166/18
March [8] 3/6 27/24
28/22 82/18 82/25
83/5 97/3 143/2
marker [1] 150/18
Martin [2] 88/14 89/1
master [1] 44/23
material [9] 10/25
38/13 39/8 65/16 76/3
92/14 99/10 130/12
162/5
material’ [1] 17/5
materials [2] 65/1
65/7
maths [2] 77/3 77/17
matter [8] 1/18
129/22 129/25 130/5
130/11 130/18 146/8
146/12
matters [11] 11/16
11/20 11/23 12/12
12/19 15/21 44/19
57/14 128/11 156/5
159/3
may [43] 3/10 5/2 5/5
5/23 16/25 17/4 19/8
20/8 34/15 38/9 47/8
53/19 53/19 54/11
54/11 63/13 76/1 76/6
76/20 82/5 105/20
106/19 107/19 121/21
122/7 122/14 124/2
130/25 131/2 131/3
133/16 133/19 133/21
141/25 153/13 153/17,
155/6 155/7 155/15
155/24 155/25 163/17)
169/11
May '06 [1] 133/16
maybe [6] 15/24
69/19 78/5 79/4 81/13
155/24
McCall [1] 170/5
me [46] 1/7 1/9 1/23
2/6 2/8 2/10 2/23 4/7
4/18 18/10 19/11 41/8)
41/10 46/11 46/25
52/9 53/11 53/15 58/9)
58/23 68/7 71/21
75/17 75/24 79/19
100/14 103/22 110/13)
116/1 131/4 131/13
131/19 142/6 146/16
146/25 147/10 148/18)
149/9 149/10 154/12
155/7 158/15 158/16
160/22 165/8 167/15
mean [49] 24/1 24/2
24/4 32/10 34/19
35/10 42/3 49/5 50/20)
50/24 51/2 51/4 53/16
55/7 57/4 64/14 64/21
74/20 74/25 80/3
85/19 86/6 86/17
87/13 93/9 94/15 96/9
96/13 96/14 97/18
99/4 99/16 103/24
107/6 107/10 111/10
111/12 112/9 119/21
129/5 129/12 143/15
147/8 153/24 155/5
156/11 161/19 165/22
165/23
meaning [6] 98/11
98/16 99/2 99/12
99/14 164/6
means [8] 22/13
22/16 43/1 100/16
105/3 105/5 144/21
150/19
meant [16] 7/13
23/24 27/3 48/17
60/13 87/12 96/9
98/15 98/19 98/21
99/10 105/9 160/8
160/9 164/13 164/14
mechanical [1] 26/11
medium [1] 73/24
member [3] 29/6
47/4 158/10
memory [2] 30/18
99/13
men [1] 79/13
mention [3] 76/13
121/14 131/8
mentioned [9] 53/17
76/10 104/2 120/7
121/20 121/24 128/11
150/22 161/4
mess [2] 140/23
143/6
message [13] 42/24
43/4 106/3 106/10
117/4 123/14 123/15
124/15 124/17 130/16
133/18 134/9 154/25
messages [3] 122/9
133/25 134/6
messagestore [1]
123/13
Microsoft [2] 167/24
168/8
mid [2] 75/3 84/18
mid-2009 [2] 75/3
84/18
middle [3] 90/21
101/5 153/14
might [11] 2/10 6/2
51/15 52/15 55/25
64/14 65/21 121/18
134/25 144/19 164/11
Mik [6] 46/24 47/1
50/4 50/11 157/8
157/14
Miletic [1] 97/10
mind [7] 17/14 34/24
36/19 65/15 94/5
137/18 160/4
mindset [1] 146/14
mine [1] 13/15
minor [1] 100/7
minute [1] 144/19
minutes [5] 138/14
139/23 140/11 145/7
145/8
misinterpreted [1]
160/8
mislaid [1] 67/18
misleading [3]
152/25 160/14 160/20)
Misra [18] 48/1 48/3
70/10 70/14 70/18
75/4 75/12 80/20
108/20 131/22 132/8
136/19 138/8 138/25
139/23 140/7 145/14
149/12
Misra's [3] 83/9
84/18 132/6
missed [1] 83/23
missing [3] 38/22
38/25 123/9
Mitchell [1] 8/2
Mm [10] 9/11 13/2
34/22 68/3 75/22 83/8
88/25 115/23 130/3
152/14
Mm-hm [10] 9/44
13/2 34/22 68/3 75/22,
83/8 88/25 115/23
130/3 152/14
Mmm [1] 146/13
mobile [1] 51/1
moment [8] 1/6 14/3
18/23 24/14 25/20
57/6 83/21 108/6
Monday [2] 23/8
100/22
money [6] 37/12
37/22 38/22 38/25
140/15 169/17
month [9] 28/23
29/16 29/18 31/8
31/10 76/21 76/24
78/7 86/1
months [3] 31/11
37/9 38/9
months' [1] 36/25
mop [1] 102/4
more [41] 3/14 14/12
14/15 28/15 29/20
33/18 46/21 50/2 51/9)
54/8 70/14 70/15
70/18 71/12 71/17
71/18 71/19 80/22
81/7 84/21 86/10
98/22 106/2 106/11
108/21 117/24 123/18)
124/19 129/10 133/8
135/23 139/6 146/5
148/15 149/9 154/21
158/1 164/11 165/8
168/1 169/17
morning [16] 1/3
1/16 41/5 51/22
108/18 108/20 110/3
110/11 114/13 115/20)
123/1 125/6 125/7
130/22 134/23 155/13)
most [3] 5/22 100/13
4111/2
mother [1] 106/2
motivating [1] 87/7
move [10] 16/19 75/2
82/14 108/17 113/20
130/24 132/5 168/9
168/22 169/4
moved [2] 168/4
169/14
moving [2] 168/23
169/17
Mr [111] 1/5 1/8 1/15
1/16 1/20 2/24 3/2 3/4
15/24 17/22 18/23
25/20 36/6 36/11
36/16 36/19 36/23
37/4 37/14 37/25
38/10 38/15 38/21
39/19 39/22 41/25
43/2 43/6 43/15 44/11
47/14 47/24 48/1 51/7)
51/25 55/2 61/18 64/3
70/6 72/11 75/13
76/12 78/18 82/17
83/24 83/25 84/2
84/17 86/22 87/18
87/18 87/19 88/13
90/16 91/2 97/10
100/4 100/5 101/18
108/16 109/4 124/21
125/15 127/3 132/12
133/4 135/23 144/15
145/8 145/12 145/14
145/15 146/2 146/15
146/24 147/8 147/9
147/20 147/22 148/12)
149/6 149/13 154/14
155/17 156/10 156/19}
157/23 159/1 159/12
159/20 161/13 161/23)
161/25 162/21 163/6
164/12 164/18 165/5
165/11 166/6 166/12
167/11 167/12 167/13)
169/22 169/23 169/25]
170/4 170/5 171/4
171/18
MR BEER [7] 1/15
3/2 149/13 161/25
(68) loyal... - MR BEER
MR BEER... [3]
169/23 170/4 171/4
Mr Budd [3] 41/25
43/15 44/11
Mr Budd's [1] 43/6
Mr Castleton [1]
145/14
Mr Castleton's [1]
70/6
Mr Defendant [1]
64/3
Mr Dunks [42] 1/5
15/24 18/23 25/20
51/25 55/2 61/18
83/24 108/16 124/21
125/15 135/23 144/15)
145/12 145/15 146/15
146/24 147/8 147/20
147/22 148/12 154/14)
155/17 156/10 156/19
157/23 159/12 162/21
163/6 164/18 165/5
165/11 166/6 166/12
167/13 169/22 169/25
Mr Hooper [3] 87/18
88/13 90/16
Mr Hosi [7] 36/16
37/14 37/25 38/10
38/15 38/21 39/19
Mr Hosi's [8] 36/11
36/19 37/4 39/22
72/11 83/25 86/22
127/13
Mr Jenkins [6] 48/1
133/4 159/20 161/13
161/23 164/12
Mr Jerry [2] 36/6
84/2
Mr Longman [3]
78/18 82/17 132/12
Mr Longman's [1]
76/12
Mr McCall [1] 170/5
Mr Miletic [1] 97/10
Mr Peach [4] 47/14
47/24 51/7 159/1
Mr Posnett [2] 75/13
87/18
Mr Sewell [3] 43/2
147/9 149/6
Mr Sewell's [1] 146/2
Mr Stein [3] 167/11
167/12 171/8
Mr Ward [5] 87/19
91/2 100/4 100/5
101/18
Mr X [1] 17/22
Mrs [13] 64/3 83/9
99/21 138/8 138/25
145/14 149/12 155/19)
156/19 157/23 158/17
1/8 1/16 1/20 2/24 3/4}
159/1 159/4
Mrs Chambers [5]
159/1 159/4
Mrs Chambers’ [1]
157/23
Mrs Defendant [1]
64/3
Mrs Josephine [1]
99/21
Mrs Misra [4] 138/8
Mrs Misra's [1] 83/9
Ms [21] 17/22 31/23
32/1 32/20 33/4 33/9
40/15 40/23 43/15
46/23 69/10 127/21
133/4 145/8 145/11
151/2 158/25 163/15
164/9 167/10 171/6
Ms Allan [1] 40/23
Ms Allen [3] 40/15
69/10 127/21
Ms Bains [6] 31/23
32/1 32/20 33/4 33/9
43/15
Ms Chambers [2]
46/23 133/4
Ms Page [3] 163/15
164/9 167/10
158/25
Ms Y [1] 17/22
much [14] 3/1 4/22
5/15 8/17 36/20 42/23
72/23 77/5 84/10
91/15 108/10 144/15
145/6 145/20
multi [2] 106/23
123/1
MULTI-COUNTER [1]
106/23
multiple [2] 124/7
125/25
Munro [1] 57/5
must [12] 2/10 2/22
22/16 22/9 63/5 69/24
85/19 86/6 106/23
106/24 116/24 163/14)
mustn't [1] 167/5
MWright1245K [1]
118/6
my [98] 1/16 19/24
20/22 20/23 21/17
23/10 23/18 27/5 34/4
34/17 35/3 35/21
41/15 41/18 41/20
41/24 42/4 46/22
47/20 49/12 49/13
50/3 52/5 56/14 56/25
57/3 57/6 59/10 59/24
59/24 69/6 72/17 74/5)
75/25 76/9 77/3 77/5
T7IT 78/16 83/24
155/19 156/19 158/17)
138/25 145/14 149/12)
Ms Thomas [2] 151/2!
92/13 93/9 94/7 94/10
94/15 94/15 94/17
95/17 99/19 107/6
107/21 109/13 109/18
109/23 111/9 114/11
114/15 141/18 112/14
112/16 112/21 113/12
113/16 113/18 118/19]
120/16 120/23 124/11
125/14 125/20 126/1
127/17 128/9 130/7
133/6 133/11 135/21
137/13 137/25 143/14
143/22 149/10 149/10
150/21 153/1 154/21
156/17 157/4 158/2
158/6 158/16 160/13
160/14 160/17 161/2
162/4 165/12 167/9
myself [10] 8/5 27/7
58/11 58/22 59/3 59/4
59/25 126/2 135/17
147/23
N
name [17] 1/16 3/4
5/5 7/5 7/8 15/1 17/23
28/13 28/21 32/4 57/2
145/21 146/7 146/23
149/2 150/8 151/6
namely [2] 87/10
99/10
names [2] 7/18 57/2
nasty [3] 146/6
146/20 149/1
nature [28] 52/11
58/10 60/9 61/2 61/6
63/19 63/22 63/25
64/8 64/11 64/15 69/4
72/16 76/16 86/2
109/11 113/10 116/2
127/13 129/12 129/14
129/18 142/8 143/12
143/15 150/24 151/4
152/2
nature’ [2] 60/5 60/13
NBSC [56] 38/14
60/22 61/1 61/5 61/10
61/16 62/6 62/9 62/13,
62/14 63/2 63/4 63/15)
63/23 69/17 69/21
69/23 70/1 114/14
114/19 115/2 115/8
115/11 115/21 115/22
116/1 116/6 116/17
116/23 119/23 138/15}
138/23 138/25 139/1
139/3 139/3 139/4
139/5 139/19 140/1
140/2 140/17 140/22
141/2 141/6 141/9
141/11 141/15 142/2
142/25 143/5 143/8
144/3 144/3 144/5
144/9
nearly [1] 76/24
need [22] 10/15
13/23 17/25 40/20
42/15 44/12 63/16
71/24 76/1 77/24
82/20 85/8 90/5 133/7,
137/2 137/15 137/19
153/3 156/5 156/16
159/3 160/4
needed [23] 9/8
12/13 12/24 16/13
38/12 54/12 54/19
54/22 56/4 61/25
63/12 78/5 116/18
117/23 128/3 154/15
156/18 156/20 157/3
166/17
needs [3] 137/8
152/15 153/12
Neither [1] 158/25
Neneh [3] 7/24 8/5
148/20
nervous [3] 32/16
32/23 33/14
Network [4] 6/16
6/23 89/25 90/13
never [17] 17/14
25/10 56/10 63/9
79/23 80/3 80/3 80/9
111/19 112/16 113/3
115/12 160/2 160/4
167/3 167/4 167/7
new [15] 41/8 41/15
101/7 114/11 117/3
126/16 127/21 166/5
167/22 167/23 168/11
168/16 168/17 168/25}
169/1
newer [1] 168/3
next [4] 91/11 103/2
140/12 140/12
night [1] 122/9
no [287]
nodding [1] 152/19
node [4] 122/17
122/19 154/25 154/25}
none [6] 19/9 31/10
34/12 87/9 129/3
169/9
nor [2] 86/6 158/25
normal [12] 69/5
72/17 86/3 109/12
113/11 114/24 116/3
117/17 127/13 129/20}
130/1 142/9
normally [1] 142/14
not [199]
notable [1] 134/5
note [5] 39/8 60/15
60/21 88/6 95/3
notes [1] 54/11
nothing [10] 59/21
154/21 154/23 155/19)
123/21 138/19 139/8
143/20 144/13 154/17)
155/18 156/10 157/3
notice [3] 85/6 88/11
1341/7
noting [1] 95/7
November [4] 36/22
38/7 90/3 114/9
now [32] 2/15 4/5
4/11 4/16 4/19 5/4
15/15 36/5 41/18
43/12 46/20 76/4
76/17 81/24 82/18
98/20 98/23 105/4
114/1 130/24 139/2
144/10 145/19 149/20)
150/5 152/22 153/8
160/11 160/19 162/9
164/6 169/1
NT [8] 73/20 101/8
105/1 118/2 119/7
121/18 167/24 168/8
number [25] 7/18
13/11 13/11 13/17
13/21 28/4 32/10
69/14 77/2 78/10
78/12 78/25 80/2 85/2
86/9 86/14 101/16
114/9 117/1 117/13
134/15 142/23 151/15)
153/3 167/16
Number 10 [1]
117/13
number 29 [1]
142/23
number 3 [1] 114/9
number 8 [1] 117/1
numbers [1] 143/23
numerous [1] 38/15
oO
oath [1] 98/18
objection [2] 2/12
2/13
obtained [2] 38/6
38/17
obtaining [2] 21/21
33/25
obviate [1] 10/14
obviously [2] 132/10
147/13
occasion [9] 5/21
25/19 25/21 30/24
31/1 72/25 104/13
124/23 166/18
occasions [3] 137/6
163/7 163/15
occur [6] 46/3 49/22
66/1 106/19 106/20
170/8
occurred [7] 73/25
101/8 117/4 117/5
118/2 118/16 119/7
occurring [5] 37/17
(5!
9) MR BEER... - occurring
[e)
occurring... [4]
154/9
occurs [1] 106/13
October [1] 36/14
odd [1] 79/16
off [26] 16/14 19/24
20/19 45/19 50/11
50/15 50/16 50/18
79/9 81/10 95/13
101/1 104/7 122/2
131/23 132/25 133/1
140/2 150/6 150/7
159/25 165/4
offer [3] 24/1 24/4
139/21
offered [1] 140/18
offering [1] 27/11
office [78] 5/19 6/4
6/8 6/11 9/15 9/19
9/23 11/15 12/18
13/22 15/20 16/2
16/13 17/7 18/4 25/22)
25/23 27/19 28/24
29/6 29/10 29/17
30/24 31/16 33/1 33/5
36/3 36/5 37/7 37/25
38/11 38/12 38/20
39/3 39/11 39/14
39/16 39/18 40/1 40/6
41/20 44/3 44/4 47/13)
65/10 67/12 67/16
68/19 70/16 71/2
71/10 72/10 73/25
75/9 78/8 79/12 80/14,
82/12 86/2 86/18 87/5
88/4 89/11 90/25
106/20 111/1 118/17
123/2 123/4 132/12
143/5 150/23 163/18
165/23 168/21 168/25)
169/2 169/10
Office's [4] 12/11
12/22 38/14 66/12
Officer [1] 75/25
official [1] 158/11
officially [2] 133/11
158/6
often [3] 60/24 150/6
159/24
oh [12] 9/6 30/2
71/23 72/3 74/20 79/7
97/4 148/14 148/16
149/22 152/12 168/10}
okay [43] 6/11 9/9
10/3 13/10 13/14
14/25 15/18 16/19
24/23 29/6 29/16
31/13 33/19 35/23
40/4 40/15 48/6 66/10)
68/2 68/7 75/2 75/17
122/20 133/21 153/17)
50/24 51/3 57/5 62/20
77/19 78/19 79/4
82/14 83/17 87/10
87/25 97/20 100/24
106/24 111/7 112/23
131/13 131/22 132/21
Old [1] 46/20
on [314]
once [6] 28/15 29/4
31/8 49/10 86/17
115/22
one [85] 5/16 8/9
8/14 8/23 17/12 17/13
18/10 20/14 21/8
21/19 23/10 26/11
28/10 28/16 31/9
36/15 36/23 41/10
46/10 46/11 46/16
47/17 47/23 56/6
59/21 62/5 65/25
69/16 69/19 69/20
69/22 70/3 73/16
73/18 77/4 82/11
83/17 87/2 90/3 90/22
96/12 100/7 100/15
100/16 100/25 101/18)
104/4 104/4 106/7
106/25 109/17 110/4
112/18 115/17 117/9
119/12 122/8 122/20
123/18 124/9 124/10
124/19 125/3 125/18
127/2 130/4 132/8
132/9 132/13 132/13
134/10 137/4 137/6
140/10 150/17 151/6
151/12 151/19 152/41
155/2 157/14 163/18
165/21 167/16 168/4
one-page [2] 151/12
151/19
ones [4] 19/23 57/4
98/3 136/4
online [6] 117/25
167/18 167/23 168/2
168/7 168/18
only [20] 12/11 17/4
20/22 26/1 31/1 32/19
42/13 43/3 44/8 44/18
76/1 76/17 76/20 78/6
84/23 96/17 98/21
99/15 144/17 159/19
onwards [2] 28/5
99/23
opened [2] 120/18
138/15
opening [2] 73/25
118/17
operate [1] 117/17
operated [3] 7/13
9/10 137/16
operates [1] 139/7
operating [19] 26/20
139/22 144/24 151/22
151/25 162/16 167/19)
26/24 27/4 27/10
92/14 92/16 93/16
96/3 107/5 114/23
139/17 141/4 162/5
162/7 167/18 167/22
167/24 168/3 168/8
operation [6] 25/4
48/19 92/16 106/12
107/17 162/7
18/19 123/17
opinion [46] 24/1
24/4 27/12 44/23 69/6
72/17 72/19 73/12
74/17 74/19 77/5
77/18 78/11 78/16
86/10 86/15 94/4 94/7
94/10 94/15 94/17
94/18 107/21 109/13
113/12 113/16 113/18}
114/4 115/1 115/8
125/18 126/1 127/17
127/23 128/9 128/14
129/3 130/7 130/10
137/13 137/19 137/25]
156/17 157/4 162/20
162/21
opportunity [1] 9/24
optional [5] 7/8 13/13
13/18 13/20 90/22
options [1] 90/22
or [214]
oral [3] 24/16 50/9
83/24
order [16] 17/1 37/1
41/11 42/2 42/8 43/9
44/22 72/19 86/4 86/7
111/17 111/22 132/3
136/14 143/13 145/9
order’ [1] 41/13
ordering [1] 71/17
orders [3] 72/6 72/9
160/15
organisation [1] 5/18
organise [1] 144/20
original [3] 67/19
165/17 169/15
originally [2] 149/16
159/14
other [40] 8/2 18/16
18/18 20/1 28/11 34/9
38/22 39/1 43/5 43/19
43/20 43/24 43/25
44/3 45/5 46/1 49/11
54/1 54/1 56/6 57/18
65/8 65/25 66/3 73/8
83/17 88/18 90/3
102/25 105/20 106/25}
107/5 115/17 119/12
122/15 130/4 155/2
157/16 163/6 163/8
others [4] 36/15
36/16 39/15 73/13
otherwise [14] 10/25
Operational [3] 17/12
33/24 34/11 84/22
109/19 111/9 111/12
112/23 113/4 121/20
137/21
our [12] 1/20 8/2 8/3
13/8 21/14 21/14
22/23 40/21 54/2
166/10 167/16 168/1
ourselves [2] 36/10
155/10
out [77] 1/7 4/2 7/3
7/25 8/18 9/10 16/8
20/19 27/23 43/20
43/24 44/20 45/2 53/1
53/4 53/5 58/3 61/24
82/4 82/6 90/9 92/16
94/11 95/1 98/8
1411/1 111/4 11116
120/9 123/3 123/20
125/15 125/21 129/1
130/20 133/23 134/11
139/21 143/20 146/4
146/6 146/23 148/14
150/8 151/2 151/11
151/17 152/6 152/10
153/9 153/19 154/1
155/3 155/6 155/18
155/19 156/20 156/21
156/24 156/24 162/7
163/25 168/12 169/18}
outage [1] 106/13
outcome [8] 67/16
69/16 117/6 120/18
126/13 143/7 143/25
144/2
outlines [2] 6/22
90/12
outlining [1] 68/17
outside [12] 69/5
72/16 73/25 86/3
113/11 114/23 116/3
118/16 127/13 129/20}
130/1 142/9
outward [1] 32/23
over [56] 3/2 11/22
14/12 19/9 24/4 24/14}
29/8 29/16 29/18
29/21 30/17 35/6
37/24 48/1 50/12
53/23 57/14 57/17
59/21 66/2 66/18
76/21 78/7 81/5 81/21
82/7 84/23 89/19 90/8)
91/9 95/2 96/22 98/23
103/4 108/25 114/12
114/14 117/12 117/18}
117/23 123/12 124/14}
134/8 137/4 139/22
111/20 111/24 112/15}
ought [2] 159/4 159/4)
62/17 78/7 80/6 81/15)
101/14 102/13 103/17)
106/19 109/10 109/12)
134/16 134/17 137/23)
140/6 140/16 140/24
141/10 141/11 141/17)
141/18 141/23 150/18)
157/14 160/7
overall [4] 43/13
77/10 93/9 114/4
overnight [1] 141/14
overview [5] 71/4
71/7 120/16 120/17
137/24
owe [1] 144/11
own [24] 19/22 19/24
37/14 45/15 46/3
48/22 49/3 49/13
49/15 49/19 50/8 55/2)
55/7 56/8 56/14 74/15
109/19 111/9 111/11
111/19 111/23 112/11
137/18 160/21
P
pad [1] 117/22
page [122] 3/15 3/17
4/23 5/7 5/8 7/4 7/7
7/16 8/10 9/13 10/6
11/22 11/23 14/1
14/12 15/18 16/19
18/14 25/16 30/7
31/21 35/24 36/17
37/24 39/24 41/2 41/2
41/3 46/14 46/14
47/23 52/3 57/24
57/25 60/2 66/18 68/9
70/12 70/13 72/12
73/15 73/16 75/5
75/19 78/1 79/10
80/11 80/21 80/22
82/24 85/11 86/25
90/20 90/21 91/8 91/9I
91/11 91/11 91/12
91/16 92/7 92/8 92/8
94/20 94/21 94/21
95/2 97/4 97/5 97/5
97/9 101/3 101/5
102/12 108/25 109/15}
113/7 113/22 114/8
114/14 117/14 117/12
117/18 117/23 118/10}
122/5 127/7 131/11
132/23 134/8 134/20
135/6 138/3 139/22
140/6 140/16 140/24
141/7 141/23 142/21
145/8 145/11 149/21
149/21 150/1 150/3
150/3 150/4 150/4
150/12 150/14 150/14)
151/10 151/11 151/12)
151/17 151/19 153/14I
163/15 164/9 167/10
171/16
page 1 [8] 7/16 9/13
41/2 79/10 80/21
109/15 149/21 150/1
(60) occurring... - page 1
P
page 13 [3] 73/15
73/16 118/10
page 16 [1] 31/21
page 17 [1] 18/14
page 19 [2] 46/14
46/14
page 2 [12] 8/10
35/24 39/24 68/9 78/1
80/22 90/20 113/7
127/7 132/23 150/3
150/3
page 21 [1] 91/16
page 22 [3] 10/6
15/18 138/3
page 23 [2] 3/15 3/17
page 25 [1] 16/19
page 26 [1] 141/7
page 27 [1] 91/8
page 28 [1] 97/4
page 29 [1] 14/1
page 3 [4] 75/19
101/3 102/12 114/8
page 31 [2] 92/7 92/8
page 32 [1] 91/12
page 33 [2] 94/20
94/21
page 38 [1] 57/24
page 4 [1] 75/5
page 41 [1] 97/9
page 5 [2] 117/1
150/14
page 52 [1] 4/23
page 57 [1] 70/12
Page 59 [1] 60/2
page 6 [1] 25/16
page 61 [1] 135/6
page 69 [1] 5/8
page 7 [2] 36/17
82/24
page 8 [1] 142/21
pages [5] 3/10 99/23
151/9 151/14 151/23
pages 56 [1] 99/23
paid [1] 169/17
pan [1] 7/3
paper [1] 1/7
paragraph [59] 3/20
3/21 4/23 12/17 14/7
14/8 16/6 16/8 16/20
16/21 18/15 25/14
25/16 31/21 36/18
41/10 41/15 46/15
52/3 57/24 60/2 70/12
70/13 72/13 74/23
82/19 91/13 91/16
91/17 92/9 92/9 92/21
92/24 93/21 94/21
94/21 95/3 95/8 95/10
95/23 96/1 96/7 96/12
97/12 97/14 98/5
98/19 99/12 102/4
110/2 110/12 111/7
113/8 113/23 113/25
127/8 135/6 157/24
161/25
paragraph 100 [1]
96/1
paragraph 115 [1]
57/24
paragraph 167 [1]
4/23
paragraph 192 [1]
70/12
paragraph 196 [1]
60/2
paragraph 20 [2]
25/14 25/16
paragraph 204 [1]
135/6
paragraph 33 [1]
36/18
paragraph 48 [1]
31/21
paragraph 53 [1]
18/15
paragraph 57 [1]
52/3
paragraph 60 [1]
46/15
paragraph 7.2.4.1 [1]
91/16
Paragraph 77 [1]
3/20
paragraph 8 [2]
97/12 97/14
paragraph 8.2 [1]
16/20
paragraph 96 [2]
94/21 94/21
paragraph 97 [1]
95/8
paragraphs [14]
13/11 13/18 13/23
14/15 17/15 85/8
85/10 87/11 87/12
99/23 109/16 112/19
161/23 161/24
parameters [12] 23/9
69/5 72/17 86/3
109/12 113/11 114/24)
116/3 127/14 129/21
130/2 142/9
Pardon [1] 162/25
part [33] 3/23 4/6
4/17 6/8 6/9 7/24
15/19 23/12 26/2 35/5)
35/9 35/10 35/25 45/4
46/1 52/5 54/17 56/13
57/18 57/21 70/23
73/4 74/16 75/8 88/8
95/11 106/4 112/6
124/3 125/9 132/20
150/12 151/7
Participants [2]
144/18 145/7
particular [22] 5/19
25/23 35/8 38/24 45/2
45/6 47/9 64/24 72/20
73/16 74/5 74/18
74/20 102/24 108/18
109/23 118/20 120/21
121/15 123/22 136/18}
170/8
parties [1] 115/6
partisan [1] 148/25
parts [2] 43/5 125/10
party [12] 26/2
159/15 160/5 160/8
160/9 160/12 160/13
160/14 160/23 160/25}
161/5 167/6
passage [1] 91/5
passed [25] 9/5 9/7
48/7 62/1 63/14 63/22
69/17 69/21 69/23
70/1 81/25 107/1
114/19 115/2 116/6
116/16 116/21 116/23
138/23 138/25 139/3
139/4 141/6 142/2
143/8
paste [2] 23/18
125/17
PAUL [4] 1/14 3/5
66/15 171/2
pause [4] 1/11 147/4
147/17 165/10
Pausing [1] 97/17
pay [4] 62/24 63/5
63/16 144/11
payment [1] 80/2
pearroll [2] 104/4
106/8
Peach [10] 46/24
47/1 47/14 47/24 50/4
50/11 51/7 157/8
157/14 159/1
PEAK [2] 123/16
124/18
Pearson [1] 101/17
Penny [14] 8/4 19/4
28/13 79/11 82/18
132/21 134/20 148/20
149/19 149/23 149/25)
150/5 158/10 166/2
people [26] 19/8 20/1
20/20 28/16 32/10
43/19 43/24 44/3 45/5}
45/9 45/20 46/1 47/16
48/8 49/10 49/10 55/5
57/17 57/18 88/18
90/5 103/19 146/4
148/14 150/7 167/6
people's [1] 34/15
per [2] 10/11 150/10
perfectly [1] 158/22
perform [5] 20/2 21/4
33/3 41/14 41/17
performed [4] 18/24
29/5 33/4 35/21
performing [7] 18/18
19/3 26/15 31/24 32/7I
33/24 34/14
perhaps [2] 133/22
153/18
period [12] 28/23
29/16 29/19 31/10
38/7 38/10 68/15 69/2
78/7 85/25 109/9
114/12
period’ [1] 101/9
permissible [3]
22/16 22/17 56/19
persist [1] 106/20
person [26] 7/9
10/13 10/17 18/7
29/11 29/14 31/23
32/6 32/23 44/8 46/16)
47/15 53/13 53/16
54/10 54/15 61/19
62/19 62/23 71/9
116/9 116/13 137/7
146/20 169/7 169/20
person's [1] 148/8
personal [3] 44/19
46/3 74/15
personally [3] 53/25
54/23 163/14
perspective [3]
22/23 45/1 55/3
pertaining [4] 69/1
72/14 85/17 85/20
pertinent [1] 10/25
Pete [4] 57/5 147/9
147/23 148/1
Peter [2] 42/13
145/25
Phase [1] 3/7
Phase 3 [1] 3/7
Phil [10] 36/2 38/3
39/15 39/24 40/6
40/16 42/6 42/15
42/20 132/12
phone [6] 45/19
52/15 53/21 53/22
53/23 137/4
phones [1] 51/1
phoning [1] 49/4
phrase [5] 60/6 69/3
126/17 164/4 164/5
physically [3] 9/5 9/6
39/2
picked [7] 76/11
84/21 101/10 117/7
118/4 125/8 136/4
picture [2] 70/18
120/25
piece [1] 1/7
PIN [4] 117/22
Pinder [1] 57/5
place [11] 12/1 12/6
13/25 18/2 38/25 75/1
106/13 128/20 136/23
155/8 155/10
placed [2] 54/21
159/2
plate [1] 158/1
please [131] 1/12 3/4
3/20 4/22 5/7 6/14
7/16 10/7 10/7 11/22
12/16 12/16 14/4
15/18 16/19 18/13
25/15 25/16 27/16
31/20 31/21 35/23
35/24 36/17 39/23
41/2 42/13 43/2 46/13
51/16 52/13 57/2
57/24 60/1 66/10
66/18 67/8 67/15 68/7
68/9 70/10 70/11
72/11 72/12 73/15
75/5 75/15 75/19
75/20 76/11 76/19
78/1 79/9 79/10 80/19
80/21 80/22 81/1 81/6I
81/12 81/13 81/16
81/17 81/23 82/15
82/23 82/24 84/8 85/4I
87/13 87/15 88/13
89/22 90/19 90/20
91/8 91/16 92/7 94/19
95/2 97/1 97/4 97/9
99/20 100/1 100/1
100/2 100/20 100/24
100/25 101/3 104/22
105/3 106/9 108/21
108/24 109/15 113/7
113/20 114/8 117/1
117/13 117/18 118/1
118/10 122/4 126/8
127/1 127/8 130/24
131/4 131/19 132/5
132/9 132/17 132/23
134/12 138/1 138/3
138/4 139/22 140/12
140/24 141/7 141/18
142/19 142/21 142/22)
147/2 149/15 150/14
pm [8] 84/11 84/13
108/11 108/13 141/15}
144/25 145/2 170/11
point [16] 2/12 10/16
41/7 11/22 11/24 12/3}
21/17 71/4 71/8 87/3
87/17 129/10 139/9
142/18 168/9 168/21
pointing [1] 90/8
pointless [2] 134/24
155/14
points [2] 12/13
12/23
POL00003219 [1]
27/16
POL00044482 [1]
101/1
POL00051960 [1]
85/5
POL00052220 [1]
(61) page 13 - POL00052220
Pp
POL00052220... [1]
75/2
POL00058443 [1]
82/23
POL00058448 [1]
132/9
POL00061793 [1]
138/1
POL00073280 [1]
66/10
POL00167135 [1]
142/19
policies [6] 9/3 9/25
18/25 19/15 20/12
21/8
policy [13] 6/14 14/3
14/5 16/21 19/19
20/20 21/14 21/15
89/24 91/25 92/1
95/11 110/3
popped [1] 43/10
pops [1] 41/24
populated [2] 16/15
28/11
port [2] 116/11
124/12
Porters [11] 36/2
36/5 67/12 68/16
68/20 72/14 84/3
109/3 109/5 129/2
130/25
position [3] 47/5
92/18 96/24
positive [1] 96/8
Posnett [5] 75/7 75/7
75/13 79/12 87/18
possibilities [1]
38/22
possibility [2] 58/1
125/24
possible [6] 10/12
10/18 76/15 102/4
106/14 124/21
possibly [7] 34/8
59/18 59/22 71/24
72/24 147/24 148/18
post [81] 5/19 6/3 6/8
6/11 9/15 9/19 9/23
11/15 12/11 12/18
12/22 13/22 15/20
16/2 16/12 17/7 18/4
25/21 25/23 27/19
28/24 29/6 29/9 29/17,
30/24 31/16 33/1 33/5}
36/3 36/5 37/7 37/25
38/11 38/12 38/14
38/20 39/3 39/10
39/14 39/16 39/18
40/1 40/6 41/20 44/3
44/4 47/13 65/10
66/12 67/12 68/19
70/16 71/2 71/10
72/10 73/25 75/9
75/17 78/8 79/12
80/14 82/12 86/2
86/18 87/5 88/3 89/11
90/25 94/1 106/20
111/1 118/16 123/2
132/12 150/23 163/18)
165/23 168/21 168/25)
169/2 169/10
Postance [1] 101/8
posted [3] 27/23
78/20 100/23
postmaster [27]
101/16 102/15 102/21
114/11 116/15 117/15)
122/13 123/8 138/8
138/10 139/7 139/15
139/25 140/1 140/4
140/5 140/8 140/10
140/13 140/18 140/20)
141/11 141/12 141/14)
141/16 142/25 143/3
postmasters [6]
115/7 115/10 141/9
143/16 144/9 149/1
postmistress [3]
139/15 141/14 141/5
power [1] 106/13
PowerHelp [5]
133/18 136/8 136/11
136/15 153/13
PowerHelp/TfS [1]
153/13
practical [1] 22/1
practicalities [1]
19/4
practice [1] 16/1
pre [1] 38/21
precise [1] 97/13
precisely [1] 135/7
prepared [9] 3/8
27/19 27/22 32/14
39/13 44/18 44/21
159/8 161/10
present [3] 107/1
110/7 110/9
presented [2] 45/14
48/21
presenting [1] 49/5
press [3] 158/10
158/11 168/24
pressure [1] 167/7
pretty [1] 145/20
previous [4] 41/15
47/3 83/1 113/24
previously [2] 128/6
128/17
principle [1] 1/25
print [3] 67/6 75/17
150/7
print/sign [1] 75/17
printed [11] 53/4
53/5 82/4 82/6 131/2
150/6 151/2 151/7
151/9 151/11 151/17
printing [1] 53/6
printout [1] 70/5
printouts [1] 70/23
prior [3] 46/19 55/17
55/19
priority [4] 101/15
102/14 102/14 103/1
privilege [4] 2/1 2/4
2/5 2/22
probably [8] 8/22
17/22 33/17 43/5 71/3}
82/3 128/6 142/13
problem [31] 69/14
69/20 74/3 74/24
101/15 102/14 102/18}
104/25 106/8 106/19
114/17 117/11 118/7
118/18 119/17 121/9
121/9 121/15 122/6
122/20 122/24 123/12
124/14 124/22 133/10
134/7 134/11 138/9
141/22 142/5 155/2
problems [10] 38/11
106/17 106/21 119/3
121/10 121/19 121/22]
122/13 122/16 140/14
procedural [1] 26/11
procedure [2] 118/2
123/18
procedures [6] 6/22
8/18 9/10 74/6 90/12
118/21
proceeded [1] 38/21
proceedings [3]
32/14 46/22 47/18
process [29] 3/23 4/6
4IN7 6/2 11/25 16/12
18/19 29/1 34/2 34/5
34/17 50/3 57/22 72/5}
72/22 80/1 97/25 98/8
99/5 99/19 106/14
107/15 111/5 123/5
153/1 157/1 160/19
163/24 163/25
processed [1] 24/6
processing [1]
105/24
processor [1] 105/24
produce [3] 68/18
82/20 131/23
produced [9] 60/8
76/2 76/3 76/4 92/1
122/8 131/16 154/4
154/16
producing [1] 123/8
product [1] 66/2
production [2] 29/24
94/24
products [1] 140/9
professional [1] 35/6
progress [1] 79/5
progressed [1] 71/5
prompted [3] 52/19
71/11 71/19
proper [3] 32/21
107/18 125/21
properly [11] 43/21
43/25 92/15 92/16
93/23 95/21 96/3
107/5 162/6 162/7
164/17
proportion [2] 29/23
30/12
proposed [1] 78/18
prosecution [23] 5/1
6/4 6/7 6/17 6/23 8/19)
9/12 10/10 11/16 12/6
12/18 12/23 15/12
15/20 17/1 38/6 39/18}
39/19 68/20 89/25
90/14 108/19 146/8
prosecutions [3]
31/17 89/10 96/23
protect [1] 145/20
protected [1] 157/7
protecting [1] 157/14
protective [3] 50/4
50/12 51/8
provide [38] 1/7 4/25
5/21 9/24 10/10 17/8
17/10 18/8 25/21
30/17 30/24 31/1
31/18 32/20 33/20
43/14 50/7 59/12
59/16 67/15 68/11
71/17 72/19 78/17
82/10 83/1 85/17
85/20 86/8 86/13
101/23 109/2 126/12
126/16 127/21 131/4
131/19 159/5
provided [25] 11/10
11/14 12/9 17/18
31/16 33/23 38/2
41/14 46/25 70/23
71/16 79/20 80/8 82/8)
84/19 85/12 86/22
87/4 91/19 91/24 92/2
92/3 151/21 155/20
157/9
provider [1] 10/21
provides [1] 10/8
providing [12] 17/23
30/14 35/8 35/10
52/14 57/17 74/17
78/22 78/23 94/4
142/7 157/16
provision [8] 10/16
26/7 31/15 35/5 35/18
36/3 79/22 89/9
proxy [2] 77/6 77/10
PSS [3] 6/4 10/10
11/5
public [4] 1/21
pulled [1] 16/15
pulling [1] 30/20
purely [2] 21/24
26/11
purpose [3] 95/7
112/2 112/5
purposes [2] 67/25
89/10
pushed [1] 169/15
put [37] 1/22 2/7 2/11
5/16 14/25 21/12
29/10 43/21 45/1
50/13 86/15 99/16
100/7 100/9 110/11
111/2 111/4 112/4
126/2 127/1 128/25
129/5 137/23 140/4
147/10 148/18 149/9
151/20 152/23 159/13)
159/21 159/25 160/3
160/16 167/4 167/7
167/8
putting [3] 69/13
125/15 164/12
Q
qualification [1]
156/4
qualified [1] 113/15
qualify [1] 156/13
quality [2] 8/12 20/21
quashed [1] 39/21
query [1] 76/1
querying [1] 81/8
question [21] 1/22
1/24 2/10 2/11 2/14
31/17 45/24 48/10
59/22 64/5 84/23
97/11 98/10 99/17
103/7 125/25 129/24
160/18 160/23 161/9
168/1
questioned [7] 1/15
32/17 145/11 167/12
171/4 171/6 171/8
questioning [4] 2/21
99/1 159/17 161/4
questions [19] 1/17
1/18 2/7 2/8 49/11
81/1 81/14 81/17
81/24 98/3 144/17
144/18 145/7 145/12
149/14 159/11 167/9
167/13 167/14
quick [1] 88/6
quickly [8] 66/21
91/10 91/15 117/14
128/14 128/16 130/22!
131/12
quite [16] 4/2 12/25
22/1 30/6 30/15 30/16
34/8 34/18 34/21 50/4I
53/8 91/10 122/5
131/11 142/16 163/7
quote [2] 47/6 99/8
quotes [1] 152/7
(62) POL00052220... - quotes
R
raise [5] 1/19 61/6
102/20 123/16 124/18)
raised [10] 52/11
58/2 58/11 60/25
101/15 102/14 102/15)
103/1 119/13 124/11
Raj [2] 32/2 33/18
Rajbinder [1] 32/3
ran [1] 166/3
rates [1] 69/20
rather [14] 9/19 16/1
18/24 19/15 20/19
35/5 50/25 60/23 64/1
86/10 129/10 147/13
151/14 151/20
raw [10] 65/1 65/6
65/16 66/2 66/7 81/5
81/21 82/8 82/10
82/21
reoleman [3] 104/4
104/21 104/23
re [5] 1/14 33/7 95/1
106/20 171/2
re-extract [1] 33/7
re-occur [1] 106/20
re-read [1] 95/1
re-sworn [2] 1/14
171/2
reached [1] 63/10
read [26] 4/2 8/23
11/20 11/21 14/19
23/17 31/21 36/18
40/15 52/20 53/5
56/13 59/8 59/21 60/8
71/15 85/8 92/5 95/1
99/24 107/4 113/5
117/14 146/16 148/10
152/10
reader [3] 67/1
117/19 117/20
reading [11] 42/4
4T7IT 48/2 49/9 53/6
107/2 107/2 118/15
139/6 147/4 147/17
reads [2] 12/17 155/5
real [1] 147/24
realise [1] 45/18
really [6] 53/22 142/1
147/16 150/16 150/20}
160/12
reappears [1] 106/4
reared [1] 41/6
reason [10] 41/18
92/11 94/13 97/15
97/21 98/11 98/17
110/4 162/2 167/24
reasons [2] 32/19
111/6
reboot [22] 74/1
74/23 101/13 101/17
102/13 102/16 102/21
103/3 105/25 106/17
117/10 117/16 118/7
118/17 118/23 120/22)
121/11 121/17 123/4
123/6 123/11 124/13
rebooted [2] 122/8
123/11
rebooting [2] 121/11
122/25
rebuild [2] 123/13
124/15
recall [15] 13/20 18/1
24/20 31/23 34/17
46/16 46/18 89/15
90/18 105/4 111/5
142/17 168/5 168/20
169/13
received [6] 12/5
27/21 86/18 88/12
130/21 153/2
recent [2] 5/22 5/23
recently [1] 161/24
recognise [2] 36/13
162/1
recognised [1] 1/23
recollection [6] 4/11
4/20 46/22 135/7
163/2 164/2
recommend [1]
142/2
recommends [2]
117/10 118/6
record [26] 22/20
27/19 54/9 54/13
54/14 55/25 56/5
56/21 59/13 59/18
61/4 67/2 73/8 99/25
102/17 102/22 119/2
119/6 119/10 136/17
137/6 137/7 137/9
137/19 139/12 139/14)
recorded [10] 11/1
27/2 48/18 58/14
58/20 59/17 67/2
68/15 69/15 73/4
records [31] 4/5 4/16
19/7 25/22 26/1 26/6
30/25 31/2 33/25 35/7,
36/21 49/3 58/3 58/21
60/15 66/19 66/22
70/5 70/7 94/24
109/20 109/22 115/21
119/6 119/10 136/14
138/1 138/2 141/3
154/3 155/17
recurs [1] 106/1
red [1] 81/15
redacted [2] 28/5
30/9
reduce [1] 41/23
reentered [1] 123/10
refer [6] 6/3 7/2
61/10 73/16 166/25
168/17
reference [9] 4/9
14/19 27/11 69/14
80/8 115/25 132/10
134/3 140/18
referred [19] 60/21
61/1 61/4 61/16 61/21
62/6 62/9 62/12 73/19
101/13 106/7 114/14
115/8 115/11 115/22
116/1 117/8 118/5
121/3
referring [6] 21/2
95/24 127/5 130/16
136/7 154/7
refers [2] 73/22 91/6
reflect [2] 7/12 13/18
refusal [1] 43/14
refusing [1] 57/19
regard [1] 164/6
regarded [1] 167/25
regarding [3] 101/25
132/15 167/17
regularised [1] 23/2
regularly [2] 30/13
60/15
regulated [1] 23/2
reiterate [1] 41/15
related [3] 21/23 24/5
60/17
relating [2] 2/19
96/19
relation [11] 12/12
23/8 27/21 72/20
72/25 81/8 88/7 92/18
118/11 129/2 135/8
relationship [9] 7/22
51/7 148/1 148/2
157/6 157/11 157/19
157/22 169/5
relatively [1] 66/21
relax [1] 149/10
releases [1] 168/24
relevant [13] 11/1
11/16 12/12 12/19
15/21 16/6 26/20
26/24 77/13 81/7
96/13 120/12 120/14
reliability [1] 96/17
relied [3] 39/14 56/25
137/1
reluctance [1] 48/24
rely [4] 2/5 44/4 55/6
55/13
relying [3] 20/17
41/20 142/10
remain [2] 5/25 135/9
remained [1] 5/24
remedial [1] 73/21
remedy [1] 58/6
remember [79] 8/23
9/1 14/4 14/18 16/12
19/24 20/7 29/3 30/19
30/23 31/6 32/22 40/3
41/7 42/3 42/10 44/15
47/25 48/5 48/6 50/3
50/3 51/13 53/18 54/4
57/5 67/25 70/6 71/13,
73/2 73/3 73/4 74/9
75/7 79/2 79/6 84/17
87/19 89/18 89/18
89/20 90/3 92/6 96/11
98/25 99/18 120/13
124/24 125/1 125/12
126/8 128/22 128/23
129/5 135/11 135/12
135/13 135/15 135/24}
136/9 136/10 148/10
152/12 153/10 155/5
155/8 155/22 156/1
157/19 159/12 159/15}
159/21 162/22 163/3
163/12 163/25 168/4
168/10 168/11
remind [3] 2/3 36/10
155/10
reminder [1] 39/22
remote [5] 101/13
102/13 117/10 118/2
118/6
repaired [3] 74/3
74/23 118/18
repeat [2] 64/5
129/24
repeated [1] 134/6
repeatedly [3] 60/18
60/21 141/1
replace [1] 106/4
replaced [1] 133/17
replacing [1] 162/12
replicated [1] 122/17
replied [3] 68/4
126/20 128/8
replies [2] 42/19 89/1
reply [8] 75/20 76/12
76/19 78/18 100/20
131/11 147/2 147/13
report [7] 38/3 38/18
39/12 40/25 44/2
68/17 114/16
reported [5] 37/19
67/17 104/13 114/21
126/13
repository [1] 9/3
representative [2]
1/6 1/23
represented [1] 2/16
repurpose [2] 49/15
49/18
reputation [1] 148/8
request [22] 11/6
11/15 12/10 12/18
15/20 33/2 65/25
67/25 70/16 71/11
71/12 72/9 76/17
82/12 86/18 86/19
86/21 87/5 111/1
131/18 163/17 166/22)
requested [17] 25/21
25/23 26/1 30/24 33/1
33/5 65/9 65/24 66/8
66/8 128/3 128/21
134/21 134/23 155/11
155/13 156/6
requesting [1] 21/24
requests [6] 8/1
27/20 28/24 29/17
29/23 29/23
require [1] 133/14
required [19] 6/22
8/19 17/4 18/17 27/21
28/10 30/8 30/13
41/17 54/14 73/21
73/22 90/13 92/20
92/22 118/14 137/22
152/5 156/4
requirements [5]
11/3 11/12 21/7 91/21
92/22
research [1] 56/15
resolution [12] 54/12
69/15 69/21 101/10
102/18 114/14 115/4
124/5 124/25 125/11
125/16 143/2
resolutions [1] 124/8
resolve [4] 101/14
102/14 123/12 124/13)
resolved [9] 52/12
53/10 58/11 115/3
115/13 115/16 143/18}
144/4 144/5
resource [2] 47/9
47/15
respect [14] 5/1
10/11 19/5 19/7 26/25)
47/14 52/5 60/16
92/15 93/13 93/14
94/6 94/23 162/6
respects [1] 50/5
respond [3] 39/11
101/9 118/9
responded [1]
102/11
response [4] 11/4
83/4 137/10 147/14
responsibility [4]
32/11 34/4 34/18
119/24
responsible [5]
10/13 10/18 31/24
32/6 92/18
restart [1] 123/17
restarted [1] 122/10
restricted [1] 122/5
result [6] 37/5 61/14
88/22 105/24 123/23
135/10
resultant [1] 68/18
resulted [2] 29/23
164/4
results [1] 38/4
resume [1] 144/22
retain [1] 10/14
(63) raise - retain
R
retainer [1] 42/23
retrieval [1] 154/25
retrieve [1] 47/10
return [1] 91/3
reveal [2] 161/10
166/13
revealed [1] 161/15
revealing [3] 46/8
157/10 157/18
review [2] 90/22
119/3
reviewed [8] 20/21
69/1 71/23 72/14
85/24 109/9 113/9
127/12
reviewer [2] 7/8 91/3
reviewers [2] 9/13
9/18
reviewing [1] 60/15
revised [2] 127/6
128/8
rewiring [1] 117/23
Richard [2] 90/16
101/7
Riddell [2] 88/14 89/1
right [64] 1/21 2/17
3/12 6/19 7/5 7/19
9/21 10/4 10/22 12/11
15/6 16/17 19/16 20/4
22/2 22/15 26/18
26/22 28/12 29/18
29/22 30/5 30/25 32/3
33/8 33/21 39/25 40/7
42/17 47/14 48/9 53/4
54/24 55/4 55/11 57/6
61/10 61/19 76/22
80/15 81/11 84/6
86/11 89/23 91/12
110/15 114/11 116/13)
124/20 127/3 127/10
132/3 145/10 145/21
149/20 150/12 151/16)
157/2 168/10 168/15
168/15 169/22 170/7
170/9
right-hand [2] 127/10
149/20
rightly [1] 116/9
RING [1] 123/4
Riposte [7] 106/11
106/15 107/1 121/9
122/10 123/16 123/17)
rise [1] 122/16
risk [2] 1/24 123/7
RLITO000130 [1]
36/12
RMGA [1] 40/11
rogue [1] 132/10
role [21] 8/5 8/14
12/11 12/22 20/23
25/10 26/3 26/7 34/13,
34/21 35/16 35/17
40/2 40/3 47/20 51/9
58/24 59/6 59/10
158/16 158/24
role’ [1] 47/5
roles [1] 54/1
rolled [4] 114/12
rollouts [1] 168/13
rollover [1] 69/21
room [1] 46/18
roughly [1] 168/16
route [2] 123/16
124/18
routine [43] 60/5
60/9 60/12 61/2 61/5
63/19 63/22 63/25
64/8 64/11 69/4 69/19
72/16 76/23 77/1 77/7
77/11 86/2 109/11
113/10 116/2 124/3
127/13 129/11 129/14)
129/17 141/4 142/8
143/11 143/15 143/18)
143/20 143/21 150/24}
151/4 152/2 152/7
152/19 153/6 154/17
155/21 156/15 156/21
routinely [4] 63/23
143/17 143/24 157/8
rows [1] 28/4
rubbish [3] 146/7
146/23 149/1
rule [1] 2/13
run [6] 29/8 29/8 36/6
78/3 95/21 168/12
running [2] 119/8
122/25
runs [2] 27/24 139/15
s
safe [1] 134/1
said [54] 14/5 15/7
23/17 30/23 34/21
35/16 37/11 37/14
37/19 42/1 43/2 50/14)
51/6 55/13 56/13 57/3
57/19 58/22 59/13
59/17 62/23 64/12
71/20 71/23 72/3 77/1
85/1 93/25 97/14
103/15 105/11 111/11
111/13 112/7 113/25
114/21 120/23 122/2
136/10 137/7 138/15
143/15 148/8 149/9
152/24 154/16 157/11
160/18 160/24 162/14)
163/6 164/12 164/14
169/20
same [29] 7/24 8/4
8/8 11/7 20/2 29/11
30/20 33/9 36/24
40/12 64/15 68/13
72/22 98/5 100/8
141/10 141/11 141/17)
103/17 104/15 113/21
113/24 122/21 123/19]
140/6 158/14 162/12
162/20 164/7 164/7
164/10 165/3
sarcasm [2] 147/22
147/23
sarcastic [1] 147/13
satisfactory [2]
115/4 115/5
satisfied [4] 59/3
59/25 104/10 135/17
satisfy [8] 27/7 58/11
58/18 58/22 59/4
126/1 135/19 136/1
satisfying [2] 57/22
58/14
Saturday [3] 100/21
141/13 141/14
saw [12] 10/2 49/7
49/7 59/10 61/3 76/22
83/5 83/16 86/22
115/12 121/25 165/1
say [117] 3/20 4/24
5/23 13/23 16/6 17/15)
18/15 19/12 20/12
20/22 21/15 21/16
21/20 22/4 22/6 22/9
22/12 22/15 23/7
25/19 26/21 27/2
28/10 29/21 31/9
31/22 33/17 40/8
41/11 42/22 43/17
43/22 43/22 44/13
44/21 45/9 46/11 47/7
50/11 50/14 50/24
52/4 53/1 54/23 55/3
55/21 57/11 57/25
60/3 60/20 62/10
67/10 68/9 68/19
73/18 74/10 74/22
75/10 75/13 80/24
81/16 82/25 84/7
85/11 85/16 90/6
92/20 94/12 94/22
95/2 95/16 96/1 98/16
99/4 99/24 105/8
107/3 107/4 107/16
109/1 109/8 109/17
109/20 109/23 111/3
111/21 112/9 112/13
114/25 116/5 118/11
119/16 125/13 128/1
129/16 129/20 129/21
130/4 135/16 138/22
139/6 141/3 143/11
145/20 147/15 147/23}
153/8 156/13 157/17
158/23 158/25 159/5
159/23 161/1 166/1
167/5 169/9
saying [53] 23/12
40/23 42/7 42/14 43/8
44/18 44/25 49/6
49/17 49/23 50/18
51/8 64/7 64/11 79/7
84/20 89/2 92/1 95/10)
95/22 96/6 98/15
98/18 101/18 101/20
102/5 104/11 116/2
116/15 119/15 129/11
129/25 137/15 138/8
142/8 142/24 147/10
147/20 150/18 152/1
152/15 152/18 153/2
153/20 154/14 155/19)
156/4 157/11 157/15
160/13 160/19 160/22)
165/7
says [36] 16/22
17/15 18/3 40/15 43/7I
43/9 43/23 47/4 63/5
78/2 78/24 88/21
97/11 100/5 102/12
105/4 110/4 113/19
120/9 120/17 128/17
133/4 134/13 134/20
140/10 141/20 141/24}
144/11 146/13 150/20}
153/12 153/12 153/15]
158/4 159/3 162/22
scale [1] 25/1
scanned [1] 151/21
screen [6] 3/16 6/15
18/14 25/17 117/14
117/15
screens [1] 67/5
scroll [67] 3/20 7/16
8/10 10/7 12/16 14/1
14/3 14/14 15/18
28/12 35/25 36/14
36/17 40/10 42/13
66/20 68/9 68/25
73/17 75/5 75/19
76/11 76/19 78/1 79/9)
80/11 80/22 81/6
81/12 81/14 81/15
82/15 82/17 82/24
85/7 87/15 87/16
88/13 89/1 90/20
91/10 96/1 100/3
100/20 101/4 104/25
106/8 108/23 109/15
117/2 118/10 132/23
132/23 134/12 138/4
139/22 140/6 140/10
140/19 141/18 141/18
142/21 146/1 149/21
149/22 150/2 150/25
scrolling [3] 14/14
69/12 102/2
searched [1] 104/7
second [31] 3/8 3/17
4/22 7I7 16/21 18/13
31/14 31/20 46/14
52/2 69/20 70/6 70/11
72/13 81/9 83/21
94/20 97/11 99/22
106/7 109/17 113/7
113/22 113/23 113/25)
116/22 122/19 127/8
139/23 168/21 170/1
secondly [4] 25/7
43/19 56/12 134/19
seconds [1] 122/9
Section [2] 6/4 6/8
Security [25] 4/6
4I17 5/20 5/24 5/25
7/25 8/3 15/13 18/16
18/19 19/21 47/9
47/15 54/2 57/3 57/17,
58/24 59/7 75/8 87/20)
87/22 87/23 87/24
89/17 169/3
see [130] 1/3 6/15
6/25 7/4 7/7 7/10 8/11
10/7 11/20 12/17 14/7I
14/10 14/12 14/14
18/3 18/5 20/11 24/14)
25/16 28/1 28/3 28/5
28/13 28/16 28/17
30/9 36/1 40/10 41/3
45/3 49/25 51/22
58/24 59/6 59/10
60/15 60/24 62/2
66/13 66/15 66/18
67/6 67/11 68/5 69/9
75/20 75/20 76/12
79/4 79/10 80/12
80/23 81/13 82/16
82/24 84/14 85/8
86/16 87/22 89/23
89/25 90/10 90/15
90/20 90/23 91/3 91/8}
91/12 92/9 92/24
95/22 97/4 97/6 97/10
98/2 99/8 100/17
100/18 104/22 104/25)
106/6 107/9 107/25
108/14 108/22 108/25}
109/6 109/16 110/2
110/11 111/17 114/2
116/19 124/3 124/24
125/23 126/9 126/14
126/20 126/23 127/9
127/19 129/6 131/9
131/14 132/20 134/18}
138/3 138/5 138/16
141/21 145/3 146/3
146/21 148/6 148/7
149/18 149/21 149/22!
149/24 150/3 150/7
151/4 151/13 156/12
157/22 160/19 166/19
166/21 167/17
seeing [4] 64/15
81/24 92/6 122/11
seek [3] 22/12 57/13
57/16
seem [5] 68/20 69/19
76/20 77/5 124/20
Seema [11] 48/1
(64) retainer - Seema
Ss
Seema... [10] 70/10
75/4 80/20 84/18
108/20 132/5 132/8
136/19 139/23 140/7
seemed [1] 78/15
seemingly [1] 43/11
seems [7] 40/23
76/10 77/16 99/13
122/24 151/8 151/9
seen [27] 5/4 13/21
61/17 61/25 63/23
64/13 64/19 80/3
107/11 109/8 117/11
118/8 119/4 121/24
123/1 123/14 123/18
124/3 124/9 124/17
124/19 124/22 125/2
143/23 145/24 166/19
169/13
self [2] 2/2 2/20
self-discrimination
[1] 2/20
self-incrimination [1]
2/2
send [4] 106/4
123/12 124/14 131/5
sending [2] 133/5
157/25
sense [5] 17/15
100/14 113/1 151/13
164/17
sent [8] 29/6 29/9
68/19 82/6 103/3
122/21 132/21 152/22)
sentence [2] 93/18
113/25
sentenced [1] 36/25
separate [4] 87/10
99/9 99/20 151/8
September [3] 66/12
89/9 89/16
sequences [1]
128/24
series [2] 66/22
83/17
serious [4] 106/2
129/12 129/14 129/17)
seriously [5] 34/19
34/21 34/24 35/16
35/18
served [3] 84/25 85/6)
132/16
server [4] 123/15
123/19 124/17 124/19}
service [16] 5/18
6/24 8/15 8/20 9/12
10/10 12/19 15/12
17/22 18/25 19/15
19/19 65/21 80/7
118/8 169/2
services [1] 117/25
session [1] 115/20
set [8] 9/10 95/1
109/10 120/9 124/24
149/15 153/9 156/20
sets [3] 1/7 8/18
145/6
settling [1] 119/24
seven [3] 28/23
29/16 29/18
seven-month [3]
28/23 29/16 29/18
several [1] 133/13
Sewell [6] 42/14 43/2
57/5 145/25 147/9
149/6
Sewell's [1] 146/2
shall [6] 11/1 11/5
11/9 12/6 91/18
144/21
shared [4] 15/11
15/12 16/15 30/21
sharing [1] 89/4
she [38] 7/25 8/6
32/6 32/13 32/14
32/15 33/13 33/13
39/25 40/4 40/5
128/20 134/17 136/7
136/7 136/13 138/10
139/7 139/15 140/1
140/17 140/20 141/13)
141/20 141/24 143/1
152/4 153/12 153/12
153/15 155/7 158/4
158/20 158/21 159/3
159/4 166/3 166/3
she'd [1] 128/21
she's [4] 32/23
126/16 134/15 152/15)
sheet [1] 66/11
shift [1] 54/6
short [10] 51/20
84/12 86/8 88/11
108/12 122/5 127/21
131/7 145/1 150/13
shortages [1] 37/11
shortfall [2] 37/4
39/17
shorthand [1] 2/1
should [40] 2/14
11/23 12/20 15/22
16/2 19/12 21/22
22/12 22/12 22/20
24/9 26/20 26/24 27/4
27/10 41/17 43/20
43/24 44/4 44/5 44/11
51/5 56/23 67/10 74/4
75/10 81/10 81/13
82/8 93/11 93/16
100/12 106/18 107/22)
123/9 123/20 133/23
138/3 153/4 153/19
shouldn't [3] 24/10
51/6 153/4
show [2] 38/14
150/19
showing [4] 138/10
139/25 140/8 140/15
shown [6] 4/5 4/16
sic [1] 127/17
side [6] 5/16 109/12
127/7 127/10 127/16
134/1
sign [10] 41/8 41/10
42/6 50/11 50/15
50/16 50/18 50/24
75/17 81/9
signature [3] 5/9
40/10 150/18
signed [14] 15/1
16/17 20/19 43/16
75/12 79/8 93/20
101/1 132/25 133/1
150/17 150/19 153/5
156/4
significant [3] 34/15
78/10 116/8
signing [3] 41/25
51/3 96/22
similar [3] 90/10
94/25 98/3
simpler [1] 4/22
simplify [1] 100/16
simply [5] 105/23
109/25 131/24 132/3
150/20
since [6] 3/8 37/15
41/13 122/11 124/2
142/3
single [2] 41/10
72/23
sir [20] 1/3 1/5 3/3
15/17 51/14 51/18
51/22 83/21 84/10
84/14 108/6 108/14
144/17 144/23 145/3
145/6 167/9 169/24
170/7 170/10
site [2] 106/23
122/21
sits [1] 151/23
sitting [1] 46/18
six [5] 28/23 29/16
29/18 85/16 108/25
sixth [2] 53/24 137/5
size [2] 16/23 86/2
slightly [1] 108/21
small [3] 147/5
147/18 148/16
SMC [7] 106/23
117/7 117/8 118/4
118/5 125/8 136/5
so [201]
software [8] 52/10
95/19 95/20 95/24
96/4 96/18 98/22
116/20
solely [2] 41/20 44/4
solicitor [1] 132/13
20/13 21/8 39/4 60/18
solution [8] 105/19
106/16 119/18 122/23}
124/8 125/9 125/10
125/14
solve [1] 103/3
some [37] 6/2 13/12
14/12 14/15 19/2
20/17 23/23 35/23
44/23 50/21 51/10
60/16 66/1 85/8 99/25)
100/9 100/10 104/17
105/2 106/17 109/16
121/22 133/14 133/15}
133/24 143/17 144/18}
145/12 148/8 149/14
152/5 152/5 156/5
159/11 161/22 163/7
165/8
somebody [15] 21/3
40/12 49/14 54/3 54/4)
56/9 56/11 56/20
56/21 56/22 72/2
74/19 112/12 136/25
142/13
somehow [1] 83/7
someone [18] 29/4
33/2 33/6 47/10 56/2
80/4 105/11 107/8
121/5 121/6 161/21
161/22 163/17 165/6
165/7 165/7 165/22
166/2
something [29] 10/3
28/5 29/2 32/16 34/24
43/22 49/14 56/15
57/21 98/1 98/8
106/21 109/20 111/23)
111/23 120/14 124/1
128/16 128/18 129/12}
129/14 129/17 135/15)
137/18 148/9 156/2
159/19 162/14 167/7
sometimes [7] 34/24
65/3 65/5 65/6 65/11
65/12 102/3
somewhere [1] 74/13)
son [1] 37/5
sorry [48] 6/10 12/15
23/12 24/17 26/21
30/4 30/4 33/12 35/11
40/2 40/17 44/16
45/24 48/10 52/17
54/11 55/9 62/10 64/5
64/20 82/5 84/1 84/7
89/14 93/25 103/15
111/21 112/20 129/13}
129/16 129/24 133/1
136/9 139/13 144/1
147/15 152/21 156/25}
158/19 159/10 161/14,
163/5 164/23 166/2
167/23 168/19 168/20}
169/7
sort [9] 9/2 27/8 34/4
T7I17 139/21 143/17
148/2 148/15 165/3
sorts [2] 20/20 56/19
sound [1] 29/17
sounds [1] 29/22
source [1] 123/15
South [2] 99/21
100/8
Southwark [1] 36/23
speak [14] 22/17
22/23 44/18 45/19
46/2 46/7 53/24 54/3
55/24 56/20 56/20
56/22 139/5 158/14
speaking [11] 16/7
45/15 45/19 49/9
49/23 55/15 55/19
71/9 105/11 112/10
159/24
species [1] 93/7
specific [8] 11/12
91/21 133/10 133/22
134/17 135/23 136/10
153/18
specifically [2] 74/9
153/11
speed [1] 4/2
spelling [1] 100/8
spoke [4] 48/12
54/15 101/25 111/13
spoken [13] 49/10
56/11 72/19 72/25
103/19 121/5 128/19
142/13 142/15 142/16)
155/7 155/7 163/20
spot [1] 99/16
spreadsheet [2]
27/17 27/18
Square [3] 121/9
121/15 134/7
SSC [53] 4/7 4/18
22/17 45/5 45/9 45/20
46/7 46/11 46/16 47/4
47/5 48/8 48/12 49/23)
49/24 50/1 50/7 50/13
52/10 52/19 52/21
53/17 53/19 53/24
55/22 56/20 56/21
56/23 58/10 72/20
73/1 104/17 104/18
105/12 107/1 107/8
111/13 121/5 121/6
121/16 123/13 123/16
124/15 124/18 136/25)
137/7 143/4 143/8
157/7 157/17 157/18
158/15 159/8
SSC's [1] 48/24
stability [3] 74/4
118/19 118/23
stable [1] 119/9
staff [2] 46/7 47/4
stage [11] 2/5 2/21
8/23 16/12 19/2 78/5
(65) Seema... - stage
Ss
stage... [5] 78/22
82/11 89/8 89/16
137/22
stand [2] 158/21
159/9
standard [16] 11/9
74/1 85/8 86/13 86/17
87/11 89/16 89/20
91/18 96/11 112/7
118/17 160/1 161/22
161/24 165/14
start [7] 24/12 31/17
35/23 75/4 87/14
165/3 170/4
started [4] 37/10
89/11 122/7 131/22
starting [4] 14/7 71/4
71/8 100/1
state [8] 34/23 46/12
56/12 81/5 81/21
112/24 113/3 119/11
stated [12] 38/19
60/4 60/12 64/12
109/19 111/9 111/12
111/13 111/20 112/15}
140/1 161/4
statement [279]
statement' [1] 97/17
statements [74]
10/15 11/3 11/10
11/11 13/1 14/20
14/23 14/25 16/25
A7N7 17/18 25/24
26/8 26/13 30/14
31/16 31/19 32/15
32/20 33/10 33/20
34/1 34/10 35/12
35/18 45/4 45/8 45/12
45/21 45/25 47/21
48/21 50/9 59/2 59/11
60/7 63/21 65/1 65/4
72/7 89/9 89/20 91/19
91/20 92/24 93/6
94/23 96/8 96/15
110/12 110/15 110/16}
110/17 110/22 110/23)
110/25 113/5 120/10
125/19 132/7 136/17
136/19 137/9 152/24
157/9 157/15 157/17
160/16 160/20 162/15
165/2 165/15 165/25
166/15
states [9] 127/25
138/10 139/25 140/13
140/20 141/9 141/12
141/15 142/25
stating [3] 43/24
60/18 140/8
staying [1] 132/19
stealing [1] 37/22
Stein [4] 145/8
167/11 167/12 171/8
step [7] 21/5 21/5
53/7 53/7 98/13 98/13)
125/11
steps [3] 104/19
107/9 125/13
stick [2] 23/3 160/25
still [13] 80/20
107/18 114/4 122/20
130/25 145/3 156/8
156/17 156/19 156/23)
157/3 162/20 169/1
stock [7] 140/21
140/23 141/9 141/10
141/16 143/1 143/5
stolen [2] 38/22 51/1
stood [1] 167/2
stop [6] 53/1 93/20
123/17 140/25 141/23)
146/24
stopping [5] 32/19
60/6 76/22 98/2 98/14
storage [1] 105/21
store [5] 42/24 43/4
106/10 124/15 133/18)
story [2] 80/13
160/25
strategy [1] 97/25
streets [1] 51/1
strength [1] 146/8
stress [2] 41/23
43/10
stressed [1] 43/11
strike [1] 38/5
strong [1] 146/25
strongly [1] 123/6
structures [1] 106/15
stump [1] 42/22
subject [6] 47/2
129/22 129/25 130/4
130/10 130/18
subjected [1] 106/11
submitted [1] 71/7
subpostmaster [7]
36/6 37/16 60/18
61/12 61/20 114/16
119/15
subpostmasters [6]
60/25 63/8 85/13
119/24 145/13 167/16)
subsequent [2]
17/13 136/19
substance [7] 36/9
64/2 77/7 77/11 78/9
78/14 78/23
substantial [1] 3/15
substantially [1]
113/21
substantive [1] 114/7I
substitute [1] 163/14
success [1] 37/13
successful [1]
102/22
such [16] 2/10 11/16
12/19 15/21 31/18
38/11 52/9 57/17 58/9
58/25 60/25 92/16
103/23 105/21 105/22}
162/7
suffer [1] 33/15
sufficient [1] 37/21
suggest [3] 55/25
100/15 147/12
suggested [1] 47/24
suggesting [3] 137/2
147/16 151/16
suggestion [1] 169/4
suggestions [2]
136/1 137/10
suggestive [1] 102/6
suggests [2] 91/2
150/5
suite [1] 20/11
sum [1] 37/2
summaries [2] 83/11
120/2
summarise [5] 22/9
25/24 61/3 65/3
142/23
summarised [7]
21/22 64/24 65/5 70/4
70/8 70/25 143/10
summarising [4]
24/17 25/3 26/12 66/3
summary [14] 6/20
12/9 23/18 65/11
65/16 69/13 69/15
70/8 78/22 80/13
86/14 86/23 123/22
131/23
supplied [15] 3/23
4IT 4/18 13/5 41/21
66/9 79/3 80/2 86/21
88/10 94/23 153/25
156/7 166/17 166/18
supply [3] 33/3 44/5
131/20
supplying [10] 34/19
47/11 47/18 47/20
59/2 59/11 71/21 82/3
132/4 158/15
support [37] 5/1 6/4
6/8 6/17 6/24 8/16
8/19 9/12 10/10 11/16
12/7 12/19 12/23 15/7
15/12 15/21 16/11
17/22 18/17 31/16
37/18 46/17 52/10
85/12 87/23 87/24
89/25 90/14 101/11
133/3 134/21 146/16
147/11 148/3 149/10
155/11 166/11
supported [1] 88/22
supporting [1] 38/6
suppose [5] 15/15
55/14 55/23 146/4
148/15
supposed [1] 58/18
sure [28] 8/5 12/25
32/21 34/3 41/20
43/15 44/7 57/8 57/9
88/15 96/21 97/13
98/10 98/16 98/19
98/23 99/11 99/17
99/18 119/5 133/8
149/1 150/11 151/1
152/24 162/19 165/1
167/2
surface [1] 63/10
surname [1] 8/8
swap [1] 103/4
swipe [1] 117/21
sworn [4] 1/5 1/14
97/7 171/2
SYSMAN2Z [1] 133/13
system [94] 3/22 4/7
4/18 16/24 17/4 25/8
26/4 26/19 26/24 27/3,
27/10 37/23 39/4
43/20 48/19 52/16
55/25 60/19 61/7
61/14 62/25 64/4 64/9)
64/14 69/6 72/17
73/23 74/4 74/23
85/18 85/21 86/4 88/7,
95/14 96/3 97/24 98/7,
99/3 99/15 101/11
101/12 107/5 107/21
109/13 113/11 114/23}
114/24 116/3 116/15
118/19 118/24 119/8
121/11 121/12 121/17
122/11 127/14 129/7
129/21 130/2 130/8
132/15 135/18 135/19)
136/2 136/4 138/19
139/8 139/17 140/8
141/3 141/5 141/22
142/4 142/10 150/23
162/13 162/18 163/9
163/14 164/5 164/10
167/19 167/22 167/23}
167/24 168/3 168/8
168/18 168/22 168/24}
168/25 169/4 169/18
system.’ [1] 97/23
systems [5] 17/3
40/11 41/22 44/17
74/1
TO
tab [1] 133/13
take [15] 2/3 13/3
21/2 31/13 34/24
51/15 54/19 68/7 72/6
77/20 98/13 99/25
140/22 143/5 150/10
taken [11] 12/6 21/9
42/4 51/3 77/14 1014/7
4114/4 1191/4 114/41
144/10 163/24
taking [5] 13/25 18/2
51/9 106/13 152/20
talking [5] 16/17 64/6
77/15 93/6 140/2
target [1] 106/24
task [7] 19/4 20/2
21/4 26/2 35/3 35/21
45/18
tasked [1] 158/24
tasking [1] 20/3
tasks [4] 18/18 18/24
19/3 33/24
Taylor [1] 132/12
team [34] 4/6 4/17
5/20 5/25 7/25 8/2
15/5 15/13 16/10 18/2I
19/22 20/1 28/19 29/7)
40/12 40/22 46/25
47/9 47/15 50/4 50/12
51/8 53/19 54/2 57/17
75/9 83/10 89/17
148/22 149/2 157/15
158/9 164/25 169/3
tear [3] 147/5 147/18
148/16
technical [24] 17/2
25/4 26/18 26/23
47/10 47/16 52/9 56/3
58/9 60/24 61/6 61/14I
62/2 63/8 63/13
109/22 113/14 116/19}
120/19 121/6 137/1
152/5 153/3 159/2
technology [1] 168/1
tell [24] 2/10 2/23
7/21 10/20 19/13
20/16 21/19 25/2
30/12 32/6 46/15
48/11 73/11 94/12
98/21 105/3 116/1
124/7 135/5 139/10
139/14 149/10 166/25]
167/1
telling [8] 45/21
55/11 55/22 56/5 56/7
62/19 130/18 144/9
tells [4] 49/14
template [27] 13/8
13/10 13/17 14/4
14/24 15/4 15/7 15/10
16/1 16/5 16/10 16/15)
30/21 91/6 92/3 92/7
93/2 95/4 95/13 95/15
96/23 159/18 163/9
163/11 163/13 164/24)
165/6
templates [11] 161/5
161/7 161/11 161/12
161/16 161/25 165/3
165/4 166/6 166/7
166/7
temporarily [1] 36/11
ten [4] 144/19
tended [1] 101/19
(66) stage... - tended
T
term [2] 73/20 118/13}
terminology [1]
47/12
terms [3] 48/8 69/15
70/8
test [2] 41/14 105/23
testify [1] 17/8
testifying [1] 93/22
testing [2] 44/20 45/1
tests [1] 45/2
text [1] 100/8
TFS [4] 133/19 136/14
136/15 153/13
than [22] 9/19 16/2
18/25 19/15 20/19
33/18 35/6 50/25 52/9
54/8 56/3 58/9 60/24
86/10 107/5 121/7
123/18 124/19 129/11
135/23 147/13 158/1
thank [70] 1/4 3/1 3/3
5/7 5/15 5/15 7/17
8/17 10/6 10/24 18/12
24/23 27/17 28/3
28/16 43/7 51/14
51/18 51/23 51/24
52/3 67/8 70/3 72/13
73/17 75/10 80/11
80/19 80/23 81/16
82/15 83/20 84/6
84/10 84/15 86/13
87/16 88/3 88/6 89/23
90/9 91/11 91/15
95/16 99/20 100/3
108/5 108/10 108/15
4117/1 127/2 127/9
132/5 132/6 132/24
138/4 142/22 144/15
145/5 145/6 146/2
147/3 147/10 149/12
167/9 167/10 169/22
169/24 169/25 170/10)
thanks [2] 40/21
40/25
that [1061]
that I [1] 56/12
that's [78] 1/10 11/7
15/9 18/22 19/12
19/23 21/5 23/10
29/10 30/9 32/3 34/4
39/22 50/18 50/22
53/18 55/15 60/6
64/21 65/25 68/13
69/9 70/3 71/7 74/25
78/13 82/2 82/15 84/3
87/15 88/5 101/18
101/20 103/24 104/23)
106/7 107/15 107/20
111/11 112/6 112/23
113/18 113/18 114/1
114/19 124/4 125/9
126/4 127/19 128/16
130/21 145/22 146/13}
146/14 146/14 148/9
149/2 150/6 150/9
150/15 150/25 151/8
151/16 152/18 153/14)
154/4 154/21 159/10
159/24 159/24 159/25)
160/15 160/16 160/17)
161/2 167/5 169/3
170/7
theft [2] 36/23 88/10
their [21] 7/22 17/22
29/5 29/8 43/20 43/24
44/24 49/3 50/8 50/8
55/7 65/15 83/16
86/21 105/12 105/12
119/24 133/9 147/11
150/8 163/18
them [67] 2/20 3/14
418 4/19 5/22 8/24
14/16 14/21 14/22
19/12 19/18 20/12
20/14 23/10 23/18
26/1 26/5 26/12 28/21
45/11 48/12 48/13
48/15 49/4 50/12 53/5)
53/6 53/21 53/22
53/25 54/1 55/13
55/15 55/19 64/24
64/25 65/3 65/5 65/8
70/8 70/22 71/11
71/16 71/17 71/22
82/1 82/4 82/6 82/6
82/7 83/10 87/7 87/8
105/13 119/25 121/4
123/4 129/3 132/8
138/23 139/20 152/6
152/24 159/4 161/6
161/17 161/20
themes [1] 108/17
themselves [8] 26/3
46/2 48/25 49/24
57/19 66/24 129/11
144/20
then [111] 3/8 4/9 4/9
4/22 7I7 8/5 9/1 10/21
12/3 12/8 16/17 17/12
22/4 26/12 28/12
31/13 32/9 33/6 33/20
33/25 34/1 35/14 37/3)
40/13 41/8 49/20
49/20 49/21 55/8 61/1
61/15 67/9 68/8 68/16
68/25 69/12 69/16
71/5 76/3 76/19 78/1
78/4 80/12 81/6 82/1
82/14 82/23 85/10
85/16 86/15 86/15
87/10 88/13 89/1
91/11 95/1 97/12
98/14 99/7 99/8 99/9
102/16 105/2 106/4
106/6 106/19 106/21
106/22 108/24 109/20)
116/18 117/12 117/13}
117/13 117/16 118/1
120/12 122/23 123/16
123/19 124/18 127/5
127/15 131/11 131/23}
134/20 137/24 138/14
139/22 140/3 140/6
140/10 140/12 140/19)
140/24 141/13 141/18}
141/18 141/23 146/3
150/1 150/3 150/15
151/11 151/20 153/15}
158/4 162/21 163/21
166/4 170/9
there [174]
there's [18] 1/18 14/5I
14/15 17/24 69/2 73/8
91/5 98/10 99/8 105/2
107/13 124/24 125/11
131/8 137/19 153/3
157/16 164/9
thereafter [1] 2/12
therefore [16] 2/7
25/25 28/10 33/3 59/6
60/22 61/1 62/5 62/8
62/11 63/9 106/3
116/22 168/23 169/5
169/12
hereon [1] 41/16
hese [54] 12/13 17/1
17/15 19/9 19/21 23/9}
25/24 29/3 55/5 55/6
60/13 61/2 63/18 64/2
64/3 64/7 64/8 73/1
73/24 74/6 81/5 81/21
85/10 93/5 93/5 96/15)
105/12 106/17 107/3
107/10 113/5 116/1
118/16 121/3 121/22
122/8 122/12 125/18
129/25 133/20 133/22}
133/25 137/13 137/14]
137/24 138/2 143/18
143/23 152/16 153/6
153/16 153/18 154/9
159/2
they [116] 7/22 9/1
9/6 9/7 10/1 10/2
13/23 14/21 19/14
19/18 21/7 21/9 24/1
32/19 39/8 39/9 40/20
41/9 42/22 45/6 45/9
45/11 45/21 49/2 50/7
50/14 50/14 50/18
50/19 50/22 51/4 51/5)
51/5 51/8 51/10 52/11
54/16 55/7 55/10 56/5
57/1 58/5 58/11 61/13
61/15 62/17 62/17
62/19 62/23 63/4 63/9
63/15 64/11 64/12
65/11 65/12 65/21
65/24 65/24 66/8 67/6
71/6 71/11 71/22 72/1
tl
tl
72/5 72/10 80/16
81/24 82/12 86/6
86/20 87/5 100/13
105/13 105/16 106/20
110/24 115/7 115/11
119/14 123/3 123/5
123/6 123/7 123/9
123/10 127/12 128/25}
129/20 133/21 133/22!
140/14 143/17 143/17]
144/19 146/3 148/14
148/15 149/16 149/17]
152/7 153/17 153/18
156/21 157/9 157/10
159/8 161/18 161/18
161/19 161/19 165/2
166/19 166/19 166/21
they'd [4] 29/4 71/15
72/3 149/10
they're [9] 61/22
99/24 105/14 107/14
107/14 140/15 143/24}
152/19 157/15
they've [2] 8/8
151/20
thing [12] 16/7 43/3
54/24 70/22 97/25
107/12 132/1 146/5
148/15 164/7 164/10
165/21
things [31] 19/13
20/25 20/25 22/24
24/9 24/10 24/15
34/25 45/20 45/21
50/5 56/10 74/22
100/11 103/19 110/25)
4111/1 112/10 112/12
115/8 125/16 134/15
137/2 153/3 157/12
157/17 157/20 163/24}
163/24 165/8 168/14
think [81] 2/15 3/10
7/4 TIT 8/9 10/19
13/12 15/24 17/19
28/8 30/12 33/17
35/20 36/5 36/9 36/12
40/10 42/15 42/18
48/23 49/22 50/1
50/21 51/5 51/12
54/19 55/21 57/4
57/11 58/22 58/23
60/7 61/25 66/6 66/16
71/13 75/5 77/18
78/12 78/16 78/17
79/1 79/11 81/23
83/12 85/1 85/19 86/6
86/8 88/5 90/20 95/9
99/2 101/23 110/11
110/13 110/15 111/11
115/20 125/5 127/25
128/2 129/19 130/23
131/2 131/18 131/20
132/7 133/11 135/3
135/14 136/6 137/22
144/23 146/17 153/10)
153/21 154/12 158/7
163/15 168/12
thinking [3] 44/8
98/24 124/13
third [6] 12/17 60/1
82/18 91/17 97/11
141/7
Thirdly [1] 25/10
this [239]
Thomas [13] 8/4 19/5]
79/11 82/18 132/21
148/20 149/19 149/23)
149/25 150/6 151/2
158/10 158/25
Thomas' [1] 28/13
thoroughly [1] 35/4
those [67] 1/18 5/11
5/20 11/17 11/20
12/20 15/3 15/21 19/2I
20/16 20/19 23/23
23/23 24/9 24/10
24/15 25/19 33/15
34/11 34/18 42/12
45/2 47/20 49/7 49/10;
56/19 58/23 63/22
63/23 72/4 72/15
73/18 74/20 82/1 83/3}
83/18 85/9 104/7
104/11 104/15 105/23)
108/20 111/14 111/14I
115/18 118/11 125/13}
131/20 134/3 136/5
136/5 137/4 137/6
141/3 144/17 147/3
149/8 156/23 157/12
157/20 161/11 161/12)
161/15 162/22 164/8
165/8 167/9
though [9] 4/11 4/19
19/7 39/8 54/20 75/24I
76/6 99/24 146/5
thought [14] 34/13
34/17 44/8 46/20 50/3I
56/4 61/13 99/19
116/18 137/12 158/25}
160/9 164/13 164/14
thoughts [1] 76/9
three [8] 24/15 36/24
76/24 127/10 132/7
135/25 137/2 139/23
through [25] 13/12
41/22 44/6 49/8 52/25)
53/5 53/14 59/24
59/24 72/5 72/22 77/3I
82/3 83/7 102/2
131/12 140/4 143/14
143/14 146/10 147/4
147/17 150/2 163/22
165/23
throughout [4] 89/19
99/14 122/9 153/1
throw [1] 146/9
Thursday [1] 114/9
(67) term - Thursday
T
Tifa] 122/19
ticked [1] 28/17
Tier [1] 142/2
time [91] 8/1 8/25
17/21 18/2 24/15
26/20 26/24 31/25
53/10 53/23 54/7
56/15 57/4 66/8 67/7
69/14 72/23 76/16
76/21 77/1 77/8 78/7
78/11 78/13 84/7
86/20 87/2 87/21 88/1
89/13 89/19 90/15
93/10 93/14 95/17
96/13 96/15 98/24
99/15 99/17 99/19
100/13 103/12 105/7
105/25 107/22 111/2
112/16 112/21 113/17)
113/18 119/21 120/23
120/23 121/7 122/19
123/19 125/1 128/2
128/3 130/7 133/7
135/17 139/9 143/23
144/21 146/18 147/9
148/1 148/19 153/22
153/24 153/24 154/22
155/23 158/3 161/2
163/10 163/10 163/19)
166/23 168/16 169/11
time/date/nature [1]
76/16
timeout [3] 101/9
117/5 133/24
times [17] 31/4 48/16
53/20 65/8 74/1 76/24,
92/14 96/3 99/10
118/17 134/3 134/17
153/18 162/5 162/10
163/8 165/24
title [2] 6/16 6/20
to' [1] 76/5
today [1] 2/16
together [1] 151/20
told [46] 15/4 18/7
24/9 24/16 37/8 37/10
38/10 40/5 45/9 45/11
46/1 46/6 48/7 48/8
54/16 54/24 55/3 56/9
58/18 63/4 63/15 93/3
99/11 112/8 113/3
115/20 121/11 121/16}
121/17 136/25 138/25
157/6 157/9 157/10
157/17 157/18 157/19}
160/15 160/25 161/1
166/4 166/5 166/7
167/3 167/4 168/24
tomorrow [3] 131/8
170/5 170/9
32/7 33/2 33/18 34/17
39/9 40/5 47/19 49/12
too [3] 39/3 39/4
167/25
took [18] 12/6 31/15
32/11 34/18 34/21
35/16 35/17 44/15
52/18 70/22 75/1
95/13 116/16 128/19
136/23 155/8 155/10
160/14
top [16] 6/19 30/7
42/19 57/6 68/4 80/11
80/21 89/23 131/1
149/20 150/8 151/6
155/9
topic [3] 51/15 99/20
159/11
total [2] 36/25 78/6
towards [2] 7/13
57/25
trading [1] 34/3
trail [2] 12/7 128/5
trainee [1] 34/7
trainer [1] 34/6
training [4] 33/23
34/2 34/6 34/10
transaction [3]
transactions [5]
41/14 41/22 44/5
122/15 123/9
transcript [3] 97/2
97/6 152/20
Transfer [2] 122/16
122/18
transferred [3] 81/4
81/20 140/10
transparently [1]
56/23
trial [7] 39/14 39/14
40/18 40/24 48/1 48/3
146/20
tried [1] 106/18
true [10] 5/12 55/22
93/4 94/8 96/11
145/22 156/9 156/17
156/19 156/23
truth [1] 142/10
try [4] 134/11 149/9
155/3 155/6
trying [20] 20/19
41/23 48/10 74/25
77/8 94/1 98/24
104/19 120/16 128/1
130/8 146/16 147/10
147/12 148/18 149/9
161/8 162/20 164/7
169/18
Tuesday [2] 1/1
130/22
turn [15] 24/24 31/14
51/14 51/25 62/20
64/23 70/10 87/10
89/22 91/7 94/19
131/11 132/19 149/18)
122/18 134/23 155/13)
99/20 130/21 135/6
149/12
turned [1] 61/24
two [31] 3/11 5/11
23/9 23/23 56/10
73/16 73/18 79/12
83/3 83/18 100/7
104/2 104/7 107/3
110/24 113/21 118/11
125/2 128/2 132/13
134/3 138/14 140/11
140/21 143/1 145/6
157/12 157/20 162/22
164/8 167/13
type [11] 32/23 60/13
64/13 79/18 90/11
124/6 125/13 132/1
143/24 146/5 147/25
types [3] 64/18 64/20
64/21
typing [2] 164/15
164/16
U
ultimately [1] 88/9
um [11] 8/22 13/20
15/11 50/16 52/22
55/12 66/4 77/14 94/1
119/19 165/20
unclear [1] 3/19
under [19] 1/20 6/20
10/8 27/24 28/14 37/7
62/23 80/1 85/6 87/24
90/21 111/2 111/3
115/1 123/17 138/8
140/3 167/7 167/22
underlying [2] 47/8
83/10
understand [27] 2/15)
2/24 14/16 23/6 27/5
28/8 37/16 46/21
47/11 52/10 53/8
53/11 58/10 97/13
104/16 104/18 105/6
105/8 111/10 112/9
120/20 121/4 136/7
136/13 142/1 161/14
170/4
understanding [14]
13/19 42/4 48/22
49/12 95/17 96/8
107/6 112/16 112/17
112/20 160/9 160/17
161/2 161/6
understood [8] 49/20]
60/23 79/25 99/17
120/25 120/25 160/23
161/9
undertake [3] 38/1
47/5 48/24
undertaken [5] 10/12
10/17 20/13 74/3
118/18
undertaking [2]
10/18 45/18
unexpected [1]
117/3
unexplained [2]
37/11 39/16
unfair [1] 39/20
unfolding [2] 70/18
71/19
uninterrupted [1]
77/21
unit [6] 103/4 105/21
106/25 141/9 141/10
141/16
units [4] 140/21
140/23 143/1 143/5
unknown [1] 32/16
unless [4] 109/19
111/9 111/20 112/15
unofficial [3] 133/6
158/2 158/13
unresolved [1]
121/13
unscathed [1]
146/10
unsure [2] 22/15
58/7
until [7] 51/15 83/22
91/12 108/8 122/9
141/13 170/12
unused [2] 67/20
76/2
up [63] 3/16 6/15
12/16 18/14 21/11
28/21 30/20 40/10
42/13 42/22 47/4 49/4)
50/13 53/23 62/24
63/16 63/18 76/11
76/11 76/19 78/1 79/9
80/22 81/6 81/15
82/17 84/21 86/25
87/16 88/13 89/1
91/12 100/3 100/20
101/10 102/4 104/7
117/7 118/4 119/8
123/2 125/2 125/8
125/14 125/17 134/12
134/20 135/6 136/4
137/5 141/13 142/18
144/11 146/7 146/24
146/25 147/2 152/9
152/10 154/5 155/9
158/21 159/9
update [1] 156/18
updated [4] 19/8
168/3 168/6 168/7
updates [3] 168/13
168/19 169/9
updating [1] 156/16
upgrade [1] 168/1
upheld [1] 2/14
upon [6] 2/5 2/13
17/8 17/10 56/18
83/11
URN [1] 3/9
us [46] 1/3 3/4 3/7
7/21 9/7 10/20 15/15
16/11 18/18 19/13
20/8 20/16 21/19
21/20 25/2 30/1 32/1
32/6 36/18 38/5 40/5
46/15 46/19 48/7
48/11 51/22 70/21
72/3 73/11 81/22
83/13 84/14 95/8
98/21 105/3 108/14
115/20 130/18 135/5
136/25 145/4 157/6
157/19 161/19 168/2
169/3
use [27] 13/9 15/4
15/7 16/5 16/10 16/11
17/21 42/23 67/19
77/6 77/10 89/17
92/13 93/3 94/14
96/18 97/23 99/3
110/6 112/8 161/5
161/7 162/4 162/9
163/7 166/5 166/8
used [32] 14/19 15/4
19/10 19/14 44/1
58/23 60/6 95/9 95/18
99/15 113/6 133/20
146/4 148/14 149/8
153/16 154/9 159/18
159/24 161/11 161/12!
161/16 161/18 161/18)
161/19 161/19 162/10)
162/12 163/10 164/25)
165/3 165/6
user [9] 60/23 61/17
115/3 115/3 116/17
116/24 138/19 139/5
139/18
user's [1] 85/14
users [2] 8/24 26/4
using [3] 20/16 89/20)
167/23
Vv
values [1] 140/9
varied [2] 29/20 31/5
various [1] 17/3
vast [1] 20/25
verifying [1] 96/2
version [3] 6/19
114/5 168/3
versions [1] 136/15
very [28] 3/1 5/15
8/17 18/19 37/11
44/10 70/8 71/6 84/10
86/8 91/15 94/25
97/12 98/3 108/10
129/12 129/14 129/17
141/20 144/15 144/15)
145/6 145/15 147/3
147/9 149/5 156/3
158/4
via [1] 128/4
(68) TI- via
Vv
view [6] 2/3 21/17
38/21 39/7 94/4
122/15
views [1] 73/13
visible [1] 123/10
volunteering [4]
133/12 158/8 158/12
158/14
Ww
wait [1] 86/16
waited [1] 119/2
waiting [3] 46/18
117/5 133/24
waiver [1] 161/1
want [28] 31/17
32/13 32/23 33/13
40/19 46/24 49/2
49/24 50/1 55/24
77/20 78/4 79/19 81/3
81/4 81/19 81/20 82/2
82/4 82/5 82/6 97/12
97/13 105/16 142/5
158/20 158/21 167/8
wanted [9] 39/8
41/10 41/19 71/6
72/10 82/7 82/13
86/20 87/6
wants [4] 1/6 1/8
163/16 167/17
Ward [7] 87/19 88/3
90/22 91/2 100/4
100/5 101/18
Warn [1] 123/8
Warnborough [2]
99/21 100/9
warning [1] 73/24
was [488]
wasn't [36] 6/13
14/20 31/3 31/6 31/7
43/13 45/13 45/16
46/11 53/20 54/18
54/22 56/10 57/8 57/9
59/5 74/15 77/13 90/7,
121/14 121/15 125/3
125/20 128/1 146/24
147/22 148/17 148/24
149/2 149/7 157/4
159/10 160/18 161/8
163/13 168/13
way [28] 23/10 23/14
23/16 23/19 23/22
24/18 28/10 30/20
56/6 58/13 59/21 62/7
70/3 80/9 80/12 83/7
113/5 115/17 119/12
125/20 130/4 139/7
139/15 143/10 146/19
151/21 158/13 165/11
ways [2] 23/6 156/20
we [263]
we'd [4] 21/2 72/13
107/9 128/5
we'll [1] 75/20
we're [15] 13/10
21/11 24/14 45/3
51/14 67/9 80/23
82/18 85/9 97/4 100/2
130/24 168/24 169/18)
170/4
we've [17] 20/11
35/25 36/9 36/20
55/21 56/4 83/23 90/7
95/4 108/19 121/24
137/5 142/23 144/10
151/10 156/14 161/1
weather [1] 3/7
Wednesdays [1]
122/12
week [7] 76/25 77/5
122/12 122/20 140/20)
142/25 143/1
weekday [1] 123/3
weeks [3] 41/6
122/21 140/13
well [72] 17/16 20/22
27/5 35/12 41/9 42/10
43/23 44/25 46/10
49/20 50/16 50/20
51/3 59/10 66/6 72/9
74/22 77/1 79/23 83/6
89/3 93/13 94/1
101/24 102/1 102/10
103/1 103/10 105/8
105/8 107/13 115/12
118/25 119/11 119/13)
119/21 121/5 129/7
129/19 135/24 136/4
136/15 136/23 137/12,
138/22 138/23 141/17,
142/12 143/14 147/9
147/16 149/5 150/12
153/1 153/7 153/24
155/9 156/12 156/25
158/14 160/3 160/11
161/5 161/10 161/15
161/22 163/4 164/11
165/22 166/22 168/7
169/25
went [11] 15/3 23/3
A7IT 48/12 52/1 52/16
58/13 72/5 77/17
137/5 141/15
were [231]
weren't [17] 27/12
27/14 45/6 45/9 62/6
64/6 64/10 95/10
99/11 109/22 110/25
121/16 145/15 146/11
148/6 158/17 159/9
West [5] 75/16 83/3
85/23 133/3 150/22
what [274]
what's [10] 42/7 43/1
49/3 92/20 93/18 98/7)
104/19 112/5 142/11
159/23
whatever [3] 61/23
72/1 99/18
whatsoever [1] 87/9
when [60] 12/4 12/5
18/17 24/17 24/17
26/1 27/9 35/8 45/18
45/25 47/25 50/24
52/6 57/11 60/4 60/12
60/15 62/9 62/12 63/1
64/11 77/25 89/12
93/20 95/9 95/21 96/7
96/22 99/4 99/11
111/15 112/23 115/8
115/11 120/2 128/19
131/16 137/17 141/13}
142/7 150/7 152/22
153/2 155/25 156/6
156/19 156/23 159/12}
159/20 159/24 160/17
160/18 160/22 161/23
163/24 168/2 168/4
168/11 168/16 169/18}
whenever [3] 41/24
43/10 61/3
where [27] 6/10 8/7
13/23 15/10 16/12
33/1 46/12 53/24
54/16 58/1 58/7 71/21
74/8 74/9 74/10 97/6
110/14 111/19 115/10}
122/17 131/22 137/5
137/6 138/22 143/16
146/3 148/2
whereabouts [1]
136/9
whether [76] 2/13
2/23 8/6 10/1 14/18
15/15 19/24 21/21
24/5 26/19 26/23 27/9
27/21 27/22 28/9 30/1
31/18 31/19 38/13
38/24 39/1 44/8 48/17
52/6 52/15 54/14
54/23 55/10 55/22
55/24 56/4 56/6 56/19
56/21 64/24 65/15
70/22 70/23 70/24
71/15 71/16 71/17
73/5 73/8 77/7 77/11
77/14 78/10 81/10
82/8 92/4 93/4 94/8
101/25 102/6 102/22
103/8 107/25 108/7
119/3 119/3 119/6
119/9 125/23 129/22
130/4 133/17 133/18
134/2 135/9 135/12
137/20 144/19 152/7
154/8 156/21
which [109] 2/8 3/9
3/14 3/24 4/5 4/16 5/4)
5/5 5/7 6/16 7/12 8/3
8/18 9/15 9/23 11/17
11/23 12/13 12/20
12/23 13/13 15/22
19/2 19/3 20/12 20/12)
20/24 21/22 23/16
24/9 24/10 24/24
24/25 25/15 30/13
37/18 38/4 42/1 44/19)
45/5 45/22 46/20 47/2)
47/3 57/24 59/13
59/17 60/13 60/14
61/13 63/19 64/1 64/6)
65/21 70/21 73/11
74/2 80/15 81/9 81/25)
83/11 84/1 84/19 85/6)
86/1 91/2 91/6 91/8
92/15 100/15 101/14
102/13 103/2 105/20
107/3 111/7 113/6
115/14 117/10 118/7
119/7 122/18 124/7
124/22 126/11 127/4
132/14 133/14 134/6
137/16 149/13 149/15]
150/18 152/3 154/16
155/20 156/5 156/13
156/14 156/20 157/17)
159/20 160/20 162/1
162/6 163/9 164/3
166/7 166/18
while [3] 25/24
153/16 154/9
whilst [4] 106/12
117/4 133/20 167/21
who [58] 2/8 10/18
11/5 14/21 17/7 20/19)
21/3 27/22 28/17
29/10 29/11 32/1
32/10 37/6 40/12
46/16 47/10 47/11
47/16 52/8 52/9 53/14)
54/4 55/5 56/18 57/19
58/8 58/8 58/18 72/6
75/7 87/19 88/3 88/14,
90/15 115/5 121/6
136/25 142/15 158/15)
161/10 161/11 161/16
161/20 162/24 163/1
163/2 163/25 165/10
165/13 165/16 165/17,
165/19 166/6 166/7
166/9 166/20 167/15
who's [1] 56/2
whoever [4] 29/7
53/10 54/6 121/5
whole [11] 7/4 16/5
47/6 79/25 81/4 81/20)
96/3 96/19 136/24
151/9 153/3
whom [2] 7/9 54/15
whose [2] 146/20
148/4
why [35] 3/22 20/8
20/10 41/25 42/6
49/22 50/1 55/15
55/24 64/17 65/6
65/24 66/5 82/10 93/1
110/14 110/19 110/20)
110/22 110/24 111/6
115/24 120/6 130/21
136/22 137/10 149/7
162/22 163/12 163/16)
164/8 164/19 164/21
165/13 167/24
will [27] 1/19 2/12
10/10 10/12 10/17
11/16 11/17 12/19
15/21 40/21 42/24
67/11 67/19 76/14
76/17 77/24 78/5
82/20 84/22 98/13
100/22 123/10 133/10)
146/6 146/9 158/5
162/1
wipe [3] 147/4
147/17 148/16
wish [10] 2/5 2/9
2/20 2/21 3/11 3/24
4/4 4/13 5/2 32/20
within [60] 5/20 7/25
8/2 13/22 15/5 15/13
16/10 17/6 18/2 18/4
19/21 20/1 21/1 47/14
47/20 49/12 49/13
53/8 53/14 54/2 56/14
57/7 57/10 57/13 58/4
59/3 69/22 75/9 89/17,
92/7 96/5 101/9
105/11 106/15 107/8
107/20 109/18 111/9
111/11 111/15 111/18)
111/23 112/3 112/11
112/21 113/2 120/7
121/2 121/6 127/24
128/8 138/14 140/11
158/15 161/21 163/18}
163/19 165/23 166/19}
169/2
without [8] 46/8 47/7
49/5 133/9 139/6
154/9 157/10 157/18
WITN00300100 [1]
25/15
WITN00300200 [1]
3/9
witness [284]
witnesses [3] 17/6
17/10 18/3
won't [2] 42/23 89/7
wonder [4] 83/22
108/7 144/18 164/11
word [4] 142/12
150/10 159/23 159/24)
wording [14] 59/3
94/25 104/19 159/13
159/25 160/1 162/9
162/12 163/21 164/22)
164/24 165/14 165/19)
165/24
(69) view - wording
Ww
words [14] 25/19
39/1 58/23 85/2
105/12 111/20 128/9
147/4 149/8 162/13
162/23 163/7 163/8
164/8
work [47] 5/17 7/22
10/13 10/19 18/20
19/1 19/5 19/6 19/9
19/14 20/1 20/6 20/9
20/13 20/17 20/23
21/3 21/5 21/12 21/16
27/20 37/10 39/1
40/12 43/25 50/8 50/8)
77/21 78/7 79/15
79/25 80/5 103/13
120/24 126/4 128/6
128/20 129/1 129/5
130/20 137/23 153/7
153/8 160/21 169/1
169/2 169/18
worked [10] 20/25
25/11 37/6 37/12 40/8
79/6 83/7 128/24
148/24 159/10
working [48] 17/3
41/11 41/13 41/22
42/2 42/8 43/9 44/22
44/24 62/3 69/5 85/18)
85/21 86/3 86/4 86/7
89/13 92/18 93/11
93/22 93/24 94/2
106/24 107/18 107/22
109/12 113/11 114/24}
117/19 117/20 117/22)
119/1 123/2 124/9
124/10 125/3 125/4
125/20 127/14 129/8
129/20 130/1 130/8
137/17 142/9 143/13
143/20 164/17
workplace [1] 169/12)
world [1] 138/18
worry [3] 42/7 43/6
160/4
would [221]
would've [1] 156/25
wouldn't [25] 23/20
33/17 42/5 42/8 43/5
62/20 62/22 63/1 63/4,
63/10 63/17 63/20
82/10 107/23 111/24
116/4 119/12 128/16
132/2 135/3 137/12
137/14 154/20 154/23
158/23
write [4] 63/18 90/6
111/24 115/24
writing [7] 34/1 34/9
35/12 45/20 45/25
96/15 112/21
written [10] 19/2
24/11 24/12 104/18
105/13 113/6 120/24
134/1 142/11 142/12
wrong [8] 54/25 55/4
55/11 61/15 61/20
139/17 169/7 169/20
wrote [3] 19/6 96/7
165/16
YO
yeah [28] 5/3 9/6
15/14 16/4 22/8 31/3
35/22 52/24 54/12
74/25 74/25 78/21
79/5 86/12 93/9 96/15
96/24 104/14 128/12
137/3 147/24 152/18
152/19 153/7 156/22
157/13 165/9 166/10
year [9] 27/25 30/17
31/4 31/5 31/6 47/3
90/7 92/4 169/11
years [11] 19/9 29/21
59/13 59/17 89/19
96/22 98/20 99/13
124/2 145/19 163/23
yes [298]
yet [7] 1/9 49/23
121/18 154/4 154/14
154/15 155/20
you [951]
you'd [10] 34/6 59/8
103/15 103/25 132/25
133/1 139/6 145/18
151/1 152/24
you'll [10] 7/17 14/14
18/3 28/3 28/16 36/12
41/3 69/9 92/9 100/17
you're [36] 22/15
24/17 24/17 26/10
28/16 49/4 49/14
49/16 50/18 61/18
66/18 74/17 75/6
78/22 78/23 88/24
95/22 96/6 97/7 97/9
98/2 98/5 103/5 128/1
130/15 137/15 147/20)
148/3 152/19 160/12
160/19 165/7 165/13
168/15 169/7 169/20
you've [13] 48/6
62/24 70/3 70/7 71/20
113/3 130/10 136/25
143/10 144/15 151/14)
162/12 169/9
your [173]
yours [3] 40/7 82/25
159/21
yourself [13] 44/12
44/13 45/22 46/2
55/10 55/16 55/21
57/22 58/14 58/18
135/19 136/2 162/10
(70) words - yourself