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The Post Office Horizon IT Inquiry
Thursday, 28 September 2023
(10.00 am)
MR BLAKE: Good morning, sir. Can you see and hear
me?
SIR WYN WILLIAMS: =I can. Thank you.
MR BLAKE: Thank you very much. This morning we're
going to hear from Mandy Talbot.
SIR WYN WILLIAMS: Yes.
MANDY TALBOT (sworn)
Questioned by MR BLAKE
MR BLAKE: Thank you very much. Can you give your
full name, please?
A. Mrs Mandy Talbot.
Q. Mrs Talbot, you should have in front of you
a witness statement?
A. That's correct.
Q. That has your name on the front, dated 31 May
2023; is that correct?
A. Correct.
Q. Can I ask you to turn to the final substantive
page on that witness statement, that's page 36.
Is that your signature at the bottom of that
page?
A. Itis.
Q._ Thank you very much. Is that statement true to
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preservation of relevant data and a more
conducive engagement with Mr Coyne.
Paragraph 24 of my statement, refers to my
request to Bond Pearce not to issue cases
involving Horizon. It meant cases where
subpostmasters had alleged that the Horizon
System was at fault in response to an action to
recover debt. As now disclosed to me from
September 2005 at POL00107426, email to David
Smith of POL, I was seeking to set up
an appropriate system for compiling data and
investigating cases prior to the business
sending matters out to civil litigation agents.
Despite pressing, this was ultimately rejected
on the basis of cost.
Q. Thank you very much Mrs Talbot, that statement,
which is WITN08500100 will be published by the
Inquiry in due course. Those amendments have
been made because, as you've said, the witness
statement was taken some time ago now.
I will take you thematically through various
things and if any of those points jump out at
you at any relevant time then please do feel
free to say as well.
Thank you. You are here today because you
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prop
the best of your knowledge and belief?
It is as, at the time.
Thank you. I believe there are some small
changes that you would like to add now?
That is correct.
Please do feel free to make those amendments
now.
If I may, I wish to make some additional
comments, having received 1,661 pages of further
disclosure that affects my original statement.
I'm now aware that I was updated on the case of
Wolstenholme in March 2004 by Mr Jim Cruise.
This was after Mr Coyne's initial review and his
comments upon the response from Fujitsu had been
received. As can be seen from the documentation
now disclosed to me, Mr Cruise had concerns
about the case and Mr Coyne's initial opinion
and response to Fujitsu. It was for that reason
that counsel was instructed by agents.
I've now also seen FUJ00121724, email to
Colin Lenton-Smith, and report on Cleveleys,
FUJ00080715, of Mr Holmes. I was very surprised
by the contents of the former and agree that, if
Fujitsu had been brought into the matter
earlier, it could have resulted in a possible
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were lawyer at the Post Office. One thing that
isn't entirely clear from your witness statement
is whether you qualified as a solicitor and when
that was. Are you able to assist on that?
Ooh, I am qualified as a solicitor. I joined
the Post Office in 1990, I believe I qualified
about 18 months before that. I can't, after
this period of time, recall the precise date.
You've said in your statement that you worked at
Cameron McKenna and Wilde Sapte?
Yes.
Were those training as a solicitor or some other
role?
No, that was as a junior solicitor. I did my
training contract or articles, as it was then
referred to, at Douglas-Jones Mercer of Swansea,
a provincial firm.
Thank you. You joined the Post Office in 1990
as a legal assistant; is that right?
Correct.
You were in the Civil Litigation department?
Correct.
During your time, it became Royal Mail Legal
Services as well?
Yes.
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The Post Office Horizon IT Inquiry
I think you spent over 20 years in the
department; is that correct?
Correct.
Briefly, can you tell us what kinds of cases
that you were involved in, working for the Post
Office, other than the kinds of cases that we're
going to be talking about today?
Awhole range. Usually small County Court
matters under the Postal Services Act,
injunctions, giving training courses, issuing
proceedings on debt actions, but I'd also done
personal injury work, rent arrears cases. Also
used to assist the chairman's office if they
wanted information and Freedom of Information
action cases.
In 2011, you became part of the regulation team
at the Royal Mail Group?
Correct.
Was that something different?
Entirely. I no longer functioned as
a solicitor. I became -- within Legal Services
Department, I was somebody with legal knowledge
working for Royal Mail Group itself, in a team
set up to arrange for the flotation of Royal
Mail Group as a company.
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I had been a team leader in the Postal
Services team which, as the name suggests, dealt
primarily with matters pertaining to the Postal
Services Act, items lost in the post, County
Court actions, some debt action against parties
who had contracted with Royal Mail for postal
services. But, after 2004, in effect, although
I had the title, the number of people working
within Legal Services meant the title was
a nonentity.
So you had general counsel, did you?
She was referred to, this is Catherine
Churchard, as "the" solicitor but, in effect,
performed the role of general counsel, though
I don't believe she ever had a permanent
position on the board.
Underneath the general counsel, would it be
right to say you were the principal lawyer
dealing with civil matters?
No, that's not correct. There was the Head of
Civil Litigation and I was never the Head of
Civil Litigation.
Who was that, sorry?
At the beginning, Mr Joe Ashton, Clare Wardle,
Biddy Wyles, Rebekah Mantle, so I was there for
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pero
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I think you took redundancy in 2014?
In the September, yes.
Yes. Did you work elsewhere after that, or ...?
No, unfortunately for family reasons it was
necessary for me to help support my
father-in-law, my mother and, ultimately, other
relatives.
Thank you. I want to begin by looking at the
structure of your team. During Mr Castleton's
case, you've been described, I think, as the
litigation team leader or, at one point,
principal lawyer.
Mm.
Can you assist us with that role?
Prior to 2004, Legal Services had a large number
of in-house solicitors. In 2004, the then
solicitor, who was, in effect, the Head of Legal
Services, offered everybody and anybody who
wanted it redundancy on quite good terms.
I think, to the best of my recollection,
only four members of staff in the whole of Legal
Services were prevented from accepting the offer
of redundancy. There was no structure involved
at all and so teams were, in effect, decimated.
So that was 2004.
along time, and then when I was a team leader,
I was on a direct report to Joe Ashton but,
after that role disappeared, I was on a direct
report to Clare Wardle, Biddy Wyles, Rebekah
Mantle and they, in turn, would report upwards.
So although described as the litigation team
leader or principal lawyer, it was, in fact, the
case that you weren't the leader at all?
No.
Was there somebody in an equivalent position
dealing with criminal matters?
The -- equivalent to myself? There were --
prior to the reduction in headcount, there were
many caseworkers like myself in the Criminal Law
Department, but the Head of Criminal Law was Rob
Wilson.
Who would his equivalent have been in your team?
That would have been Joe Ashton, Clare Wardle,
Biddy Wyles and Rebekah Mantle.
The impression that you've given is that those
who remained in the team after 2004 were few in
number and quite stretched; is that fair?
That is correct.
Do you know why the redundancies were offered at
that stage?
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To the best of my recollection, this is probably
my opinion, in 2004 there was a desire on the
part of the corporation to have a reduction in
headcount and I believe that is the reason for
the offer of mass redundancy.
In respect of actions against subpostmasters,
whether they be criminal or civil, was there
anybody in the team that had an overview of the
work that was going on?
Neither in the -- not in Civil Litigation or --
this just speculation -- or Prosecution team,
because prosecution was an entirely different
specialism.
In the Civil Litigation Team, we're going to see
that you were involved in a number of actions
against subpostmasters. Did anyone have
oversight or a general view of alll of those
cases?
No.
In terms of Horizon, did you receive any
training on the system?
I received a one-hour training course very, very
early on with people trying to explain lots of
moving parts on a whiteboard, and that was it.
Do you think that was a similar experience of
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Itis.
Were you given such a strong assurance and who
by?
I cannot put a name but I got the distinct
impression that this was a system of which
Fujitsu were incredibly proud and, as I say,
anecdotally in my statement, there was
a suggestion that they were so proud that there
was a desire to sell it to other organisations.
You said you got the impression. Where did that
impression come from?
Numerous dealings with Fujitsu over the years.
Who, in particular, did you deal with at
Fujitsu?
Usually, when I dealt with Fujitsu, it would be
in respect of a particular piece of litigation
or case but, also, as you can see from the
correspondence, they were copied in to numerous
matters that I was dealing with, both with
themselves and POL.
Who in particular do you think gave you the
impression that the system was "infallible"?
I would be lying if I tried to put a name to it
after this period of time. I'm very sorry.
Can I take you to your witness statement, that's
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your colleagues within the team?
Within Civil Litigation, yes. I can't speak as
to any of the other teams.
I want to talk about your knowledge of bugs,
errors and defects in the system. You've said
this morning you've been receiving a number of
different documents before today. But apart
from the corrections that you made this morning,
are you content with the words that are in your
witness statement?
Generally, yes.
Did you give consideration to terms that were
used? For example, you have described, in
respect of the Horizon System, that it was
"infallible". Is that something that you were
told?
Possibly not the word “infallible” but I was
given the distinct impression that it was
a perfect system and that any minor bug or
glitch was quickly identified, its footprint
made plain and that these were things that
Fujitsu would search for if we ever asked them
for information as to the running of
a particular branch.
"Infallible" is quite a strong word?
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WITN08500100, please. It's page 27 of that
statement. It's paragraph 62. Thank you.
You say there, at the bottom of the page:
"Looking back, I obviously have concerns
about the cases I was involved in knowing now
that there were problems with the Horizon System
but that is with hindsight and the knowledge
that has come into the public domain. At the
time when Civil Litigation was instructed to
obtain repayment of money by POL via legal
agents, we genuinely believed the position
adopted by Fujitsu."
Can you tell us when it is that you have
obtained -- you say “with hindsight", with the
information from the public domain, since --
since when did you know that it was not
infallible.
The case of Bates, and the increasing amount of
publicity about the Horizon System in the press.
Do you really think that it was not until Bates
that you didn't have sufficient information to
cast serious doubts on the reliability of the
Horizon System?
I left Civil Litigation in January 2011 to go
into a very different world, a very labour
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intensive job. I didn't really think anything
about Horizon, from the time I entered Royal
Mail Group as a non-lawyer to the time of the
eventual class action.
During the years that you were working in Civil
Litigation though -- 2004, 2005, 2006, 2007,
2008, 2009, 2010 -- did you not feel you had
enough information to cast doubt on the
reliability of the Horizon System?
I really, really didn't. In 2010, looking at
the additional documentation that's been
supplied, I believe -- and this is just my
opinion -- that concerns were maybe arising
within POL itself but, you know, even through to
the summer of 2010 with the Rod Ismay report --
and I know there has been serious criticism of
that -- we were still being assured that the
system was robust and fit for purpose.
Who by?
Well, there were -- there was Mr Rod Ismay
himself and the other senior partners to which
his report were copied to.
Okay, we'll get to that report in due course but
is it your evidence then that, internally within
the Post Office, you were being convinced that
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on 17 January 2001. He says there in the first
paragraph:
"At that time the losses were £14,000 and
the [subpostmistress] was refusing to make them
good blaming the losses on the Horizon System
which had been introduced in February 2000 at
her office."
If we look at the third paragraph, the final
sentence there, it says:
"[Mrs Wolstenholme] asked for proof that the
losses were her fault and caused by computer
failure. She also asked for copies of all error
notices but Chesterfield said that these were
not available."
Can we go over the page, please. The second
line there says:
"The CC [that's the counterclaim] is that
the contract was wrongly terminated; the
computer system was unfit for its purpose and
throws in the Human Rights Act", and other
regulations as part of the counterclaim.
If we go down to the fourth paragraph he
summarises there at the end of that paragraph,
he says:
"She declined to settle saying the losses
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the Horizon System was robust?
I can only speak as to the situation within
Civil Litigation. I cannot speak as to the
actual position in Post Office Limited at the
time.
But you spoke earlier of being reassured by
Fujitsu and now you've mentioned Mr Ismay. So
was it from outside and also within that you
were being reassured about the robustness of
Horizon?
From within Post Office Limited and Fujitsu.
Yes.
I want to begin with the Cleveleys case that we
looked at before the summer break. Can we look
at POL00118236, please. We're here in March
2004. Could we scroll down, please. There's
an email from Jim Cruise to you. Can you tell
us who Jim Cruise was, please?
He was a member of my team. Formerly, he had
been a member of the Prosecution team and, very
unusually, a number of years earlier, he had
transferred from that specialism over into Civil
Litigation.
He is there summarising the case of
Mrs Wolstenholme. He says that it started back
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were not accepted as her fault but let [the Post
Office] remove all the equipment other than the
computer equipment."
The next paragraph, if we could scroll down
slightly, thank you very much, says:
"Since then ..."
So this about an offer to settle:
he report of the computer expert, Best
Practice [Limited], based on the available call
logs has been received and as you are all aware
is unfavourable and unflattering to Fujitsu if
not actually hostile. In light of the report,
which cannot really be challenged, I do not
think that POL will be able to prove, even on
the balance of probabilities that the losses
were the fault of the [subpostmistress] and our
agents are still concerned about the lack of
evidence for the losses."
Next paragraph, he says the advice that he
is going to give the Post Office, he says, about
halfway down that final paragraph:
"L intend therefore to advise that [the Post
Office] should pay [Mrs Wolstenholme] or pay
into court the figure of 3 months' remuneration
plus interest on the basis that although it is
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unlikely that POL can now prove the losses were
her fault alone, as per the contract for
services, [the Post Office] can give 3 months’
notice without giving reasons and this is all
she will be able to obtain by way of damages in
any event if she takes the matter to trial."
So you were aware, in March 2004, that there
was this case against Mrs Wolstenholme and that
it was her case that the Horizon System was at
fault; is that right?
Yes, correct.
And also that there was an expert report that
was unfavourable to the Post Office?
Correct.
Why is Mr Cruise updating you in this email? Is
this your first involvement in that case?
I believe it was my first involvement and it
would have been part of Jim's preparation for
leaving Legal Services via the mass redundancy.
So is he passing the case on to you?
The case was actually out with Weightmans who
were one of the firms of external agents. In
effect, he was passing on to me the in-house
role in respect of the case.
That somewhat minimises the role of the Post
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a matter of keeping an eye on the costs and, if
anything unusual or untoward occurred, we would
then try and assist the external agents to the
best of our ability to achieve a successful
resolution for POL.
Is it, therefore, your evidence that you weren't
in some way directing the actions of the law
firm, with regards to, for example, settlement.
Until such time as this email, I would have had
no involvement in this case whatsoever.
Thereafter, given the concerns expressed,
I probably would have endorsed their decision to
go to external counsel.
Can we look at the actual report from Best
Practice Group, that's Mr Coyne's report. It is
WITN09020115. It's a report that's well known
to the Inquiry. We've heard from Mr Coyne. If
we look at page 2, please. He says:
"I have been contacted by Weightman Vizards
a law firm representing ‘Post Office Counters
Limited’ and Mrs Julie Wolstenholme,
an individual ..."
Were you aware that Mr Coyne had been
instructed jointly both by the Post Office and
Mrs Wolstenholme?
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Office, though, because you are instructing
Weightmans, aren't you?
At that time, because of the mass redundancy,
Post Office Limited were entitled to take
matters directly out to our external legal
agents, without referring the matter to in-house
solicitors. This case, I believe, might be
slightly different in that, I believe, from
the -- from this document that Jim himself had
issued proceedings for the return of Post Office
Limited property at her branch and it was only
thereafter that it was referred out to
Weightmans, our agents.
Trying to understand how things would operate in
the generality of cases, are you saying, then,
that the external law firms had significant
discretion as to how they carried out their
practice and were not instructed?
There was this massive redundancy, followed by
quite a lot of work that wasn't conducted by
myself, setting up agreements with a network of
external agents, under which Post Office Limited
could give instructions directly to external
agents and, insofar as we within civil
litigation were usually involved, it was
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Not at the time of the email that we previously
looked at. Not at the time I made my original
statement but, with the additional disclosure,
lam now aware.
Were you aware at the time? I mean, this report
is January 2004. Presumably, you would have
received this report?
Personally, no, not until such time as
I received the email communication from Jim
Cruise. Then I would have been made aware of
this report.
So on receiving his email of the 17 March 2004,
did you then read the expert report?
\ did.
You did. Were you, therefore, aware that it was
a jointly-appointed expert report?
At that time, I would have been, yes.
Were you aware of what that meant in respect of
the importance of it, in respect of the fairness
of it?
Yes.
What did you understand by the importance of it
and the fairness of it?
That the report or initial observations, as he
actually terms it, would have been created for
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the assistance and benefit of the court.
Can we scroll down the page, please. I'll just
highlight some parts of this report. We've
already looked at them. This is where Mr Coyne
refers to the statement from Ms Elaine Tagg, the
Retail Network Manager, and it's a section from
her witness statement in those proceedings,
where she said:
"Mrs Wolstenholme persisted in telephoning
the Horizon System Helpdesk in relation to any
problems which she had with the system
generally, these problems related to the use and
general operation of the system and were not
technical problems relating to the system."
Mr Coyne then says:
"This, in my opinion is not a true
representation on the evidence that I have had
access to. Of the 90 or so fault logs that
I have reviewed, 63 of these are without doubt
system related failures. Only 13 could be
considered as Mrs Wolstenholme calling the wrong
support helpdesk requesting answers to ‘How do
I ...?' type training questions."
He says:
"The majority of the systems issues were
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support operator stating: 'They all freeze, but
if it gets bad give us a call and we will
investigate’.
"From 31 October ... there seems to be
a number of logs which talk of ‘large
discrepancies’ in stock figures, trial balances
with ‘all sorts of figures showing minus
figures’ ..."
He references a call log and he says:
... there is a comment noted by the support
operative that ‘[the postmistress] advised that
this is an intermittent problem occurring since
the counters were upgraded ...' Although the
documents do not list an upgrade taking place,
it does seem that these ‘large’ reported
discrepancies occur very frequently and shortly
after the noted upgrade."
If we go over the page, please, he then
summarises his opinion and he says:
"From a computer system installation
perspective it is my opinion that the technology
installed at the Cleveleys sub post office was
clearly defective in the elements of its
hardware, software or interfaces."
"Clearly defective" is quite a strong term,
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screen locks, freezes, and blue screen errors
which are clearly not a fault of
Mrs Wolstenholme's making, but most probably due
to faulty computer hardware software, interfaces
or power. In fact, on a detailed view of call
11021413, dated 2 November 2000, Ms Tagg may
have witnessed firsthand the style of system
problems that Mrs Wolstenholme experienced in
her operation of the system. The fault log
notes that: 'Elaine reports that one of the
counters has a blue screen with the message [and
it gives the message]' and was advised by the
operator to 'reboot’.”
Could we go over the page, please. He then
gives his opinion. He refers, for example, to
system freezing:
"System freeing’ which is most probably due
to either the hardware or interfaces crashing;
or alternatively fully saturated communication
lines."
If we scroll down to the final three
paragraphs on that page, he says:
“It is interesting and certainly warrants
further examination that in November 2000 the
‘system freeing’ is reported again with the
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isn't it?
Yes.
Did that not surprise you at the time?
Mr Coyne had created this report, or so
I believe, on the basis of a review of the
pleadings and the HSH logs. Subsequent to this
document being received, Fujitsu then took the
opportunity to comment upon the same.
I believe, though I haven't been shown a copy,
but Mr Coyne then commented upon their opinion
and, ultimately, Fujitsu wrote to Legal
Services, again disputing the conclusions
reached by Mr Coyne, but being open to inviting
him to come and visit engineers and their
facilities, to take him through the Horizon
System.
You, at this stage, a qualified solicitor, who
had been practising for some time, you receive
an independent expert's report, jointly
appointed, that says that the technology
installed was clearly defective. Did that not
cause you to pause a little on your view of the
robustness of the Horizon System?
It was expressed to be an initial report, and
I took the view that Fujitsu being so open to
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inviting him in to discuss the matters further
was further evidence of their conviction of the
robustness of their system.
It didn't cause you to be worried in any way
about the impact that this might have?
I was advised by Fujitsu that the system in 2004
was very different to the system in 2000, under
which -- the 2000 system -- data was disposed
of, I believe, after a period of 18 months. The
system in 2004, I was assured was much more
robust.
Who told you that?
That would have been the people I was speaking
to in Fujitsu.
Can you please give their names?
Oh. After this period of time, I'm sorry,
I can't.
Okay, well, perhaps over the lunch break you can
look at the papers you've been given and you
might --
Yes.
-- recall more. But, in respect of say, the
period, then, 2000 to 2004, were you not worried
about the impact that this opinion may have had?
No, because I was assured it was on a unique set
25
"She was talking about taking the option to
admit the report and concede the contents are
an accurate reflection of what happened (the
[Horizon System Helpdesk] transcripts are
an accurate reflection of what happened it's
just the 'Expert’ opinion is the problem). The
liability question is removed and it's then just
about ‘how much to go away and keep your mouth
shut’.”
Now, Stephen Dilley's evidence to this
Inquiry is that you speak in a way that is
“eminently quotable", was his words. Now, are
your words that are quoted there, "how much to
go away and keep your mouth shut"?
It's a minute created -- sorry, it's
a communication created by Jan Holmes. It
really doesn't sound like me. Possibly, I am
“eminently quotable" but I really don't think
I'd have expressed myself in those terms.
Why would that be the best approach if you
weren't at all worried about the report from
Mr Coyne?
We had a situation with the original
documentation in Castleton -- I'm sorry, the
original documentation with Mrs Wolstenholme was
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of facts that had occurred in 2000 and, in 2004,
it simply couldn't happen.
So you weren't at all worried, no?
No.
Well, can we look at FUJ00121637, please. This
is an email from Jan Holmes of Fujitsu to Colin
Lenton-Smith, and he says:
"Jim Cruise has taken early retirement so
I ended up speaking to Mandy Talbot, who was his
boss."
Now, you're described there as Jim Cruise's
boss; is that right?
Correct.
That's correct.
"The [postmistress] rejected the offer that
was made to her some time ago and a trial date
has been set ... [The Post Office] are still
taking advice as to how best to deal with this
and Mandy's view/belief was that the safest way
to manage this is to throw money at it and get
a confidentiality agreement signed. She is not
happy with the ‘Experts’ report as she considers
it to be not well balanced and wants, if
possible, to keep it out of the public domain.
This is unlikely to happen if it goes to court.
26
relating back to 2000. The original
documentation, plus the original records on the
Horizon System, were no longer available. All
that was left was the HSH logs.
We had members of Fujitsu who were happy to
create witness statements to go to court to
adduce to the effective working of the system,
but we did also have a jointly-appointed expert,
albeit creating only a preliminary view.
I took the view that, if the matter went to
court, it was unlikely that the evidence of
Fujitsu would be persuasive. As such, the
effective way of dealing with such a litigation
is try to resolve it by making an economic
settlement.
That all sounds very reasonable, Mrs Talbot, if
I may say. But why confidentiality agreement?
Why "keep your mouth shut"? Why would you want
to hide what had happened in this case?
I had absolutely no desire to hide what had
happened in this case. If the matter was
settled, there would be no need for the expert's
report to be disclosed in court. If the matter
were not capable of being settled, then it would
have been disclosed in court.
28
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Itwas an unhelpful statement. You are
describing here to Mr Holmes that you would like
Mrs Wolstenholme to sign a confidentiality
agreement and the words there, whether they're
exactly the phrase you used or not, are
effectively to silence her. If this was simply
a matter of not having the right documentation
to prove the case, why would that have been
necessary?
The settlement negotiations, I believe, were
dealt with by Weightmans. I'm not certain how
much more involvement I had in this matter after
this time.
So you did not mind if publicity were shined
upon this case?
No. I mean --
Nothing to hide?
In effect, if it had gone into court, at that
time, then it might well have had an impact upon
POL and its relationship with Fujitsu but so be
it.
Absolutely nothing to hide?
No.
Didn't want to hide it from the public view?
No.
29
"Prior to this point, a number of errors
and/or deficiencies had arisen in relation to
Mrs Wolstenholme's Post Office accounts."
If we continue over the page to
paragraph 10, please. Counsel continued:
"Mrs Wolstenholme has defended the
proceedings, claiming the computer system
installed by the Post Office was defective and
this was, in fact, the cause of the losses
recorded within her accounts."
Paragraph 11:
"The trial of this matter is now about one
month away. A joint computer expert's report
has been obtained. This report concludes, from
the limited records available, that the computer
system installed by the Post Office did appear
defective."
Over the page, please, to paragraph 13:
“lam asked to advise in relation to quantum
and evidence. I am asked to take into
particular account that the Post Office is
anxious for the negative computer experts’
report to be given as little publicity as
possible.”
Now, that is directly contrary to the
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The Post Office Horizon IT Inquiry
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Can we please look at POL00118229, please. This
is an advice on evidence and quantum. If we
turn to the final page, page 18, if we look at
the bottom of the page, we can see it's written
by counsel at 9 St John Street in Manchester.
Can we turn back, please, to the beginning and
perhaps we can start at page 2, paragraph 4.
26 July 2004. The author, counsel, writes:
"The Horizon computer system did not operate
smoothly at all times, and a support help line
was set up manned by personnel from the company
which supplied the system.
"Mrs Wolstenholme claims that she had
enormous difficulties with her computer system,
and that it frequently malfunctioned, causing
inaccuracies in stock and other figures to
arise. She claims that she repeatedly contacted
both the helpline and the Post Office about
problems she was encountering, but little
effective was done to assist.
“In November 2000, Mrs Wolstenholme became
so disillusioned with the computer system that
she decided to stop using it. This was in
breach of her obligations to the Post Office and
she was duly suspended.”
30
evidence that you have just given. Why do you
say that was not your instruction?
I did not instruct counsel in this matter. It
would have been our external agents. It's true
that adducing the report in court would have not
been great for Post Office Limited but,
ultimately, if it had to happen, it had to
happen.
If your view at the time was nothing to hide --
Mm-hm.
-- why on earth would your solicitors have got
the impression that the Post Office is anxious
for the negative computer expert's report to be
given as little publicity as possible? Where do
you say that was coming from?
I can't comment.
You did nothing to give them that impression
that that was your instruction?
I genuinely cannot remember, after this period
of time, I'm sorry.
We'll continue going through the report and
perhaps some of that might refresh your memory.
Can we look at paragraph 17, please:
“In view of the negative expert's report in
this case regarding the computer system in
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The Post Office Horizon IT Inquiry
place, Mrs Wolstenholme's suggestion that the
errors that arose were the result of defects in
the computer system must be taken seriously. It
is sufficient to place genuine and significant
doubt on the evidence relied upon by the Post
Office."
Was that communicated back to you, counsel's
position that there was genuine and significant
doubt on the evidence being relied upon by the
Post Office?
I cannot recall.
Can we look at paragraph 49, please. That's the
bottom of page 15, top of page 16. It says
there:
"On the basis of the above it can be
concluded that the Post Office claim against
Mrs Wolstenholme will fail, save for the return
of the equipment which she has possibly
retained. Her claim against the Post Office in
respect of failure to give proper notice is
likely to succeed. What is the appropriate
course of conduct in the circumstances,
particularly given the desire of those
instructing me and the Post Office to avoid, if
possible, publication of the negative experts’
33
relationship, why Cheryl Woodward and I think --
is it to Cheryl Woodward and copied to you?
Cheryl Woodward worked in one of the departments
in Post Office Limited that were entitled to
instruct regional agents, like Bond Pearce,
directly. Ergo the instructions to issue
proceedings against Mr Castleton were authorised
by Ms Woodward.
So that's a direct instruction from somebody
within the Post Office who is not a lawyer --
Correct.
-- but copied to you, who is a lawyer?
No. This is a communication from Stephen Dilley
after he had taken over conduct of the Castleton
matter going back directly to his original
instructing -- to his firm's original
instructing party, Cheryl Woodward, copied in to
me because of the concerns over his firm
permitting judgment in default on a massive
potential counterclaim being issued.
You were a lawyer involved in civil litigation
in the Post Office --
Correct.
-- being copied in to an email from Mr Dilley,
who was acting for Bond Pearce, the law firm
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report in the public arena?"
Now, if the Post Office had as much
confidence in the Horizon System as your
evidence has been earlier today, why on earth
would they want to avoid publication of that
expert's report?
Because I think it might have affected the
relationship between Post Office Limited and
Fujitsu, but that is purely my opinion. I can't
speak to Post Office's intentions.
Having read Jim Cruise's email, having read the
expert report, at this point in time was it not
dawning on you that the Horizon System might not
be as infallible as you indeed thought?
I can categorically say no. At that time, it
certainly didn't.
I'm going to move on to the case of Lee
Castleton. I'm going to start in 2005. Can we
look at POL00107423, please. Thank you. Can we
start at page 7 of this. It's a chain of
emails. Thank you. At the bottom of that page
we have an email from Stephen Dilley to Cheryl
Woodward and copied to you. Can we just scroll
slightly above that, please, just to see who
it's to and from. Can you tell us the
34
instructed in this case --
Right.
-- presumably copied in because you were
a lawyer; is that right?
I was copied in because of the fact that they
had permitted judgment to be entered in default.
This meant that it wasn't being dealt with as
business as usual. They had to come back to us
at Legal Services and explain what had occurred.
For that reason, I was now being copied in.
So was there a threshold of seriousness before
which it wouldn't get to the legal team but
beyond which it would have to be copied in or
the legal team involved in some way?
I had nothing to do with setting up the
contracts for outsourcing. But, by any ream,
permitting a potential counterclaim of £250,000
to be entered against your client would justify
contacting Legal Services, yes.
We're here in October 2005, was this the first
involvement that you had with the Castleton
case?
There's a possibility that I might have been
asked for contact of people within Post Office
Limited via the solicitor who was dealing with
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The Post Office Horizon IT Inquiry
the case prior to Mr Dilley.
If we look at the first paragraph in his case
summary, he says:
"The Post Office's claim is for
approximately [£27,000] plus interest and costs
in respect of net losses. Clearly, Mr Castleton
is contractually responsible for any losses that
the Post Office makes caused by negligence or
error. However, the real issue is whether there
has been any real shortfall, or whether this
shortfall has really been generated by computer
error. To win, the Post Office must show that
there has been a real shortfall."
If we go over the page, he summarises some
reports that -- sorry, over one more page, thank
you, to page 9. There's a blank page that
follows but it's over the page, thank you.
He refers to some reports that have been
obtained by Mr Castleton, one from Bentley
Jennison and one from White and Hoggard, and he
says about halfway down that bottom paragraph
that:
"Mr Castleton's Defence, ‘appears to hold
potential merit based on the limited
documentation’ ..."
37
of it case against Castleton is being challenged
and his counterclaim dwarfs the size of the
claim. The adequacy of the records obtained
from the Horizon System is being challenged. As
the business chose to give summary termination
instead of three months’ notice it is required
to physically prove the loss. If the Horizon
evidence is not up to the job this will have
serious ramifications for the business."
You were recognising there that, if there
was a successful challenge to the Horizon
System, it would have serious ramifications; is
that right?
Correct, yes.
Yes. Is that following your experience from the
Cleveleys case, where the Horizon case was --
the reliability of Horizon was called into
question?
No, it really wasn't. I mean, my major concern
about the matter of Castleton was the sheer size
of the counterclaim, £250,000, and the cost of
putting a full defence together, because I was
concerned the proceedings had been issued in the
first place because the paper documentation that
should have been in place prior to proceedings
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This is a quote from Bentley Jenison in
their report. He is passing on that information
to you. He says:
"White and Hoggard reach a similar
conclusion in their report."
Can we go back, please, to higher up the
email chain, page 5. At the bottom of page 5,
please, this seems to be you forwarding that
email to various people. Can you assist us with
who the recipients are? Carol King, Nicky
Sherrott, Jennifer Robson.
Clare Wardle was my immediate line manager at
the time. Nicky Sherrott was, I believe, Head
of Commercial, might even have been performing
the role of Acting Head of Legal. John Legg and
Carol King were Post Office Limited employees.
I'm going to read from your covering email, if
we could scroll down the page over to page 7,
please.
It'll be over the page again. I think these
were original hard copies, which were
photocopied, which explains the blank pages.
You say:
"This is a case where the adequacy of the
evidence which [the Post Office] has in support
38
being issued wasn't.
But the final sentence there:
"If the Horizon evidence is not up to the
job this will have serious ramifications for the
business."
It seems as though your concern, actually,
is about the adequacy of the Horizon System and
the ramifications that that may have; is that
wrong?
That's what I said at the time but, in reality,
it was the sheer size of the counterclaim and
the cost and expense that we knew we would be
put to in defending a full challenge.
We've seen before counsel's advice about the
Post Office wishing to avoid publicity. We saw
that time and again in relation to the Cleveleys
case. Isn't this much of the same thing?
No.
Can we look at the first page of this chain,
please, and the bottom of the first page. We
have there an email from Dave Hulbert to Carl
Marx -- not the Karl Marx, a different Carl
Marx. Can you tell us who they were?
I have no idea who Carl Marx was, which is
surprising, given his name. Dave Hulbert,
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I believe, worked in -- I believe worked in
Fujitsu or was a liaison between POL and
Fujitsu.
We also have there Keith Baines. That's higher
up the chain, in effect.
I can't remember their title.
He was the Horizon Contract Manager at the Post
Office; do you recall that?
(The witness nodded)
Looking at that bottom email, though, can we
scroll down, please. Carl to Dave, it says in
the second paragraph:
"I've also copied below a response you
provided some weeks ago relating to a different
case, (Smallbridge) about the system creating
discrepancies and it would be worth having your
view on whether this provides useful supporting
evidence, particularly in countering the
Experts’ Reports (referred to in Stephen
Dilley’s email)."
Now, do you recall a case of Smallbridge,
where there were discrepancies?
Absolutely not but what you have to appreciate
is that there was never, ever an overriding
system that gave Civil Litigation visibility of
41
No. It's not.
At this time, were you telling people about, for
example, the Cleveleys case that you had, where
a joint expert had said that that simply isn't
right?
I wasn't telling people about the Cleveleys
case. As far as we were concerned, that had
been concluded.
You had an independent jointly-appointed expert
who was saying that describing it as robust
simply wasn't right. Do you think it might have
been worth, during that period of time, to have
told more people within the Post Office?
It was expressed to be a preliminary report.
I viewed it as a case in isolation.
Can we look at POL00070574, please. This is
7 November 2005, so we're still in 2005,
an email from Stephen Dilley to Stephen Lister,
and he summarises much the same. He says:
"As you are the relationship partner for the
Royal Mail, I thought it would be helpful to
update you in relation to a case I am dealing
with for them in case Mandy Talbot mentions it.
I recently inherited this case from Denise
Gammack when she left the firm, who in turn
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all Post Office Limited matters.
If we look at the top, if we go back a page to
page 1, we see Carol King at the Post Office,
Jennifer Robson, Debt Recovery Section Manager.
They're all in receipt of this chain of emails.
Mm-hm.
Was that not something that was ever bought to
your attention?
I cannot recall after this period of time.
If we stick with page 3, please, we can see at
the bottom of page 3, this is Carol to Dave, and
he says that he's copied certain wording from
the Smallbridge case, and it says there at the
bottom:
"In summary, the system is very robust. In
‘our experience it very seldom loses transactions
unless equipment is physically removed from
site; if it does lose transactions Post Office
procedures should quickly identify discrepancies
and they should be followed through with
Helpdesk assistance within a week."
Now, do you know where that draft wording
came from? Are you able to assist? Is that
a phrase that you heard, a form of words that
you heard repeated?
42
inherited it from [somebody else]."
If we scroll down to the third paragraph,
please, he says there that:
"[Mr Castleton] has obtained 2 experts’
reports which conclude that the [Post Office's]
Horizon computer System, despite the suspense
account entry, has failed to recognise the entry
‘on the daily snapshot and that Mr Castleton's
Defence, ‘appears to hold potential merit based
‘on the limited documentation’ they have so far
reviewed."
They say further down the page:
"We take instructions from Cheryl Woodward,
Agents Debt Team, Chesterfield but Mandy Talbot
is copied in on emails. I spoke to Mandy last
week to take instructions and her first question
was why Bond Pearce had issued the claim when
reliability was unclear."
So it seems clear that you did provide
instructions to Stephen Dilley, from that
phrase?
At that stage, yes.
"I informed Mandy that my colleagues had
expressed concern to Cheryl about issuing."
Then, if we could scroll down, there's
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a paragraph there about snapshots missing,
certain information missing, and then it says
this, it says:
"Mandy's next comment was that Cheryl may
not have had authority to tell Laura to issue
a claim but I was able to tell Mandy that Cheryl
had referred this question to her Managers
before instructing Laura to proceed.
"In any event, Mandy has instructed me to
put forward an offer of mediation to try to
settle the claim."
Now, did your previous experience in the
Cleveleys case influence you in some way on
receiving that email, on receiving that
information, to want to settle this case as
quickly as possible?
A. No, we wanted to settle the claim because it was
‘one where a counterclaim had been issued for
£250,000 and, even in 2005, that was a serious
amount of money. I was also concerned by the
fact that, when proceedings had been issued, the
paper in support of the claim wasn't in
apple-pie order. That was why I was concerned
that instructions had been issued given to issue
proceedings in the first place.
45
with this case."
Why were you tired with this case at that
time?
A. Itwas taking up an awful lot of resource.
Ordinarily, subpostmasters' cases, for me
personally, would take up one/two hours a week
maximum. This case was beginning to take up
substantial periods of time.
Whether I expressed being tired with it,
it's quite possible I did use that word.
Q. Was it that Mr Castleton wasn't accepting
a payout at that stage, like in the Cleveleys
case?
A. Absolutely not.
MR BLAKE: We're going to move now to 2006.
Sir, that might be an appropriate moment to
take our mid-morning break. It's slightly early
but I think it is a natural break. Perhaps we
could --
SIR WYN WILLIAMS: = That's fine, Mr Blake what time
shall we resume?
MR BLAKE: If we resume at 11.30, please.
‘SIR WYN WILLIAMS: Okay, yes.
(11.08 am)
(A short break)
47
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Q. So it continues to be your evidence that the
Cleveleys case was in no way relevant to your
thinking --
That was my evidence.
Q. --in the Castleton case? Can we look at
POL00072402, please. We're still in November
2005. This is an attendance note made by Bond
Pearce. JMS1 is Julian Summerhayes. I believe
he is from Bond Pearce. It says there:
"JMS1 want to know whether there was any
evidence at all of the monies that were alleged
by Royal Mail to be outstanding? MT [that's
you, I believe, Mandy Talbot] indicating that
she had gone through the file but was certainly
not able to find any manual documents to confirm
this. JMS1 talking through a few of the issues
in the Reply and Defence to Counterclaim and
saying he had slightly amended that from the
version that had been sent through earlier."
It ends on this, it ends:
>
"She was still not sure why the firm had
been given instructions to issue. She will
revert soonest.”
In fact, it also says:
“MT [that's youl talking about getting tired
46
(11.30am)
MR BLAKE: Thank you, sir.
Mrs Talbot, before we broke -- I'm going to
summarise the position as far as I understand
it - on Cleveleys, your evidence is you didn't
have anything to hide; is that right?
A. Correct.
Q. In respect of Castleton, you wanted to settle
Castleton because of the size of the
counterclaim; is that correct?
‘A. And because of missing paper documentation.
Q. But in respect of Castleton, like Cleveleys, is
it your evidence you had nothing to hide?
A. Absolutely nothing to hide.
Q. Can we look at POL00072669, please. This is
an attendance note we looked at with Mr Dilley,
24 February 2006. He summarises a telephone
conversation that he had with you. Can we
scroll down a little bit, I'll just read those
two paragraphs.
He's recalling a discussion with you. He
says:
"Internally the Post Office feels conflicted
about which direction to go in with the
Castleton case. The Post Office believes the
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The Post Office Horizon IT Inquiry
Horizon System is robust, but the downside is
the cost (in Post Office's time and money) in
proving a negative (ie that there are no faults)
and that is expensive. For example, Mandy would
need to get a report from Fujitsu (who
apparently have difficulty writing in plain
English) and get someone in the Post Office to
review Fujitsu data to see if there are any
anomalies.”
It goes on to say:
“It is Mandy's view that the Post Office
must not show any weaknesses and even if this
case will cost a lot, there are broader issues
at stake than just the Castleton claim: if the
Post Office are seen to compromise on Castleton,
then the 'the whole system will come crashing
down’ ie it will egg on other subpostmasters to
issue speculative claims."
Pausing there, is that what you told Stephen
Dilley in February 2006?
It may have been, as expressed in paragraph 1,
Post Office genuinely believed that Horizon was
a robust system and it felt -- I believe Post
Office felt the need to demonstrate that it
would take a firm line with any and all
49
itself. We believed that it was a pure
accountancy issue, in effect, but because of
publicity sought, as I say, it was becoming
a test case on Horizon, even though our -- that
is not what we believed the case was about.
If you had such confidence in Horizon and
nothing to hide, why would you need to take such
a hard line against Mr Castleton?
It wasn't necessarily against Mr Castleton.
I really do think it was driven by the size of
the potential counterclaim and that, if he had
accepted any of the offers to mediate, I think
things could have been resolved on a round table
basis.
Where there does it refer to the counterclaim
being your motivation, driving force, in your
case strategy?
This is a document created by Mr Stephen Dilley
and the disclosure to this Inquiry has been very
partial. I don't know whether, in February
2006, I was in the position of expressing
strategy. There was no litigation strategy
within the Civil Litigation Department on how to
deal with these cases. There was no strategy
coming down from on high, from Post Office
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challenges to Horizon.
We have there in speech marks, so similar to the
speech marks we saw earlier in respect of
"keeping your mouth shut” it says, "the whole
system will come crashing down". It says:
"Mandy knows that Mr Castleton is talking to
Barjarge (the other subpostmaster bringing
a Horizon based claim). The Post Office's clear
line to the industry must be that we are taking
a firm line with Castleton. She even said she
thought it might be damaging to settle the claim
on confidential terms rather than fight it and
lose."
So there seems to be a strengthening of the
line towards Mr Castleton. We've gone from 2005
potential settlement to now making an example of
Mr Castleton.
Yes, that is correct. It went from being
a case, to the best of my recollection, that
started off small subpostmaster deficiency,
massive potential counterclaim, based on, so we
believed, unsupported allegations about the
Horizon System.
By February 2006, however, it had sort of
morphed into a test case on Horizon, despite
50
Limited, on how to deal with these cases.
Doesn't paragraph 2 there precisely set out the
strategy that you wanted to adopt in
Mr Castleton's case?
In this instance, this particular piece of
litigation.
Where were you getting those instructions from?
It says here I was getting them from Post Office
Limited.
Who was telling you that you needed to send
a message to the industry? Was this your own
view? Did it come from somewhere else?
I think it was coming from Post Office Limited.
But it was a very long time ago.
Post Office Limited is a company name, it must
have come from an individual. Who was it coming
from -- or individuals?
I can't recall after this period of time, as
I hadn't had the advantage of having access to
full sequential documentation.
There is a conversation between yourself and
Stephen Dilley in February 2006, where he is
quoting what he considers to be your view that
the Post Office must not show any weakness. Is
the strategy coming from you? I mean, it's
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quite a significant strategy that has
implications for somebody's life. Can you try
and assist with where the strategy is coming
from?
I believe it was coming from Post Office
Limited, as expressed through me, and it was not
personal, it was just dealing with an individual
litigation case.
You have no recollection whatsoever where that
direction was coming from?
No.
Can we look at POL00070811, please. We are now
in May 2006, an email from Stephen Dilley to
you:
"Dear Mandy,
"I refer to our telephone conversation this
afternoon and attach our draft cost schedule,
for your information. As discussed, this is
partly a tactical document: Mr Castleton wants
to postpone mediation. The estimate should
bring home the costs implications of doing
that."
If we continue to scroll down -- sorry, if
we can scroll up to the top, you're the only
name from the Post Office that's in the
53
youl, even if [the Post Office] wins, you may
well find it difficult to enforce any judgment
because of Castleton's asset position which is
at best unclear. However, from the [Post
Office's] view there are importance broader
implications at stake such as the message it
will send out to other subpostmasters if the
[Post Office] settle or are seen to pursue it
vigorously."
So, once again -- the earlier message was
from February, we're now in May -- a message to
other subpostmasters being sent out in this
litigation. Is that your recollection of the
tactical approach that was being taken to that
litigation at that time?
At this stage, it had morphed, I think, from
becoming a technical test case to an actual test
case and, therefore, that is the position and
the message that POL wished to put out.
Had you and the Post Office lost sight, by that
point, of the fact that Mr Castleton,
an individual, was involved in this case?
I don't believe so because I seem to recall
that, at the beginning of the litigation, he did
have insurance cover. I do not know whether
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addressees there.
Yes.
Yes. So he seems to be discussing tactical
approaches to the litigation with you; is that
a fair summary of what this email is aimed at?
In this document, though I may well have sought
instruction on it from my line manager and/or
POL.
If we scroll down to number 4 and 5, please,
thank you, he says there:
"I've estimated the total global costs at
nearly £223,000 including VAT and disbursements.
As discussed, the costs will be disproportionate
to the amount of the claim [which is circa
£27,000] but not as it currently stands the
counterclaim which is unspecified but put at not
more than £250,000. However, I would value the
counterclaim as much lower. There is a risk
therefore that if the [Post Office] win,
a significant proportion of costs may be
disallowed on assessment because of
proportionality."
So disproportionate costs may be being spent
on this litigation. He says:
"As previously discussed [presumably with
that had expired by this time.
But you are clearly spending what might be
disproportionate costs on a case in order to
pursue it for a wider goal. Is that a fair
summary of the tactical approach that was being
taken?
This is still potentially a counterclaim for
£250,000 where Horizon had now been put in to
question, therefore POL thought it was the
appropriate tactic to take.
Paragraph 5 suggests that, actually, the
counterclaim isn't the real important matter
that was at stake but it was sending a message
‘out to subpostmasters?
The counterclaim had not been amended at that
stage.
Can we look at POL00090437, please. This is
a pile of different documents. So it's not
in -- I know the first page says, "Advice" but
if we look at page 65, there's an email chain
that appears there.
At the bottom of page 65, please. We're now
‘on 21 August 2006 and this is an email from Tom
Beezer of Bond Pearce to yourself, copied to
Stephen Dilley. Again, you're the only Post
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Office name at this stage that's being copied in
to these emails. Are we to read into that that
you had a significant handle on this case by
that time?
I was the person within Civil Litigation that
was dealing with the matter vis a vis Bond
Pearce but I was seeking instructions upwards
from senior officers within Post Office Limited
and keeping my line manager copied into relevant
communications.
Are you still unable to name any of those senior
managers?
Well, I've already given you the raft of
managers within Civil Litigation.
But in terms of who was providing you with the
significant instructions to pass to Tom Beezer
and Stephen Dilley, who was that?
I would have to go through what little
disclosure there is to see who I was getting
instructions from, if that correspondence hasn't
already been disclosed.
If we scroll down over to the next page, please,
this is the contents of Tom Beezer's email. It
says:
“As we discussed last week I am writing to
57
Mail/Post Office know of no issues with the
Fujitsu system and are confident that it
operates correctly. Please discuss this with me
if you have a different view."
Did you at this point say, "Well, I had this
case, the Cleveleys case, a joint expert was
instructed independently and he questioned its
integrity"?
No, I did not.
Why at this stage did the Cleveleys case seem to
simply be forgotten about?
Because I was of the opinion that the
preliminary view by Mr Coyne was created in
a unique set of circumstances, given that the
original data was no longer available. I didn't
consider it to be a full report because the
offer from Fujitsu for him to come and visit
their sites and look all over the data was never
communicated to him. So I didn't consider that
it was a full and comprehensive report.
Did you consider that only a full and
comprehensive report would have been sufficient
to require passing on to your lawyers, who were
dealing with a complaint about the Horizon
System?
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update you on certain points that came out of my
discussions on the Castleton case with Richard
Morgan of Maitland Chambers."
He gives an "Overview" and he says:
"A further point made by Richard Morgan was
that we should endeavour to move the main area
of focus in the case away from the Horizon
System if possible."
He then addresses, further down the page,
Fujitsu. He says:
"In this matter, Fujitsu are clearly going
to play a role. I understand that Fujitsu are
currently looking at the matters raised in
a letter of 25 July 2006 from Castleton's
lawyers ... One of the pivotal issues in this
matter will be the arithmetic used throughout
and I would like to go the answer from Fujitsu
as soon as possible to the points raised by
Castleton's lawyers. Is there any pressure you
can bring to bear upon Fujitsu to cause them to
answer this letter in the near future? I would
be most grateful if you would consider this.
"One other point raised by Richard was the
integrity of the Fujitsu product generally.
Just to confirm, I understand that Royal
58
In all events, that full and comprehensive
report never came into creation.
And anything less than a full and comprehensive
report you didn't think was sufficient to pass
‘on to your legal advisers?
That's correct.
They had asked you directly here whether --
well, he says there:
"... Lunderstand that Royal Mail/Post
Office know of no issues with the [Horizon
System."
Did you not think at that point "Well, maybe
I should be raising some issues with the Horizon
System that I've learnt about in my experience
of other cases"?
There isn't any communication in the document
that has been -- documents that have been
disclosed in which any conversation between
myself and Stephen on that point is itemised.
I do not believe, to the best of my
recollection, that I did mention the case of
Wolstenholme to him.
Can we now POL00069592, please. This is
a document I took Mr Dilley to. I know you saw
Mr Dilley's evidence and you've had sight of
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this document today.
Yes.
It's dated 5 September 2006. It's from BDO Stoy
Hayward, who were instructed in the Castleton
case on behalf of the Post Office. Could we go
to the final page there, please. Sorry, if we
could scroll up to the previous page, thank you,
it's that paragraph there, "Early indications of
problems with the Horizon System".
So it's on 5 September that they contact
Mr Dilley and say:
“We have found that there is some indication
of possible problems with Horizon from our
initial review of the electronic information you
sent us."
Was that communicated to you at the time?
I have no recollection of this document at all,
until a hard copy of it was handed to me this
morning.
In terms of the BDO report, I'll take you to
that shortly -- you ultimately saw the BDO.
report, didn't you?
In the additional disclosure, yes.
So you hadn't seen it before this Inquiry?
I cannot recall seeing it.
61
dealing with subpostmaster cases, was there
a particular group that was interested in
Horizon cases or something else?
I cannot recall after this period of time why
this selection. I can only conclude that they
are people who had shown an interest and it was.
for that reason -- shown an interest or possibly
participated because I recall that Keith Baines
had given witness evidence, and so I felt that
they were an appropriate selection of parties to
contact to communicate this information.
You haven't so far named any individuals who.
were providing you with instructions to pass on
to the Post Office's solicitors. Does this
assist in any way with identifying who it may
have been who was providing you with the
instructions or information or direction in the
Castleton case?
There would have been a whole selection of
people who, in turn, would have raised it
further on up their reporting structures. So it
was, to a certain extent, a movable feast.
No individuals stand out in particular there?
Not particularly.
Could we go over the page, please. You're
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a
I'll get to the report shortly. But you are
seen here on a number of different emails
between the solicitors acting for the Post
Office and you. Is it likely that, on receiving
a letter of this significance from BDO, that
they would have passed on or summarised that
information for you?
I can't answer that.
Can we look at POL00113909, please. If we
scroll to the bottom, we're now in November,
9 November 2006. There's an email from you.
Can you assist us with that distribution list
and why you would have been sending information
about the Castleton case to that distribution
list?
Okay. Biddy Wyles by this time was my immediate
line manager; Clare Wardle, head of Civil
Litigation; Rod Ismay has already given evidence
to this Inquiry. I used to communicate with
these people regularly but, after so many years,
I'm afraid I can't assist.
Are you able to assist, not with what their
specific roles or duties were but simply why it
is that you would have chosen that group of
individuals? Was there a particular group
62
passing on some good news -- and, over the page
again, thank you -- about the Castleton case.
It's about the potential of settlement in that
case. We're in November 2006. This settlement
doesn't ultimately happen but can we go over to
page 5, please. Thank you. It's the second
paragraph there. You say there, about halfway
down:
"The benefit of having a judgment against
him [against Mr Castleton] in the full amount is
that we will be able to use this to demonstrate
to the network that despite his allegations
about HORIZON we were able to recover the full
amount from him. It will be of tremendous use
in convincing other postmasters to think twice
about their allegations."
So again, that seems to be a significant
driving factor in respect of the Post Office's
approach to this report.
By this time, it had become, in fact, a test
case. Therefore, if a judgment were obtained,
it would have been of benefit to Post Office
Limited.
We saw a moment ago that in September 2006, BDO,
the accountants, had written their initial
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concerns and sent a letter to Mr Dilley. You're
not sure whether you received that or not but,
at this time, when you were talking about using
his case as a message to other subpostmasters,
do you think it likely that, in fact, you knew
that there may, in fact, be problems with the
Horizon System, as highlighted by BDO Stoy
Hayward?
Excuse me, can you just scroll back as to the
date of this? Oh, this is November, isn't it?
Yes, this is 9 November 2006. The BDO letter
was 5 September 2006. If it assists -- and I'm
going to take you to it shortly -- the actual
report from BDO, the draft report, was received
‘on 29 November. So the final report was shortly
after this email correspondence but there had
been correspondence from BDO to Mr Dilley.
Excuse me, can you repeat the question again you
want me to answer?
At this time, the strategy seems to be
convincing other postmasters to think twice
about their allegations. Might you, by this
stage, have known that, in fact, your own
experts had raised an issue with the Horizon
System, very similar to the Cleveleys case?
65
System did not contribute to the errors in any
way and formally withdraw all statements I made
to the contrary."
So there is a form of words there that
clearly suggests that the Horizon System didn't
contribute to the errors. It says that the debt
arose out of human error. What evidence was
there that the debt arose out of human error?
The evidence of the witnesses from Fujitsu and
Post Office Limited who had recreated the
accountancy side of this debt action.
Why do you say "human error", though? Why is it
not something else? How can you be sure, have
sufficient certainty, that the debt arose out of
human error? First of all, how can you be sure
that there was a debt at all? If there was
a wrong button pressed, for example, how could
you be sure that there was an actual loss to the
Post Office?
Because Post Office Limited staff had gone
through the accounts and the materials at the
branch and recreated various cash accounts and
other documentation to demonstrate that there
was a valid debt.
There may have been figures showing that there
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An issue but we had a whole selection of witness
statements from Fujitsu employees who were
confident that their evidence was going to be
persuasive.
Can we, please, look at POL00069775, please,
10 November. So this is the day after that
email.
Mm-hm.
Can we please look at page 3. So if we scroll
slightly up the bottom of page 2 we have
an email from you, 10 November, to that
distribution list, so we have names such as Rod
Ismay on there. If we scroll down, you are
proposing that Mr Castleton signs a form of
words and the proposal there is as follows, for
him to say:
"I Mr L Castleton the former postmaster at
Marine Drive Post Office admit that a sum of
money was owed by me to Post Office Limited as
a result of errors which arose whilst I was the
postmaster at the above office. I had [must be
‘thought’ that this debt arose due to
a malfunction of the HORIZON System but I now
accept that I was mistaken and the debt arose
out of human error. I declare that the HORIZON
66
was a debt but, in terms of an actual loss to
the Post Office, how could be sure of that?
If they were of the opinion that there was
a valid debt and there was sufficient
documentary evidence in support, I was prepared
to accept that position.
You mentioned earlier that the case was about
the size of the counterclaim and that's why you
wanted to settle the case. If it was about the
counterclaim, why would you be seeking to get
Mr Castleton to sign up to this statement?
Because, as I've said earlier, by this time, it
had become, due to publicity, a test case in its
‘own right.
Was it very much like the Cleveleys case: that
you wanted to silence him?
No.
Why get him to sign up to a statement such as
that if you didn't want to silence?
Because it would have -- I didn't seek silence.
It would have been of use to Post Office Limited
in dealing with other suggestions that there
might be issues with the Horizon System.
Isn't that entirely consistent with, for
example, counsel's advice in the Cleveleys case
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that I took you to earlier about the Post Office
seeking to avoid publicity?
A. I don't accept that.
SIR WYN WILLIAMS: Whose idea was it to ask
Mr Castleton to use those form of words? Was it
yours or was it someone else and, if so, who was
it?
A. I genuinely can't remember after this period of
time. Supporting the Horizon System was very
important to Post Office Limited at the time.
SIR WYN WILLIAMS: But --
A. On the balance of probabilities, I think it was
something that emanated from Post Office Limited
but that's purely my opinion.
SIR WYN WILLIAMS: Like Mr Blake, the expression
"Post Office Limited" doesn't give me very much
information because, ultimately, there must have
been a person or persons within Post Office
Limited. So is your evidence to me that
probably this form of words was suggested to you
and you acted, in effect, as the go-between in
passing it on but you can't remember who it was
that suggested the form of words to you?
A. I'm very sorry but I can't assist you any
further on this.
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Q. If we go to the first page, we then have
Mr Dilley commenting on it and he seems to want
to strengthen it further. I think the additions
he has, for example, are "unreservedly withdraw
the untrue allegations" and also, the words at
the bottom:
".., allegations about the Horizon System
and/or its functioning.”
Do you remember having any views as to that
form of words?
A. No, it was just an alternative draft.
Q. Knowing what you already knew from, for example,
the Cleveleys case, did you think that then
might have been an appropriate time to raise any
concerns you had about the functioning of the
Horizon System?
A. As I've said previously, I draw distinction
under the Cleveleys case and I did not think
that that was the time to draw distinction.
Q. Ultimately, the approach there and the approach
in the Cleveleys case was similar, in that you
were getting somebody to effectively "shut up",
to use the words from -- or "keep their mouth
shut", I think was the expression in the
Cleveleys case. Was this again an attempt to
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‘SIR WYN WILLIAMS: All right.
MR BLAKE: Mrs Talbot, it may assist, if we look at
the email again, if we go to the top of the
email with the distribution list -- sorry, it's
the bottom of page 2. We have there the
distribution list. So it's an email from you to
various people within the Post Office.
A. Mm-hm.
Q. Were those people, on the whole, more senior to
you, less senior?
A. Biddy Wyles and Clare Wardle, certainly within
Legal Services. I think that Mr Ismay, Richard
Barker were more senior to me. I don't know the
status about the others.
Q. If we scroll down, we can see, you say above the
highlighted passage:
"I have prepared a short statement but would
be very grateful for any improvements which you
can suggest."
So it certainly seems as though that form of
words was your drafting.
A. It may well -- it -- it's a possibility.
Q. Would you have said, "I have prepared a short
statement", if somebody else had drafted it?
A. Probably not.
70
get Mr Castleton to keep his mouth shut?
A. No. It was a way of drawing litigation to
a conclusion on the best possible terms for Post
Office Limited.
Q. Would Mr Castleton have been free to continue
saying that the Horizon System was not
functioning properly?
A. Ifhe had been prepared to sign the Tomlin
Order, that is maybe something we would have
taken into consideration later. As it was, he
instructed his solicitors that he wasn't
prepared to sign the Tomlin Order.
Q. Had he signed up to that, would he have been
free to say that the problem was the Horizon
system?
A. I can'ttell. That's not a situation that
occurred.
Q. You've said that it wasn't intended to shut him
up but, in reality, if he had signed what you
were asking him to sign, would he have been
free, in reality, to continue to make.
allegations --
A. It's a hypothetical. It didn't occur.
I agree but can you answer the question?
A. It didn't occur.
2
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I'm trying to get to your thinking behind this
form of words. You've said that it wasn't to
shut Mr Castleton up. Surely, if he had signed
it, he could not have criticised the Horizon
System, so the effect was intended to shut him
up, was it not? I'm asking about your thinking
behind the effect of asking him to sign up to
such a stringent form of words.
If he had signed it, which he didn't, the
litigation would have concluded. He would not
have been able to comment further upon the
Horizon System and Post Office Limited would
have been free to comment upon the Castleton
situation as it chose.
Do you not see parallels between the strategy
that was adopted in the Cleveleys case and the
strategy that is being adopted here, that you
are effectively ensuring that somebody does not
publicly criticise the Horizon System?
There was no diktat from on high dictating
strategy within these two separate litigation
cases.
So you were an individual who was involved in
both cases; the strategy seems to be the same.
Was that therefore coming from you?
73
problems that apparent from the accounting
records are three very small differences in the
cash account
So having identified there that there are
possible computer problems, were you aware of
that?
I would have seen a copy of this report at the
time it was created.
Is that in some way consistent with the expert
report in the Cleveleys case of possible
computer problems?
Based on two wholly different sets of facts, BDO
Stoy Hayward were ostensibly a firm of
accountants, not IT experts.
Two cases in two years, two expert reports, both
identifying possible computer problems. Did
that not cause you to pause for thought?
At the time, no.
Why wasn't this report ultimately disclosed to
Mr Castleton?
I've seen an email exchange between Stephen
Dilley and myself and I've wracked my brains and
I cannot recall why it wasn't disclosed.
Did you discuss that report with anybody at the
Post Office?
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I dealt with both cases separately and
individually and came to the same advice in
both.
Was it entirely a coincidence that the strategy
adopted in both was to try to prevent public
criticism of the Horizon System?
Post Office Limited was concerned to preserve
the integrity of the Horizon System. There is
no doubt about that.
As the Chair has said, "Post Office Limited" is
not a very helpful description of who it was
that was concerned. You were involved in both
of these cases. Was this your strategy?
Itis, I believe, the strategy of Post Office
Limited -- though I cannot speak to Post Office
Limited -- communicated through myself as the
solicitor dealing with these two litigation
cases.
Can we please look at POL00069955, please. This
is the draft report from BDO Stoy Hayward and
it's page 4. You'll have seen this is
a document that I took Mr Dilley to. We have
the summary there and the very first of BDO's
conclusions is:
“The only indications of possible computer
74
I genuinely cannot recall, after this period of
time.
Did that report not make you question whether
the infallibility of the Horizon System was now
in question, in doubt?
The sums in the report are tiny in the extreme
and we had become aware of potential glitches
but were assured by Fujitsu that they were rare,
unusual, extreme, capable of being identified
and, therefore, excluded when Fujitsu were asked
to look at Horizon data.
Given that there were potential glitches, do you
think it was right to be trying to get Lee
Castleton to sign an undertaking not making
allegations about the Horizon System when your
‘own expert had identified at least one issue
and, as you say, Fujitsu themselves had accepted
that there were potential glitches?
At that time, I was tasked with obtaining
a satisfactory resolution of this litigation
from the perspective of Post Office Limited.
Were you personally satisfied that that was the
correct approach, the ethical approach, for
example?
Itwas the approach I adopted at the time.
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We know you adopted that approach but did you
think it was right at the time?
I don't think I considered it.
Do you now, looking back at it, think it was the
right approach?
Given the information that has become aware in
the public arena since the Bates trial, I do not
any longer consider that that was the right
approach to have adopted but then, given the
information that's become public since Bates,
I think it was wrong the proceedings were ever
issued against Mr Castleton.
Bates, of course, was much later.
Yes.
You're here in 2006. You've got the BDO report.
You've got, as you said, acceptance from Fujitsu
that there were potential glitches. Looking
back at it then, with the information you had
then, do you consider that it was right to try
to get Lee Castleton to try to sign
an undertaking not making allegations about the
Horizon System, in light of the information you
had at that time?
I believe that it was because my job was to
conclude litigation in a satisfactory fashion as
77
back to a document we've already looked at,
which is POL00070811. This was the email,
I think you'll recall, from Stephen Dilley to
you and, at the bottom, where he says that, as
previously discussed, essentially, costs would
be disproportionate but there will be broader
implications.
This is just to refresh your memory of that
particular document. I'd now like to go to
POL00119897. This is a documents from 18 August
2006, from Cheryl Woodward to Stephen Dilley.
She says:
"I've passed the case on to a Senior Manager
who is going to speak to Mandy Talbot regarding
not being happy about the costing of this matter
going to trial."
Do you remember about the costing -- you not
being happy about the costs?
No, I -- I'd never seen this email before
disclosure.
Okay. I'm going to look at a policy. It comes
later, it's POL00084977. This is a policy
that -- the copy that we have, the version that
we have -- post-dates this particular case.
It's December 2009. I'd like to take you to
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far as Post Office Limited were concerned.
Can we look at POL00070160, please. We're now
on 5 December 2006, so quite close to the trial
in the Castleton case we have there an email
from yourself to Stephen Dilley talking about
a case called Brown and you say:
"Apparently Brown is going to be a problem
because it is a case where [the Post Office]
admitted there was a problem with the system and
replaced it. I am hoping this is a one-off
event like a power outage or something of the
like. I will investigate further tomorrow."
Very close to trial, did this cause you to
pause for thought at all?
The consequence of the list of parties,
including Mr Brown, who I believe Mr Castleton
had indicated he was going to call to trial, and
some information about what they were likely to
say, made me go to Post Office Limited and
Fujitsu to try to investigate, to acquire as
much information about these cases as I could
and to relay what information I acquired to
Mr Dilley.
I'm going to move on to a different topic and
that's the topic of costs. Can we please go
78
page 17 of this. Is this a document that you're
familiar with at all?
I have no recollection of this document
whatsoever and, although the coversheet is
December '09, if you look at the date at the
bottom of most of the appendices, it is August
2010.
Yes.
Therefore, I have no knowledge whether this was
actually ever implemented at all.
There's something I'd just like your view on,
it's page 17.
Mm-hm.
If we scroll down, it says there:
"The write-off authority levels are fairly
transparent ... The decision-making process to
write-off debt is usually where the cost of
recovery outweighs the debt (ie very high legal
costs) and/or the debt is unrecoverable
(eg insufficient evidence, legalities,
[et cetera]). It is important to note that
every case is unique, and therefore all cases
are assessed on a case by case basis.”
It seems to suggest that certainly
a consideration in writing off debt is whether
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the case would be very high legal costs and
whether the debt was unrecoverable. Were those
considerations that you were asked to take into
account in relation to Mr Castleton's case,
irrespective of the fact that this policy comes
later, but those considerations, do they feature
in your thinking at all?
No. On the basis that the case and having
a judgment that would be beneficial to POL was
considered to be so important to the business.
The document you've just referred to was, in my
opinion, the very first attempt by Post Office
Limited to, in effect, take an overview as to
the whole subpostmaster estate. I think before
that, there was no single strategy behind
anything.
So there was no policy in place about, for
example, the expenditure of disproportionate
costs in a case?
No.
Was there no policy on when matters needed to be
raised with senior management within the Post
Office?
No, Although I had worked for two City firms
for a very short period of time, I didn't really
81
Can we look at POL00069766, please. Thank you.
If we go to the bottom email, please. We have
an email from Mark Turner, solicitor in the
commercial group of Rowe Cohen solicitors and he
is emailing Stephen Dilley and this is forwarded
‘on to you. He says:
"I have just tried to speak to Mr Castleton
but have been informed by his wife that he is
rather unwell, is in bed on his doctor's
instructions, and is on some pretty strong
medication to treat the stress-related condition
that led to his hospitalisation last week. As
a result of the medication, he is somewhat ‘out
of it' and apparently not in any fit state to
provide me with instructions."
That's 15 November 2006 and, if you scroll
up, you can see that Stephen Dilley forwarded
that to you by way of an update.
There's another email POL00069722, two days
later, 17 November. This is when settlement was.
being discussed with Mr Castleton's solicitors.
If we look at the email at the bottom, it says:
"Dear Mandy,
“Please see below from Castleton's
solicitors. I have spoken to him and chased him
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have any experience of management. When I first
came into Post Office Legal Services, I wasn't
aware of the lack of structure that would be
apparent in most firms and most organisations,
in terms of reporting matters upwards, or
obtaining instructions coming downwards. It
just wasn't there.
So what was your view of the Post Office as
an organisation, in the way it was run in
respect of the bringing of actions, management
of actions against subpostmasters?
This is my own personal opinion. I could never
understand why, in some cases, actions were
taken because, as I've said, the way the system
was set up enabled departments to go out
straight to external lawyers without referring
to in-house legal assessment at all. And why,
‘on other occasions, the appropriate thing
considered was to get the Security teams.
involved and, thereafter, refer it to the
Prosecution or Criminal Litigation department.
I want to move on to a different topic, which is
Mr Castleton's health and costs and issues of
bankruptcy?
Mm-hm.
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to sign the content order. He is going to call
Mr Castleton's GP today to check that Castleton
has the mental capacity to give him instructions.
Then if you look at the top email from you
to Stephen Dilley, you say:
"Noted. It's frustrating given that
hopefully the settlement will be concluded
shortly."
Were you aware of any policies within the
Post Office addressing what to do if a party was
hospitalised through stress?
I wasn't aware of any policy within Post Office
Limited itself relating to the physical or
mental health of a party.
If we look at POL00070210, please. There is
an agreement between the Post Office and Bond
Pearce, and this is called a "Subpostmaster and
Commercial Litigation Protocol"; do you remember
this document?
I didn't until the additional disclosure.
I don't know if this was created before the
Castleton case or as a consequence of the
Castleton case. I just can't remember the date
of it.
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Ithas you down as the Legal Services
representative?
For subpostmaster cases.
Yes. So does that suggest that you were
responsible within the Post Office for
subpostmaster cases?
Within my small area of Civil Litigation, I was
the liaison between Bond Pearce over these
matters. Whether I was the liaison with all of
the other regional firms on subpostmaster cases,
I can't recall.
Could we go down to the second page, the bottom
of the second page. There's reference there to
"Significant/Sensitive Cases", and it says that:
"Bond Pearce shall notify the client and
[you] of all significant and sensitive cases
Then it gives some examples.
Now "stress/bullying/harassment", am I right
to understand that that is not in the context of
the litigation? That means the topic of the
litigation, whether it's --
I'm trying to recall whether Bond Pearce dealt
with employment cases, where a provision like
that would have been far more relevant.
85
that was?
I assume someone within the Error Resolution
Team because I think that, as a subpostmaster
deficiency, theirs would have been the
department tasked with recovering the
deficiency.
Thank you. We're now in 2007, so it's after the
original court case in the Castleton case, and
you say there:
“He has declared himself bankrupt which was
expected and we are still awaiting details of
the valuation. After a year if he has not sold
the property the rights of his kids to have
a house over their heads becomes an irrelevance
and as the largest creditor we can put the
property up for sale through a trustee in
bankruptcy."
You say there it was expected that he would
declare himself bankrupt. Was that something
that you were aware of during the proceedings?
During the proceedings?
Yes.
No. I think in the period after the trial, it
was suggested.
Given the value of the claim and given the
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If we scroll down the list of significant and
sensitive cases, do you consider the Lee
Castleton case to have been a significant or
sensitive case, falling within any of those
criteria?
As it developed, yes.
Which one would that be?
Although it refers to case values in excess of
500,000, I actually am of the opinion that any
case involving £250,000 is also something that
should have been reported on.
We know that you were, of course, aware of this
particular case.
Mm-hm.
I mean, if we scroll up, all this agreement
means is that you would be notified. Was there
an equivalent policy within the Post Office to
notify those within management, for example, of
those kinds of cases?
No, there wasn't, that I am aware of.
I want to address now his bankruptcy. Can we
look at POL00113487, please. It's page 7 of
this pack of documents. Page 7., thank you.
It's that middle email from yourself to Martyn
Mitchell of the Post Office. Do you recall who
86
strategy that the Post Office adopted, which was
to essentially, as you've accepted, make
an example of Mr Castleton for wider purposes to
dissuade other subpostmasters from bringing
actions, did you think it was proportionate for
the Post Office to seek to recover its costs
through the sale of Mr Castleton's home?
There had been opportunities at the time of the
proposed Tomlin Order to have settled the matter
without the then additional costs of the trial.
As we had been -- as Post Office Limited had
been put to the cost of the trial, it was just
normal litigation tactic to try to recover
whatever costs we could using legal methods.
There's an email from Stephen Dilley that I can
take you to. It's POL00072206. This is even
later. This is now 2009. You may recall from
Mr Dilley's evidence, it's the bottom email,
where he says:
"It is frustrating that there is no
financial recovery in this instance although we
knew that the prospects were slim particularly
after he was made bankrupt. Post Office
Limited's main goal in pursuing Mr Castleton was
achieved in that we have a good judgment
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precedent which helps us to defend the Horizon
System."
Do you think it was fair to bankrupt
Mr Castleton in pursuit of that wider goal?
Mr Castleton chose to bankrupt himself but it
was a legitimate -- it was legitimate on the
part of Post Office Limited as the major
creditor to seek to recover what costs it could.
You've been very frank about this in your
witness statement and I'd like to turn that up,
please. So could we have a look at
WITNO08500100. That's Mrs Talbot's witness
statement. It's page 19 I'd like to look at.
It really draws the themes that I've been
exploring just now of cost and bankruptcy
together. It's page 19 of the witness
statement. Thank you.
At the end, at the bottom of that page,
please. You say there at the bottom, it begins
at the very last line:
"The tactic of [the Post Office] was to draw
the costs position to the attention of
Mr Castleton ... then to overwhelm Castleton
with evidence and preserve the trial date of
early December. I refer to the telephone
89
until the defendant or those acting for him had
made the appropriate formal application to the
court. I don't know what consideration POL took
before deciding to send the matter out to
external solicitors to issue proceedings.
I just don't know whether they took somebody's
physical or mental health into consideration.
So if we look at paragraph 44 below, you say:
"In general the physical or mental wellbeing
of a subpostmaster may well have been considered
a relevant factor prior to the decision to refer
a matter out to agents but that was a matter for
[the Post Office]. I would not have been aware
of any decisions taken in this respect and do
not know if this was considered in this case.
Civil Litigation were never asked to the best of
my knowledge ..."
Yes.
So to try to understand the process, you would
receive a case from somewhere within the Post
Office. Where, in particular, would you receive
a case relating to a subpostmaster?
It could have come from the teams dealing with
subpostmaster deficiency debt. In the case of
Mr Castleton, it was already sent out by
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attendance note [et cetera]. These would have
been standard tactics in high ... litigation
cases.”
Pausing there, do you see the Post Office as.
in any way different to a normal litigating
partner?
I don't think that I do see it as different to
any other client.
Can we go on to the next paragraph, in fact
paragraph 44, page 21 -- sorry, it's 43, in
fact. Thank you.
You say at the top of that page, page 21, so
cover to the next page, please. You say:
"A Defendant's wellbeing was not considered
by [the Post Office] as relevant to the manner.
in which litigation was conducted unless or
until the Defendant or those acting on his
behalf made a relevant application to the Court
assuming that litigation had already commenced."
Can you assist us with what you mean there?
Did at no stage the Post Office consider the
wellbeing of a party, unless that party had made
an application to the court?
I can't speak as to Post Office Limited but,
within Civil Litigation, we wouldn't, unless and
90
Ms Woodward to Bond Pearce without us in-house
solicitors having any knowledge of it.
So would the in-house solicitors not have a say
as to whether the physical or mental wellbeing
of a subpostmaster was a relevant factor in
continuing a case?
Continuing with the case?
Yes.
As I referred into my statement several
paragraphs before, it would only have become
an issue if a formal application had been made
to the court. I never knew of a case where we
were asked by Post Office Limited to keep them
apprised of what may be happening with
a physical or mental condition of a defendant.
Do you think you did or didn't keep people
appraised of Mr Castleton's wellbeing in the
broader --
I was never asked to do so specifically and it
would not have been normal in general high value
litigation.
Can we look at POL00072991, please. It's the
second page. We have an email there from Joseph
Napier, who was a partner in Napier & Sons.
We're now in December 2010, so further on,
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a year on.
A. Mm-hm.
Q. He says there, in the second paragraph:
"I have had discussions with [this is
somebody called Katherine McAlerney, with her
solicitor]. They're still making some noises
[regarding] the Horizon System but I am not
getting the impression that they expect their
arguments to bring them very far.
"McAlerney is in financial difficulty. She
is trying to sell land", et cetera.
Then your response above is:
"Joe
"Thank you for the update in this matter.
We recently won a prosecution of
a subpostmistress by the name of Misra and as
a result we anticipate that the complaints about
the Horizon System may decline. I presume that
her complaints about Horizon are generic rather
than specific.”
This is a later case, dealing again with
complaints about Horizon, and there is mentioned
in that email from the solicitor about financial
difficulties. Am I right to read into that that
Mr Castleton's case was not unusual in the
93,
SIR WYN WILLIAMS: By all means. You take it as you
think appropriate, Mr Blake.
MR BLAKE: Thank you.
Involvement in criminal cases. You address
this in your witness statement. It's
paragraph 54 of your statement, where you say:
"Civil Litigation solicitors would have no
interest or involvement in a criminal case until
it had been concluded."
Can you assist us with how those teams were
separated? Were they physical separations?
A. When I first joined Legal Services, we were in
a tower block in Croydon and the Legal Services
Departments were spread out on two separate
corridors, two separate floors. The Criminal
Department was down another corridor, in effect
physically separated from the general Civil
Litigation Team and, by about 2006 -- and I'm
basing this on disclosure that was made on
Tuesday -- the Prosecution criminal team was
based in Victoria in Central London.
So we were geographically in separate places
for the middle to latter portion of 2000 to
2010, and physically separated in terms of being
two separate ends of a divided corridor, when we
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respect of the ultimate result causing
significant financial difficulties to
a subpostmaster?
I have no idea. We were never tasked with
keeping any sort of financial record or any
other sort of record about subpostmaster
deficiency cases, until such time as the Andy
Greening document, end-to-end postmaster debt,
in the August 2010 and, even then, I don't know
whether that was ever properly implemented.
So, throughout your years in the legal
department at the Post Office, did you not
yourself see trends rising in relation --
I was never asked to look for trends.
You weren't asked to look for trends but did you
not sense any trends yourself?
As I said earlier, ordinarily, when I wasn't
dealing with cases like Mr Castleton, that were
truly extraordinary, I would spent one maybe two
hours a week on these matters, subpostmaster
deficiency. It was a very, very small part of
my caseload.
I'm going to move on to a different topic.
Sir, I think I'll continue. We have
20 minutes before 1.00. I think I'll press on.
94
were all working together in Impact House.
There is a sort of landing with two sets of
double doors and Criminal and Prosecution were
down one end and Civil down the other end.
Did you share any joint meetings?
I think it extremely unlikely, until possibly
the 2000s, because --
Do you mean 2000s or do you mean post-2010?
No, sorry, 2010. Because from 2000 to the end
of 2009, and possibly way in to 2010, our only
real connection with Prosecution was cases where
they had not been able to achieve recovery of
‘outstanding debt. Therefore, they would
prosecute an individual and if they forgot to
apply for a compensation order or the court
wasn't minded to grant it then, and only then,
would a case from Prosecution be referred to
ourselves.
How about management? Did you share the same
management structure?
As I say, I worked to either my team leader or
to the Head of Civil Litigation. Criminal and
Prosecution worked to Mr Rob Wilson. So we
didn't share a management structure in that
respect.
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Did their managers share a manager, if you're
able to assist us with that?
I believe that Rob Wilson -- if I can go back to
the early days, I believe that Rob Wilson and
Joe Ashton, who were respectively Head of
Criminal and Head of Civil Litigation, reported
directly to Catherine Churchard, who was the
solicitor to the Post Office at that time. And
I believe that that's a structure that was
maintained subsequently.
Thank you. Can we look at POL00083161_002,
please. It's page 2 of that document. Again,
I'm going to take this broadly chronologically,
looking at involvement in criminal cases. If we
could look at the bottom email. There is
an email forwarded by you, but it's originally
from Graham Ward, who was Graham Ward? I think
if we scroll down, we can actually --
There's possibly his title on the next page.
There is. It says "Casework Manager, Post
Office Limited Investigation Team"?
Yeah.
So he was part of the Investigations team, was
he?
Yes, and they worked primarily on criminal
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as evidence in criminal proceedings?
Very, very rarely. At this time, we were
trying, and Stephen Dilley was trying, to obtain
witness statements and I think Graham thought it
might be of assistance if Stephen got in touch
with Jan Holmes because he had prepared
a witness statement in another case. Looking at
it, it appears possibly the witness statement
from Jan Holmes was attached to this email --
oh, yes, it was: “Revised witness statement, Jan
Holmes". Yes, so I would have seen a copy of
that witness statement at the time.
Was this particular to you in your role that you
are being involved or sent matters relating to
criminal prosecutions? You've said that your
team had little involvement?
No, this was as a consequence of Stephen trying
to identify people within POL and Fujitsu who
were capable of giving witness statements on
this type of case.
So is this relatively isolated, then?
Oh, yes, absolutely.
Can we look at POL00067487, December 2006. So
before we were December 2005, so a year later.
We have a letter and it's relating to Josephine
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cases.
Thank you. If we go up to the bottom of the
page before, so the bottom of page 2, a little
bit further, so the bottom of that page. Thank
you. He says:
"Mandy (Keith -- for info) ..."
That's Keith Baines?
Mm-hm.
"As discussed yesterday ... please find attached
the statement from Jan Holmes which was used in
a prosecution of a counter clerk at Camberwell
Branch Office in 2002."
Pausing there, we know that was Tracy
Felstead, who was 19 years old at the time and
her conviction has subsequently been overturned.
Mm-hm.
It says:
"I would suspect that Jan Holmes’ statement
is more or less exactly what you'll need should
the ‘Castleton’ case proceed all the way
(however I seem to recall that at the time, as
it was out of the normal this statement did cost
us an ‘arm and a leg’ ... but I maybe wrong)."
Did you on occasion, therefore, have sight
of statements and other documents that were used
98
Hamilton, sent to Cheryl Woodward in the Agents
Debt Team and it says, as follows -- if we could
go halfway down the page to that middle
paragraph it says:
"Ms Hamilton is likely to allege that she
was inadequately trained on the Horizon System.
It is possible that she may also contend that
there were errors with the Horizon software
although her Solicitors have not specifically
said so. Her letter does however hint at it.
In light of that I am copying this letter to
Mandy Talbot."
Now, these were the criminal proceedings
against Josephine Hamilton, again another case
that we know has subsequently been quashed. It
was written, in fact, the day before she first
appeared in a Magistrates Court and it refers
there to her potentially challenging Horizon,
and copied to you in light of that. Why would
matters challenging Horizon be copied to you?
I'm not 100 per cent certain, though as this is
Cheryl Woodward and she was the lady who gave
instructions to begin proceedings in Castleton,
she may have thought it appropriate to tell Hugh
James to keep me copied in for that reason.
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This was something that was referred to me
for information, as far as I was concerned. No
more.
I mean, sorry, if we could zoom out slightly.
This is a letter from Hugh James. The fact that
they knew that you would be interested in cases
relating to errors within the Horizon software,
shall we not read anything into that?
Hugh James had informed me of the possibility of
an embryonic class action. As such, I may have
been copied in on that basis.
Were you starting, at this point, to coordinate
cases?
No, no.
This is precisely the time when, of course, the
Castleton case was going on. Did you tell Hugh
James that you had a similar case,
Mr Castleton's case: a similar case where
Horizon software was being challenged?
I believe that I asked Bond Pearce to liaise
with Hugh James and any -- by implication, any
other external agents on subpostmaster cases,
because I wanted to ensure that proceedings were
not issued again where the documentary evidence
wasn't in apple-pie order and that we wouldn't
101
case on its particular facts and as a singular
item.
Can we please look at POL00053778, please.
Thank you. Can we turn to page 5, the bottom of
page 5. An email from you to, is it Michele?
Michele.
Michele Graves. Who was Michele Graves?
Somebody within Post Office Limited but,
unfortunately, I cannot remember which
department after this period of time.
The subject there is an Eleanor Dixon. We're in
January 2010, and you say this. You say:
"As you know, the business is prosecuting
a former subpostmistress who is adducing all
sorts of statements and comments from former
postmasters in support of the contention that
Horizon is the cause of all evil and that they
were perfect postmasters."
Mm.
Is that a little sarcastic?
I do very much regret the language I used in
this and, as I've said in my statement, with
perfect hindsight, they were right to so adduce.
You say:
"I attach a statement from Dixon along those
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be able to prove on the arithmetic that losses
had been sustained at individual branches.
Undoubtedly a serious matter, Ms Josephine
Hamilton being prosecuted, shortly before her
appearance in court. You're being told about
it.
Mm-hm.
Did you think at that stage to raise, for
example, that you had, by then, received two
expert reports where allegations were being made
about the Horizon System or concerns were being
raised about the Horizon System?
No, I did not.
Did you tell them, for example, that you had
that Cleveleys case, where the independent
expert had raised concerns about the Horizon
System?
I believe I merely read the letter and probably
filed it.
Did you think, with criminal cases being brought
to your attention, that you had any duties of
disclosure in respect of those cases of your --
in respect of your knowledge of any problems
with the Horizon System?
No, at the time, I dealt with each and every
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lines. Please can you locate any material which
[the Post Office] may still have on this lady so
we can assist the barrister who is prosecuting
the case on our behalf."
So having said that getting involved in
criminal cases was quite rare, we again have
another case here where you seem to be involved
in the --
I believe what I said was it was quite rare
until 2010. If I didn't say that --
Yes, I think you're absolutely right. Why was
it in 2010 that you became involved in criminal
proceedings?
In 2010, the Criminal department began the
prosecution of Ms Misra and, for the first time
I can ever recall, I was approached by a clerk
in the prosecution team, on behalf of a criminal
barrister, and asked to provide him with
information about civil cases that had been
dealt with in the civil courts where Horizon was
challenged or, alternatively, he may have
provided me with a list of cases that he wanted
additional information on. I can't quite recall
which of those approaches were taken.
Ihave a document that may assist you in that
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regard. It's POL00055212. This is 2 September
2010. Can we scroll down, please. This is the
case of the Crown v Gurdeep Dhale, and it's
Jarnail Singh writing to you. Jarnail Singh,
the senior lawyer in the Criminal Law Division,
writing to you and saying:
"I have [this case]. Can the Defendant have
identified previous cases where the Horizon case
system has been criticised, namely Lee Castleton
Jo Hamilton, Noel Thomas, Amar Bajaj, Alan
Bates, Alan Brown and Julie ford.
“lL understand that you and Counsel Warwick
Tatford looking at a number of cases in similar
circumstances in my case of Misra and I would be
grateful if you could give me details of that
and whether you can identify any other cases
listed above as to there were any questions or
criticisms of the Horizon System."
Does that assist you?
A. Yes.
Q. Can you tell us then what it was you were being
asked to do or what you understood the task to
involve?
A. I believe that Mr Phil Taylor of the Criminal
Law Department contacted me, it would either
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Q. Those are all specific named cases. I think he
also says "whether you can identify any other
cases listed above and whether there are any
questions or criticisms of the Horizon System".
Did you at that point carry out any exercise to
look back at the cases you had been involved in
over the years to see if there had been any
issues involving the Horizon System that might
be disclosable in those criminal cases?
A. No, I didn't.
MR BLAKE: Sir, I think that's an appropriate time
to pause for lunch.
SIR WYN WILLIAMS: Yes.
MR BLAKE: Can we come back at 2.00, please?
SIR WYN WILLIAMS: Yes, of course.
MR BLAKE: Thank you very much.
(1.00 pm)
(The Short Adjournment)
(2.00 pm)
MR BLAKE: Good afternoon, sir.
SIR WYN WILLIAMS: Good afternoon.
MR BLAKE: Thank you.
Mrs Talbot, when we left off before the
break we were on POL00055212 and that was
a letter from Jarnail Singh in relation to the
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have been very late December 2009 or early
January 2020, and asked me for information,
I believe, on the Castleton case, and I tried to
retrieve what information we had and supplied
that to the barrister.
I think, from other internal documentation,
that the barrister may even have spent a couple
of days at our office looking at materials on
the case of Castleton.
Now, Jo Hamilton, as you say, was
a Prosecution case, so I would never have had
any information on that.
Callendar Square, the only information I had
was that provided by yesterday's witness about
a particular glitch that, you know, became known
as the Callendar Square issue, Callendar Square
problem.
So, although Mr Singh has asked me for
information across all of these cases, I would
only ever have been able to provide information
about civil actions to him and I believe that my
ultimate response in December 2010 was along the
lines of "I would have thought you already had
this material as your barrister in the case of
Misra spent a number of days with us".
106
case of Dhale, requesting certain information
from you. That should be brought up on the
screen. Thank you. Do you recall that letter,
yes?
Yes, I do.
Thank you. I'm going to move on but I'll come
back to that particular topic shortly but can
we, before I do that, go to POL00107242 and it's
page 3. It this is 9 December 2010 and an
email from yourself to all and it says:
"Dear All,
“Now that the Misra prosecution has
concluded we now have to pick up civil Horizon
cases to see whether or not we should be
bringing proceedings in respect of them."
Had civil cases been paused pending the
decision in the Seema Misra case or the
judgment -- the verdict even, in the Seema Misra
case?
I think some had, yes.
Looking down to a message to Dave, you say
there:
"This was a chap who worked as a postmaster
2007 to 2008."
This is about David Bristow,
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a subpostmaster:
"He refuses to believe that he has done
anything wrong and that it was the fault of
Horizon which led him to be threatened with
summary termination -- he eventually resigned."
You say halfway through the next paragraph:
“He has jumped on the Postmasters for
Justice Bandwagon. I appreciate that the
complete printout would be very expensive.
Given your knowledge of Fujitsu, can you
estimate what the cost would be or suggest
whether there is any other way of proving that
the system was working correctly and that
therefore the losses it showed were real
losses?"
You seem there to be getting slightly tired
of the "bandwagon"; is that a fair summary of
your mindset at that time?
Within Civil Litigation, I was beginning to feel
frustrated and I think I've alluded to that in
my statement, because Fujitsu and POL were
constantly assuring us that there was absolutely
nothing wrong with the Horizon System and, yet,
every time -- well, every time a matter was
referred to Civil Litigation -- and this would
109
back to POL the business and get them to
authorise that they were prepared to pay for the
same. So that's why I'm talking about cost in
that particular extract.
At this stage, you've said you were frustrated.
It seems as though it seems all a bit of
a bandwagon to you and you don't want to go
through the expense of having to get information
from Fujitsu?
No, I was asking for Dave's opinion as to what
he thought and I think this is probably Dave
Hulbert, what he thought Fujitsu would charge to
obtain that information. I wasn't rejecting it
at all. I wanted information.
At this stage, 2010, were you aware of, for
example, the article in Computer Weekly? That
was a 2009 article?
I didn't read it personally but I have seen
additional disclosure making reference to it.
Can we move on to POL00055894, please. When we
just started after lunch I took you back to that
document, where it was a request in the case of
Dhale, that request was the 2 September 2010,
and this was, I think, your response, dated
16 December 2010. Do you recall why it took
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only have been a tiny proportion of postmaster
deficiency cases -- the response was becoming
regular that the subpostmasters were not at
fault, it was Horizon.
So we were frustrated because we'd been
given assurances there's nothing wrong on one
side and yet people are claiming there's
something wrong on the other.
You say there it would be expensive to get
a complete printout. I mean, by that stage were
you having so many cases brought by
subpostmasters or so many complaints about
Horizon being brought that you didn't want to
waste money on it?
No, that's -- pardon me. No, that's not what
I mean at all. I'm not a commercial lawyer but,
under the contract between POL and Fujitsu,
Fujitsu were only obliged to provide their
services in analysing cases 100 times a year.
Now, I'm not a prosecutor but I did come to
know that Prosecution would, in their own
investigations, utilise an awful lot of that 100
opportunities. Therefore, if you're dealing
with a civil case and you want an analysis of
data from Fujitsu, you would then have to go
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such a long time to respond to Jarnail Singh?
I think it's because there was another exercise
going on within Legal Services this time, to try
to reduce headcount and, during that process,
I was informed there was no more role for me
within Legal Services and it is on that occasion
that I moved over in the following January to
Royal Mail Group, the business.
So, by that stage, how small had the legal team
within the Post Office become?
In terms of permanent members of staff, quite
small, because a process had begun under which
the -- some of the regional agents but certainly
a lot of the London agents would provide lawyers
for a period of six to nine months to come and
work with the in-house team, ergo reducing the
actual employee numbers.
I don't quite understand that, sorry.
Sorry. There was an exercise going on to reduce
headcount within Legal Services --
Yes.
-- and I think, as part of trying to fulfil
obligations to our clients, in place of some of
us who were going, a process began under which
our external legal agents began to supply
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members of their firms to come and work within
Legal Services for a period of time, I think
a minimum of six months, sometimes longer.
So a secondment of some sort?
Asecondment, that's the word I was --
So they were reducing the size of the legal team
and replacing people who were experienced in
dealing with these kinds of cases with external
lawyers for a temporary period of time?
That's correct.
You say in that response:
“I thought that your barrister on the case
of Misra would have copies of everything which
he considered to be relevant from the time he
spent two days here. I only have email folders
‘on Lotus Notes insofar as they can be retrieved
and in Outlook but you are welcome to come over
and search them.
"There are numerous boxes in respect of
Castleton most of which are still with Stephen
Dilley ... who can let you know how much it
would cost retrieve them from their storage
facility."
Then you say this:
"There are ongoing cases every month which
113
comment on that.
But the fact that cases seem to have been
stayed, on hold, awaiting a decision on Misra
sounds as though Misra would have been very
significant for the Post Office?
I think it was significant to the Post Office,
yes.
"There are ongoing cases every month which raise
the issue of Horizon ..."
Was that not indicative of a wider problem
with Horizon at that stage?
The Mr Greening document that we referred to
this morning, if that had begun to be
implemented, would have required us to begin
reporting on subpostmaster cases and there's
a possibility that I might have been concerned
about numbers arising out of that. But, as
I say, that document was created in August 2000.
We're still only in December 2000. Probably --
2010.
2010, sorry. Probably hadn't got off the ground
as yet.
We have quite serious criminal proceedings going
on against Mr Dhale and Ms Misra. Do you know
if they were told that there were ongoing cases
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raise the issue of Horizon so it's a movable
feast. I'm endeavouring to pull together a list
of those cases currently with us where
allegations have been made in respect of
Horizon. Most of these cases have been on hold
awaiting the decision on Misra. The transcript
of that case is now being created and should be
with us shortly ...
Why was it that Misra was so significant at
this time?
Misra was significant for the business. It was
a criminal case, so, logically, looking back, it
shouldn't have had an impact on civil matters at
all. I can only conclude that a decision was
made that any embryonic subpostmaster deficiency
civil cases should be stayed pending that
decision -- pending the conclusion of the Misra
case, sorry.
I'll go on to draw your attention to a number of
other documents relating to the Seema Misra case
but, before I do that, might it be the case that
like Lee Castleton, Seema Misra's case was being
held out as an example to dissuade future
claims?
It was a criminal prosecution, so I can't
114
every month which raised issues of Horizon?
I don't know.
By this time, 2010, you knew about the report in
Cleveleys, you knew about the BDO report in the
Castleton case. You knew about complaint after
complaint about the Horizon System, so much so
it seems that cases were put on pause awaiting
a decision in the Misra case. Was all that
knowledge that you had relevant to the Misra
case and what was to become a precedent? Did
you feel any burden on yourself knowing that
this significant case was taking place to
provide information about your knowledge of the
complaints that had been made about the Horizon
System over the years?
I didn't see that as my role at the time.
I think I assumed, and this is only a personal
assumption, that Criminal would have been aware,
given their involvement with Security, Fujitsu
and POL.
You've said that the Criminal Divisions and the
Civil Divisions were kept very much apart?
They were.
You seem here to be a conduit for information in
some ways to the Criminal team. Did you see any
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responsibility on yourself to inform the
Criminal team about, for example, the Coyne
report in the Cleveleys case or the doubts that
were raised in the Castleton case or other
complaints, civil complaints, that you had
received in relation to the functioning of
Horizon?
I didn't.
Was there any process in place for drawing all
of those civil strings together and providing
that information to the Criminal team?
No, there wasn't.
Can we look at POL00055716. I think this is
a letter here -- is this from you or -- yes, if
we look over the page, it's a letter from you to
Guildford Crown Court. If we go to page 1, you
write to enquire whether the court will be
prepared to authorise the release of the tapes
of the hearing to arrange for them to be
transcribed:
“We need the transcript to us in other cases
where Fujitsu and the Horizon System are
challenged on similar facts. If the Judge is
prepared to release the tapes to us or the
transcribers for this purpose I would also want
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So it does seem, like the Castleton case,
that this was an important case for the Post
Office to win to dissuade others that were
waiting in the wings.
This was a criminal case and therefore I have
very limited information about it. I believe --
I know that I was asked to apply to the
Guildford Crown Court for the transcript. For
what use it was going to be put to, other than
that -- other than to be of benefit to Post
Office Limited, I can't really comment.
Who asked you to do that?
I'm very sorry but, without access to my papers,
I can't tell you.
You recall being asked to do it. It wasn't of
your own volition --
Oh --
-- but you don't recall who asked you?
I would never have written a letter like the one
‘on the screen at my own volition.
But you can't remember who asked you?
Not without additional disclosure.
I'm going to move on to a different topic, which
is the awareness or involvement of the Post
Office leadership and senior management. Can we
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prop
them to include details of the sentencing
hearing."
It does seem to some extent that you were
a conduit for these criminal matters and
gathering evidence to use against postmasters
who were involved in civil claims.
I don't think I was a conduit for civil -- for
criminal matters. I had other clients within
the business and I believe, if I was a conduit
for anybody, it was to provide information to
them, parties such as Mr Rod Ismay and Mike
Granville, who was Head of Regulatory
Relationships.
I can't now recall whether or not any order
was made for Misra to pay over any money to Post
Office Limited, so, therefore, it may be that
part of the reason for me writing to Guildford
Crown Court was to obtain this documentation
with a view to taking further civil proceedings,
but --
You're there writing to the Crown Court and you
say:
"We need the transcript to us in other cases
where Fujitsu and the Horizon System are
challenged on similar facts."
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please look at WITN04600211, please. I'm going
to start with Keith Baines who was the contract
manager with Fujitsu. So we're moving now far
back in time back to where we started today, the
Wolstenholme case, 4 August 2004. Can you
assist us with what involvement Keith Baines had
in the Wolstenholme case and these cases more
broadly?
I can only conclude from this that Keith Baines
had access to a statement that would have been
in general form useful in terms of creating
a witness statement specific to the facts of the
Cleveleys case.
Do you recall Keith Baines having been involved
in the early development of the Horizon project?
I don't know anything about the early
development of the Horizon project.
Did Keith Baines ever raise with you any
concerns he had about the functioning or
reliability of the Horizon System?
Never.
We've seen his name on a few documents today.
Mm-hm.
What was his level of involvement generally in
these civil proceedings against subpostmasters?
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The Post Office Horizon IT Inquiry
I'm sorry, this is 2004. I dealt with thousands
‘of managers over the 23 years I was working for
Royal Mail Group. I can't recall his specific
function.
Okay. I'll move on, then, to Rod Ismay and
others. Can we start by looking at POL00107426,
please. Can we look at page 3 of this document.
We have an email there from yourself to David
Smith, Jennifer Robson, Tony Utting, Rod Ismay,
and copied to certain people. In this, you
summarise the facts of the Castleton case. Can
you recall why this distribution list was being
used to summarise the facts of the Castleton
case in 2005?
I believe that David Smith was the most senior
officer on that list. Tony Utting was Head of
Security. Rod Ismay, you've already heard of.
Jennifer Robson, I think, was within the
subpostmaster deficiency collection team.
Was this a group that you communicated regularly
with?
No, these groups, as I've said before, they
really were a movable feast. People would move
in and out of these contractor lists.
I mean, there are some names that crop up time
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perhaps we can look at the final paragraph on
that page. It says:
"Mr Bajaj has taken the step of writing
an article in the SubPostmaster November 2005
edition, seeking information from other
postmasters in a similar situation.”
Then you highlight there "Issues":
"In each case the postmasters are
challenging the validity of data provided by the
Horizon System and the cases became litigious
before that evidence could be properly
investigated.
"In each case it was known that Horizon was
going to be challenged but there was no
procedure in place to
"(a) acquire the necessary data
"(b) identify somebody with the relevant
knowledge and capacity to interpret the data and
report on the same.
“If the challenge is not met the ability of
[the Post Office] to rely on Horizon for data
will be compromised and the future prosperity of
the network compromised.”
What did you mean by “the future prosperity
of the network compromised"?
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and time again in documents we've seen, such Rod
Ismay. Is there a particular reason why these
kinds of emails were going to him?
I can't remember what his title was at the time.
I'd like to read you briefly from this email.
Mm-hm.
It goes:
"Summary of Facts
"Castleton."
Perhaps we could scroll down a little bit
further. He says at the bottom of that, bottom
paragraph:
"As part of the claim the solicitors for
[Lee Castleton] have stated in the allocation
questionnaire that they intend to call evidence
from other existing and former postmasters about
the problems with the Horizon System. They have
asked for disclosure of data about all calls or
complaints logged from postmasters about the
Horizon System, presumably from the inception of
the system. They have called for disclosure of
all documents removed from the Branch Office
during the investigation. There is an issue
over locating all of those documents."
Then you summarise the case of Bajaj, and
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POL's ability to rely upon the Horizon System
was absolutely crucial for the continuation of
POL as a business.
So you had challenges from subpostmasters, here
Castleton and Bajaj, that you were concerned
about. The future of the network was at stake
and you make five suggestions, and I'd just like
to take you through those suggestions. The
first:
"A robust procedure is set up and
communicated to all relevant parties for
extracting necessary data from Horizon at
an early stage in all cases leading towards
possible termination of contract in each case
where the Horizon data is challenged."
Second, you talk about:
".., identifying a small team and training
them in interpretation and investigation
techniques."
Third:
"Fujitsu and the [Post Office] to liaise on
identifying a number of individuals or
specialist computer firms who could provide
a professional and independent report upon the
Horizon System in general and in the two cases
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to hand if necessary.”
Just pausing there, the evidence this
morning was very much that you took each case as
it came, each case individually, you weren't
coordinating the various cases. This is quite,
it seems, a significant suggestion that the Post
Office and Fujitsu should identify an external
firm to carry out an independent report. Do you
recall making that recommendation?
This is my communication. I wish to ensure that
for each and every case that we always litigated
‘on a purely independent basis and, by that,
I mean on the facts of every single case, that
we would be in the best possible position to
litigate by having all relevant data. I was
somewhat frustrated by the fact that proceedings
had been issued in the matter of Mr Lee
Castleton without all appropriate data being
present.
I was seeking, therefore, to try to persuade
the powers that be within POL -- I can't now
recall to whom entirely this communication
went -- but I was trying to persuade the
business that they really should put procedures
in place that would give solicitors, such as
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solicitors, so that we didn't end up in another
situation where proceedings were issued without
all the relevant material being present.
Was that coordinating role established as at
2005/2006 and onwards?
It was -- it - the nearest it ever got was
an offer by Mr Tony Utting, who is third or
fourth on the communication list, who said that
he was prepared to do so, but then -- I think he
referred to it as “the sting in the tail", his
department had been tasked with reducing
headcount by a percentage. So, ultimately, no
such position was ever created and I think that
late on in 2000, when Andy Greening was trying
to get a grip of the whole subpostmaster estate,
that was still outstanding.
Thank you. If we look, just to complete this
document, on that page you were on before,
page 5, there were two other recommendations
there. The fourth and fifth, if we scroll down,
thank you: one was investigating whether or not
they hold any data of the number of complaints;
and the fifth was identifying members of staff
who can provide witness statements.
Can we move on to POL00070496, please. This
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myself, a better chance of being able to
litigate successfully. But I was just a case
worker.
If we look at page 3, that has the recipient
list that we've already been through. You say
you can't recall, but --
Mm.
-- whose responsibility within that list would
it have been to take forward the recommendation
of identifying an independent external firm who
could carry out an investigation of Horizon?
I think, this is just to the best of my
recollection and opinion, that David Smith was
the most senior person on that list of contacts.
As at the end of 2005, going into 2006, 2007,
was that independent report commissioned?
No.
Were you concerned that it wasn't commissioned?
Of the, I think, five or so recommendations that
I made, I was less concerned about the
commission of an independent report than I was
about the creation of a team or even
an individual who would gather sufficient
knowledge of the system so as to be able to give
proper instructions on each case to external
126
is a similar time, this is a couple of days
earlier. If we look at the bottom email from
Tom Beezer. This is updating various
individuals about the position of the Lee
Castleton case and he outlines there some
concerns you had. It says:
"I spoke to Mandy. She is ... a little
disturbed that this matter has wide implications
This I talking about the default judgment
and it references there:
"As we were talking about this morning, Hugh
James are trying to contain an embryonic and not
yet issued class action relating to the Horizon
System.
"A judgment in relation to it is currently
very bad news."
Then there are requests from you and it
says:
"Mandy has made a number of requests that
I feel we MUST comply with ...
"4) that [you are] kept fully informed on
[the Castleton] matter ...
"2) that [you] be sent a full set of
proceedings ... and a full set of
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correspondence ...
"3) due to the matters handled by Hugh James
relating to Horizon, Mandy asks that we speak to
them to ensure we are all pulling in the same
direction. This is even more important given
the threatened class action. Who makes this
call is partly dictated by how many Horizon
related cases we currently have. More on this
below.”
Then 4:
"Mandy asks that we NEVER issue proceedings
on a claim based on Horizon evidence ... without
her specific consent.”
Now, that role not having been created, the
Horizon co-ordination role, were you in some way
filling the vacuum and fulfilling that role?
In respect of cases that were being dealt with
by Bond Pearce, yes. But that was purely in
respect of litigation. It was not my role to
coordinate anything on behalf of POL or Fujitsu.
This was just my concern as a litigator to
understand what -- which cases Bond Pearce were
already instructed to issue proceedings upon.
I did not want another repeat of Castleton.
At 4, you asked that they never issue
129
Usually Error Resolution Team at Chesterfield.
They're specific and quite -- the language used
is rather mandatory. Was this you on your own
asserting control or were you acting on somebody
else's behalf in instructing Bond Pearce in this
way?
No, this was me trying to fill my role as
a solicitor, in-house solicitor for Post Office
Limited in this case. This -- yes, this was me
acting to try to ensure that a repetition of
issuing proceedings in a Castleton situation
didn't occur again.
Can we look at POL00090437. It's page 63. This
is a bundle of papers that we've looked at
already. Can we look at page 63, please. Still
sticking with the theme of management knowledge,
page 63 is an email from you to a very similar
list of names, common names that we've seen
before. David Smith, Rod Ismay, et cetera.
This is you passing on the good news about the
Castleton case. It's a document I think we
looked at earlier and it's where you update them
about the progress of the negotiations.
Why this particular list on this particular
occasion? It's quite a detailed note of
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proceedings without your specific consent. Why
was that?
Because, as I've just said, I didn’t think it
was appropriate on the case of Castleton, under
proceedings had hadn't been issued before
without -- with missing documentation in place,
leading to a very expensive defence of
a counterclaim. If they were to issue
proceedings on a subpostmaster case, I wanted to
make certain that all the appropriate
documentation was going to be in place and I was
still hoping at this time that it would be
possible for POL to commission a team to, you
know, facilitate that going forward.
You've described in your evidence earlier that
you were just a case worker.
I was.
This doesn't sound much like the role of a case
worker. It sounds as though you were applying
some management of the Horizon cases; is that
fair?
I was never a manager of the Horizon cases.
I just tried to deal with cases that came into
my inbox.
Who were you doing this for?
130
negotiations. It's not a summary of what's
happened. It's very much contemporaneous: this
is happening. Why would people in other parts
of the Post Office's business be interested in
that or why would they have received that?
This is really rather similar to the list of the
document we looked at two documents back.
Yes.
Therefore, these were individuals who had
an interest in the case of Mr Castleton.
Do you know why they were particularly
interested in the case of Mr Castleton?
I can't speak to that, I'm sorry.
Can we look at page 33 of the same document.
It's the second half of the page. Sorry, the
bottom page, even. You're there updating the
entire group, 2007 now:
"This is just to let you know that we have
been completely successful in defending all the
allegations made by Mr Castleton. You will
recall that he contended that no genuine losses
occurred whilst he was a postmaster and that any
losses were manufactured by the HORIZON System.
The judgment has entirely vindicated the HORIZON
system."
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Again, similar, if not the same,
distribution list. Was it common for updates of
cases to be sent to this distribution list or is
there something particularly special about the
Castleton case?
The importance of the Castleton case was the
size of the counterclaim and the, in effect,
attack on the Horizon System.
If we look above, we have a response from Rod
Ismay. Rod Ismay there says:
"Thanks Mandy -- great news."
Then in the next paragraph:
"What can we do on a proactive comms front
here? We've watched the various inflammatory
letters in the SubPostmaster letters page and
wanted to be able to assure branches and clients
that they can rely on the integrity of Horizon.
"Any thoughts on comms following this case?"
What role did Rod Ismay have in respect of
comms, communications? He was the head of
Product and Branch Accounting, would you have
understood it to be part of his job to be
promoting communications there?
I don't know what the extent of his function was
at the time. It may well have included comms.
133
about defending claims for repayment.
"Outstanding matters are:
“communicating the matter to the Fed --
agreeing a suitable form of words possibly with
the assistance of external relations.
"arranging a meeting with Fujitsu --
[proposed form of words].
"agreeing with the auditors that they will
formally ask for, examine and refer to at least
three months worth of branch trading statements
[in future cases]", et cetera.
Do you think it was appropriate for somebody
who describes themself as "just a case worker"
to be making suggestions on how to publicise the
result of a court case?
It wasn't, in retrospect. I can only assume
that that has something to do with the document
that we looked at previously.
In 2007, you hadn't moved on to your 2010 role
in the wider Post Office. You were still
managing Civil Litigation at this stage?
Yes.
Why do you think you were drawn into making use
of the judgment and commenting on ways in which
it would be publicised?
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There was a Comms team at Royal Mail Group
Headquarters.
Let's look at a document that makes a similar
point. It's POLO00113488. We're now on
20 February 2007 and this is where Mr Castleton
has agreed to pay the costs. If we scroll down,
please, to the second half of the page. Similar
names on this distribution list. Keith Baines,
John Cole, Rod Ismay, et cetera. It says:
"Castleton has ... agreed our total bill for
costs in writing which means that we do not have
to go to Court to have them taxed which incurs
additional legal costs in its own right. This
response also indicates that Castleton has no
intention of appealing against the decision of
the Court and that the judgment is the final
comment on the matter.
"As such, we need to get on with making as
much use of the judgment as possible. Stephen
Dilley has asked for permission to publish
an article in a legal journal about the case
which I have no objection to as long as we
maintain editorial control as the more publicity
the case is given, the greater should be its
effect upon postmasters who take legal advice
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I don't know. I can only assume there is
a missing minute of a conversation where
possibly I was asked to assist on this matter.
I agree with you, this is not the role of
an ordinary civil litigator and this was
possibly the one and only time that this ever
occurred.
Do you think it was inappropriate to be doing
that?
As an ordinary civil litigator, yes, it was but
I can only conclude that I was asked to do so by
some of the parties to whom that communication
is addressed.
You were asked to, you say, by one of those
people, but --
l assume.
You assume. Did you ever raise any concerns
with anybody about the position that you were
being put in?
No.
Can we please look at POL00104618, please.
We're now in August 2008. Can we please look at
the second page, at the bottom half of the
second page. We have an email from Andrew Winn
and we'll see in due course that this is
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forwarded to you. Do you recall Andrew Winn?
I don't recall Andrew Winn and I don't believe
I ever dealt with this email, as the writing on
it isn't mine. It could well have been dealt
with whilst I was away on annual leave.
Let's just have a look at what it says. It
says:
"Coms to branches
"I think we still do not have clear sign-up
around who would be communicated to. My
understanding is that the business only wants to
contact branches who have reported the
discrepancy or who have suffered financial loss
by making good an inflated amount."
We'll see in due course through the later
email what this is all about. It's about
a software glitch within Horizon and this email
is a discussion about who to tell about the
software glitch, whether you tell the individual
branches who have suffered the glitch or whether
you communicate it more widely. Do you recall
this at all?
No. I believe it could have been dealt with by
my line manager, given the manuscript comments
‘on the document.
137
there:
"Hi Andy -- before anyone sends any comms
anywhere please can you get confirmation that
Mandy Talbot/Biddy Wyles in Legal have seen and
are OK with proposed wording.”
Now, why was Rod Ismay suggesting that you
comment on wording that was sent to branches,
following the identification of a software
glitch?
My reading of these communications is a request
by Rod Ismay for myself or Biddy, who was my
line manager at the time, to look at the
drafting of the letter. It's headed "Comms" but
I would have interpreted it as a letter that
they proposed to send to individual branches who
had suffered from this particular glitch. It
‘was really -- it was also part of our function,
although we were a Civil Litigation Department,
to assist many departments within POL and Royal
Mail Group with drafting correspondence if they
felt they needed assistance.
Did Rod Ismay put your name forward in
particular because he knew that you were dealing
with issues relating to the Horizon System?
I think you would have to ask him on that point.
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a
It says there:
"This accepts the risk that other branches
may raise the issue with [the Post Office] at
a later date.
"In terms of communication script I would
have thought something on the lines of --
Singleton makes good loss - 'Your branch
received a software change to Horizon. This has
caused a stock unit discrepancy to be calculated
incorrectly and as a result you have made good
a loss of [X amount] whereas the correct
loss/gain should have be [Y amount].
"Post Office Limited need to compensate you
for the loss and will send you cheque for the
above amount. Can I confirm [the name that is
required].”
Then over the page, if we could scroll down,
so we can just see the top of the page before.
Where a branch has actually made a gain, the
proposal there is:
"Post Office do not intend to recover the
gain.”
If we go to page 1 of this document,
please -- sorry, if we go over the page to
page 2 we have an email from Rod Ismay who says
138
Is it something that you would typically be
asked about, irrespective of your involvement in
the Horizon System or is it more likely that
this was being provided to you because of your
knowledge of the Horizon System?
We were asked to draft, in some cases, comment
and edit letters from all different departments
in the whole of Royal Mail Group.
Let's look at the first page. This is the email
that is sent to you. So it's sent to you and
Biddy Wyles. It says:
"Not sure if you are the right people to
contact regarding this.
"Basically, we recently suffered a software
glitch within the Horizon System which resulted
in various over/under payments (both actual and
virtual) to certain (but definitely not all)
[Post Office] branches.
"We are trying to come up with suitable
wording to use in explaining these over/under
payments and how we intend on correcting them,
and were wondering if you are the right legal
people to run this past first?"
Is it your evidence that you never saw this
email, despite it being sent to you?
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If I were away on holiday but my line manager
Biddy -- whose handwriting I think I recognise
‘on the documents that were disclosed to me --
had already dealt with it, I would have been
very grateful that that was something I didn't
have to look at.
Do you recall in 2008 it being brought to your
attention that there was a software glitch with
Horizon, which resulted in various over/under
payments?
Until such time as this material was disclosed,
no, I do not. I've no recollection of it.
Are you aware of any similar references to
software glitches around this time that was
communicated throughout the department or
throughout senior figures within the Post
Office, for example?
I can't speak as to senior members of the Post
Office. Legal Services were a distinct unit in
their own right. I can only speak as to what
I personally knew.
You're not aware of that having been
communicated amongst your team?
No.
Can we look back at a document that we have
141
the Chairman's Office?
It wasn't -- it was not part of my job to liaise
with the Chairman's Office, but quite often we
would receive requests for assistance from the
Chairman's Office and, therefore, I knew the
names of people to ask in the Chairman's Office
who did indeed deal with high profile
correspondence sent to the group. I knew their
identities so I knew who to contact there to see
if they had any record of Mrs Nixon or Dixon.
Wha, in particular, would you liaise with in the
Chairman's Office?
In this instance, it appears to be Michele
Graves. But, again, there were lots of
different team members over the 20-odd years
I was dealing with the Chairman's Office.
If we stick to 2010, who, in particular, would
you deal with in the Chairman's Office?
Well, on this occasion, I think it's apparent
that it was Michele Graves.
Was there anybody else who you liaised with in
the Chairman's Office during this period?
I cannot recall. Possibly if there's other
emails, I might recognise the names.
In this period, to your knowledge, was the
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already looked at today, and that is
POL00053778, and can we look at page 5, please.
Thank you. It's the bottom of that page. So we
saw there, that is the email from you to Michele
Graves and others about the prosecution of
a former postmistress and allegations about the
Horizon System. If we turn to page 1 of this
document, we have an email being forwarded from
you to Warwick Tatford and it says:
"Warwick
"I have made enquiries of our Chairman's
Office team which deals with high profile
correspondence and they know nothing of
Mrs Nixon or Dixon of Highcliffe."
It's signed by you there. I think now it
says "Dispute Resolution, Company Secretary's
Office". By this stage were you in a different
team?
I was in exactly the same department, it's just
we'd stopped becoming litigators and we were now
dispute resoluters.
You're there mentioning enquiries of the
Chairman's Office?
Yes.
How often was it part of your job to liaise with
142
Chairman's Office aware of complaints from those
who were being prosecuted about the Horizon
System?
I cannot speak to what the Chairman's Office or
their staff knew. This is merely an example of
me seeking information from them.
Do you think it's likely that, when you were
seeking information from them, you would have
told them that there is a case ongoing that is
making a complaint about the Horizon System?
It's possible.
Do you recall what the enquiries were that you
were making at that time?
This was in connection with the case of Misra,
judging by the time period.
Thank you. I'm going to move on to another
document, POL00106867, please. This is a pile
of correspondence and I'm going to go through
three or four emails within this pile. Can we
start, please, with page 27. Thank you. Can we
scroll down to the bottom half of that page.
You're not, at this stage, copied in, although
you are within the chain and I'll take you to
the relevant email. But this is an email from
Andrew Daley to Jason Collins, Graham Brander.
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We have Andy Hayward bec'd in. Andy Hayward was
from the Security team. Do you remember him?
It's a name I recognise.
It says:
"Jason/Graham,
"Andy called me and asked whether you guys
... could put together some stats on these cases
where the accused's defence was/is the Horizon
data is unreliable for any amount of reasons
given the accused."
He attaches there an article which is titled
there “Horizon blamed.pdf". This is February
2010. I mean, this sounds like much kind of
thing that you were recommending in 2005, wasn't
it?
I was -- I was recommending in 2005 that
a sensible process be put up to assist us with
civil litigation cases.
This is 25 February, 11.49. Can we now turn to
page 25 in the bottom email. We have the same
date now, 4.10 pm, and it says:
“Andrew/Jason
"I'm aware of two ongoing cases at West
Byfleet ... & Orford Road ... and also some
historical cases ... but as Fls ..."
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is a brief summary of the agreed key activities
to progress the next steps in relation to the
above piece of work ..."
The above being the subject, "Challenges to
Horizon". Do you recall that conference call
taking place?
I don't.
"AH & MT
Presumably the "MT" is you, Mandy Talbot.
I believe so.
"AH" is presumably Andy Hayward; is that right?
I assume so. I think there is a list of our
initials at the end of this document.
Absolutely. If we scroll down, we can see
exactly who was in attendance. It's over the
page. Then we have: MT, Mandy Talbot; RI, Rod
Ismay; RM, Rebekah Mantle; Dave King; Sue
Lowther; Dave Posnett; Andy Hayward.
So if we go back, it has you providing
information on past and present cases with
reference to the Horizon challenges, and it
says:
"Note: I have asked the fraud team to review
[approximately] the past 2-3 years case file
although these challenges are of a more recent
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Do you understand what that means at all?
For information, possibly.
"... we wouldn't have Horizon disputed cases
other than those reported by the investigators,
who will have far more details on the issues
than us."
Then he says this:
"I have attached an article from an IT
magazine which may have brought this issue to
the fore in the 1st place and which may be of
interest to lan.”
Do you remember the article that's referred
to in this correspondence at all?
I've seen reference to it but I can't remember
ever reading it.
Can we please look at page 3 of this chain.
Thank you. If we look at the bottom half, we're
now at 26 February and Andy Hayward has included
you as the first recipient of this email. I'm
going to take you through it. Do you recall
receiving this email?
Not until it was disclosed, no.
It says, as follows:
"All,
“Following our conference calll today, below
146
nature."
Do you recall the decision to review two to
three years of case files?
No. All that would have concerned me, on
receipt of this email, is to try to provide
Andy, on behalf of Sue, with any information
I had that could assist them with this piece of
work.
The case of Castleton, for example, and the case
of Cleveleys, they were older than two to three
years.
Mm.
Do you recall, around the 2010 time, talking to
these individuals about the Cleveleys case or
about the Castleton case?
No, and I wouldn't have. I would only have
provided what information I had about civil
litigation cases. The reference to the fraud
team there, they were the investigators that fed
into the Prosecution department. So that really
wouldn't have involved me.
Then:
"Information Security ... to conduct initial
investigations and provide Terms of Reference
outlining remit and requirements to carry out
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The Post Office Horizon IT Inquiry
full investigation.”
So the proposal seems to be that the
Information Security team conducted an initial
investigation but that is then followed by
what's called a full investigation. Do you
recall that?
I don't recall the conference call but, as it is
recorded on this document, then that must be
what happened.
If we look at the third piece of work:
"Subject to agreement of 2 above, conduct
full investigations into integrity issues, with
conclusions/report provided. Once investigated
and conclusions drawn, gain external
verification to give a level of 'external
gravitas’ to the response to these challenges
(Recommend Ernst & Young as most suitable
partner to complete this)."
Was there in fact a full investigation into
integrity issues that was verified in some way
by an external firm?
If that ever occurred, I was never made aware of
it.
In fact, you don't recall this meeting?
I don't, but I suspect that it was probably
149
Given that I had originally suggested something
similar in 2005, although I cannot recall it,
I suspect that I probably did.
Do you recall any conversations?
I'm sorry, I can't.
Can we look at page 1. This is the email, the
intervention that you've referred to. Actually,
sorry, if we look at the bottom of page 1 you'll
see that Dave Posnett there forwards the earlier
chains to Rob Wilson, and he says:
"Can we please ensure that Rob Wilson (Head
of Criminal Law, [Royal Mail Group]) is kept
appraised of the situation ..."
If we scroll up, this is his response. Do
you recall why Rob Wilson wasn't invited to that
original meeting?
No, I don't. As I say, I don't actually recall
the telephone -- I really do suspect that it
probably was a telephone conference. I've no
idea why he wasn't invited to that original
conference.
Having been what you described as just a case
worker up until this point, was it not
significant to you that you were being drawn
into what was quite a significant step on behalf
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a telephone conference call and we had lots and
lots of those.
Do you recall, in February 2010, the discussion
about a full investigation into integrity
issues?
I cannot recall it but, as it is recorded on
this document, it must have occurred. I can't
unfortunately assist the Inquiry any further on
this point than what is already written on the
document.
Isn't that entirely consistent with your
recommendation back in 2005, that there be
a full investigation?
And that is why I was very happy to support it.
What did you do in respect of supporting it?
I believe, though I would have been prepared to
provide what information I had about civil
subpostmaster deficiency cases to Sue Lowther
but I do not think, because of an intervention
by the Head of Criminal Law, that this piece of
work proceeded any further. But that is just my
opinion.
Being consistent with your suggestion in 2005,
do you recall having spoken out in favour of
this full investigation into integrity issues?
150
of the Post Office?
Well, both I and my line manager, Rebekah
Mantle, were litigators and, in effect, we had
an interest in the business being able to
litigate as efficiently as possible and, given
my recommendations in December 2005, I wasn't
too surprised to be involved in this.
Is it not something that you would have had
quite a good recollection of, given that it was
‘one of the more recent incidents, 2010 -- we're
not going to back to 2005 now -- and that you
were being involved in what is quite
a significant enterprise on behalf of the Post
Office?
I wish my memory were that good. I'm sorry,
I can't assist any further.
Can we look at the top of page 1, and this is
the email response from Rob Wilson. I'm going
to read from quite a lot of it. It says:
"Dave,
"If it is thought that there is a difficulty
with Horizon then clearly the action set out in
your memo is not only needed but is imperative.
The consequence however will be that to commence
or continue to proceed with any criminal
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proceedings will be inappropriate. My
understanding is that the integrity of Horizon
data is sound and it is as a result of this that
persistent challenges that have been made in
court have always failed. These challenges are
not new and have been with us since the
inception of Horizon as it has always been the
only way that Defendants are left to challenge
our evidence when they have stolen money or
where they need to show that our figures are not
correct.
"What is being suggested is that an internal
investigation is conducted. Such
an investigation will be disclosable as
undermining evidence on the defence in the cases
proceeding through the criminal courts.
Inevitably the defence will argue that if we are
carrying out an investigation we clearly do not
have confidence in Horizon and therefore to
continue to prosecute will be an abuse of the
criminal process.”
Pausing there, is that something that you
recall being said to you in these discussions?
I don't remember the discussions and this is the
opinion of a criminal prosecutor.
153
be open to criticism. This is 2010. So quite
a long time before the Court of Appeal
ultimately heard these cases. Given the
significance of such a statement, do you still
not recall receiving this, discussing it?
I'm afraid I don't, but I can see that the
second person to whom this document is
addressed, Mr Doug Evans, was the solicitor at
the time.
There is, of course, reference below to civil
litigation. It says:
"What we really need to do is impress on
Fujitsu the importance of fully cooperating in
the provision of technical expertise and witness
statements to support the criminal and civil
litigation now and in the future.
"Given the nature of the discussions that
took place on 26 February, I am staggered that
I was not invited to take part in the
conference.”
In light of the implications of this
potential report, I think you said that it
wasn't ultimately pursued, the independent
investigation and you linked it in some way to
this email. Can you assist us with how you link
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Q. The concern that appears to be being raised in
this email is that, by carrying out
an investigation, that will be disclosable as
undermining evidence. Would you not remember
something that significant?
A. I'm afraid I don't.
Q._ Ifwe continue, the third paragraph:
"To continue prosecuting alleged offenders
knowing that there is an ongoing investigation
to determine the veracity of Horizon could also
be detrimental to the reputation of my team. If
we were to secure convictions in the knowledge
that there was an investigation, where the
investigation established a difficulty with the
system we would be open to criticism and appeal
to the Court of Appeal. The Court of Appeal
will inevitably be highly critical of any
prosecutor's decision to proceed against
Defendants in the knowledge that there could be
an issue with the evidence."
Again, quite, you might think, a significant
statement, that it could be detrimental, that if
they secure convictions in the knowledge that
there was an investigation where the
investigation established a difficulty, they'd
154
the two?
A. Given the concerns raised by Mr Wilson, this is
only my opinion, I assume that this dissuaded
the Information Security Department from
proceeding with their original intention. But
that is just my opinion.
Q. We can look at another email you were copied
into on page 9 of this chain. It's an email
from Susan Lowther of the Information Security
team, and she says:
"All,
"As was discussed on the conference call and
taking into account Rob's comments to confirm
that what we're looking at is a ‘general’ due
diligence exercise on the integrity of Horizon,
to confirm our belief in the robustness of the
system and thus rebut any challenges."
Looking back at that original email where
the discussion had been taking place to carry
out an exercise, is that a fair description of
what seems to have been discussed at the
original meeting? That it was simply going to
be a general due diligence exercise?
A. I'm afraid, as I've said before, I cannot
remember the original conference call meeting.
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Q. There's one final document that I'll take you to
in this pack and I'll leave it at that. It's
page 15. The final. Thank you very much. Dave
King, Security Architect, continues on this
email chain. You're still copied in, 8 March,
3.27 pm.
“As discussed, I can confirm that we are in
no way questioning/investigating the financial
integrity of Horizon, or of the accounting
system as a whole. The Information Security
review is to look at the ways in which messages
are sent at a system level ..."
Again, is that consistent really with what
was being proposed at the meeting at which you
attended?
A. I'm afraid I cannot recall the precise detail of
that meeting. I'm sorry, but I can't assist
further.
Q. Okay. Eventually, we have something that we
refer to as the Ismay report. Can we look at
POL00026572. You're copied into this report
from Mr Ismay. The date is 2 August 2010. You
may not be able to assist us but is this
something that arose out of that meeting or is
this something else?
157
of enquiries that were made by Rod Ismay?
A. I don't know. It all depends what he asked me
for. I would have done my best to provide him
with what information I had.
Q. Can we please now look at POL00055418. We're
still in 2010. We're now in October, 8 October
2010. This is an email from you to Jarnail
Singh, copied to Mike Granville and Rod Ismay.
The subject is "The Horizon trial". It seems as
though this may be the Seema Misra case. It
says:
"Mike and Rod are very interested in any
developments at the trial next week which impact
on Horizon. You promised to let me know if
anything unfortunate occurred in respect of
Horizon. Please can you copy Rod and Mike into
any messages. Incidentally, I assume that you
have briefed external relations. Can you let us
know who you have briefed because Mike and Rod
may wish to have input into any story relating
to Horizon. They may give you call on [and it
gives a number]. Incidentally Postmasters for
Justice met with the Minister this week and were
accompanied by Issy Hogg and the lady from
Shoosmiths."
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A
I do not know whether this document arose
directly out of the original Sue Lowther
proposal just discussed.
Were you involved in the drafting of this report
in any way?
No. I may have been asked for information by
Mr Ismay, but I had no involvement in the
drafting of it whatsoever.
All of the things that we've been talking about
today, the Cleveleys case, the report from Jason
Coyne, the Castleton case, the report from BDO,
all of the various reports to you over the years
where people were complaining about the Horizon
System, are these matters that you passed on to
Rod Ismay as part of his investigation?
If he had asked for information as broadly as
you've just defined it then I would have
provided that to him. But, after this period of
time, and with no documentary evidence recording
what I sent or did not send to him, I cannot
assist further.
Your evidence today was that you dealt with each
case individually.
That is correct.
Do you think you took that attitude in respect
158
We spoke earlier about whether it was
appropriate to get involved in matters relating
to publicity, et cetera. What exactly was your
role here in relation to the Horizon System and
in relation to more senior members of the Post
Office?
I didn't recall this document until it was
disclosed. I believe, to a large extent, I was
just performing the role of being a conduit
between more senior members of the POL business
and Mr Jarnail Singh, who was dealing with the
case of Horizon, which had become the next --
the case of Misra, which had become the next
test case on the Horizon System.
Was Misra -- I think we've discussed this
already -- very much seen as that test case,
very similar to Castleton in that respect?
I believe that it was, although I had much less
knowledge about it, simply because it was
a prosecution not a civil action.
Do you think here you're once again being used
in a policy role, rather than a legal role?
I have never been involved in a policy or
a strategy role. I can only assume that I had
been asked by Mike Granville and Rod Ismay to
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keep them updated with developments in this
case.
You've told us that you weren't involved in
criminal prosecutions and rarely came across
them. Why are you, in particular -- why were
you dealing with this on behalf of Mike and Rod?
This was an unusual case, because, as I referred
earlier, the barrister in the case of Misra had
been in touch personally to ask for information
and, therefore, I believe, on this case alone,
I was performing that conduit function.
Can we move on to POL00062075, please. Here
we're in 2014, so you now are in your regulatory
role --
Yes.
-- and you're receiving information relating to
a criminal prosecution.
Excuse me. If I can interrupt. I suspect that
I was copied in to that by mistake. I assume
I was on original template and they just never
bothered to remove me. I would have had nothing
to do with any prosecution case in 2014. I was
firmly embedded in the compliance team within
Royal Mail Group by then. It might have had my
CC on it, but I would never have come across
161
a December trial, but preserving our ability to
get that adjourned if they serve a late report
that we need to deal with. I said that we could
prepare for a December trial if necessary and
I was happy to do so, but I was concerned to
make sure that we could reply to any expert,
reports served by Castleton. I also think that
‘our Counsel was effectively trying to ambush the
other side because he thinks that when we serve
these fifteen witness statements on them, they
will be knocked reeling a bit. Mandy
appreciates the tactics of this. She said that
the only thing with a December trial is that the
Post Office get very busy", et cetera.
Were you happy with the general approach
that was taken in Mr Castleton's case?
As detailed in the paragraph we're looking at,
yes, I was.
It seems there as though Stephen Dilley
certainly thought that you were providing
instructions. I think the answer is going to be
no because we've been over this a few times
today, but can you recall who in the Post
Office, other than yourself, who driving this
strategy?
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this document.
But even in 2005/2006, or onwards, prior to your
moving roles, why would you be copied into a --
the result of a criminal case?
I would have been copied in to the result of
a criminal case in the pre-POCA days, where
there'd been a failure to obtain an order for
compensation, so that Civil could assess on
behalf of the business whether there was any
viability of bringing civil proceedings to
achieve a recovery.
Thank you. I have two more topics to address.
I should finish them hopefully before the break
otherwise we'll take a break and I'll finish the
final topic. There will then be a small number
of questions on behalf of Core Participants.
I want to briefly address the general
strategy that was pursued against Mr Castleton.
Can we look at POL00072432. This is
an attendance note that we saw that I went
through with Mr Dilley and it's paragraph 3,
about halfway down, that I'd like to look at.
It's 16 October 2006. It says there:
"Counsel therefore wants to play some
brinkmanship with the other side, ie push for
162
I'm afraid I can't. I would have obtained
instructions, but after this period of time, I'm
sorry, I can't assist.
Can we look at POL00069453, please. This is
another attendance note. This time the 18th, so
two days after. It says:
"I had a conversation with Mandy Talbot.
She has spoken with Claire and Catherine at the
Post Office. They are happy to follow counsel's
advice and go for a December trial purely as
a tactic, even though acknowledging that it is
an unlikely event."
Et cetera.
Does that assist you with identifying who at
the Post Office, at least in respect of that
particular strategy, was providing the
instructions?
This was a reference to Clare Wardle, my
immediate line manager in Legal Services, and
Catherine Churchard, who was the solicitor to
the Post Office, as the whole organisation was
known as back at that time.
Does that assist you in respect of any of the
evidence that you've already given today?
I know you asked to be pointed to specific
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documents. Does that assist you?
This is an example of me escalating up within
civil litigation the advice that I'd been given
to ensure that they were satisfied with the
same. I would imagine that there would have
been a similar escalation within the POL side of
the business at the same time. But I --
You say the POL --
I can't assist with the identity of those
parties after this period of time.
Okay. The final topic before we take a break is
the difficulty or issues relating to obtaining
information from Fujitsu.
Can we look at POL00082080. And it's
page 6. This is an email from Stephen Dilley to
yourself.
Mm-hm.
If we could scroll down, please, it says:
"Both
I copied you into my epic email ... but the
response to the same has been limited in the
extreme.
"I attach the responses of Graham C Ward and
David Hulbert. I have also been contacted by
John Cole asking for assistance in preparing
165
and evidence from Fujitsu.
There's a message passed on it's forwarding
a message from Graham, the casework manager at
the Post Office. If we scroll down a little
bit, and this is addressed to you, Mandy, and it
says there, at the bottom:
"With regards to my knowledge of Horizon,
I can obtain data as and when required being the
SPOC between [Post Office] and Fujitsu, but I do
not have the working knowledge of the system to
analyse data and comment on whether Horizon was
working correctly or not, or whether
transactions have been processed correctly and
may still affect the office balance. I know
Tony U has agreed to have a look at the
Marine Drive data, but he is still waiting to
hear exactly what information needs analysing.”
Over the page it says:
“Fujitsu should be able to offer a technical
perspective of the system working properly.
I have searched my records of previous
statements received and have found one where
Brian Pinder's predecessor Bill Mitchell
provided a statement (see below)" -- and we'll
see that below -- "commenting on individual
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a spec for external expert or experts but
I think this is of limited use until we have
reports completed by Fujitsu on the system and
POL on the data provided. However in respect of
an external expert from the field of computer
systems and accounting can you suggest any
names..."
Then it says:
"Stephen
"In the collation of evidence did you come
across anyone who you believe could actually
interpret the information which was obtained
from Fujitsu via Graham or the paper documents
which were available from the Post Office. As
you can see I am still getting the run around on
these cases by people who are not prepared to
assist."
Do you recall any issues with getting people
to assist and if so, who?
In the matter of Castleton, I believe that
Stephen Dilley was able to eventually provide --
obtain assistance and witness statements from
persons within Fujitsu. However, I've alluded
to the fact that in ordinary civil cases, it
could be very challenging to obtain information
166
calls to the [Helpdesk] and then including
a general paragraph stating that ‘None of these
calls would have had an effect on the integrity
of the data on the system ...'."
If we scroll down, he says at the top there
"Presumably Dave will" -- sorry, no. If we
scroll up to the top of the page, sorry, he
says:
"Perhaps I should ask Fujitsu to provide
a similar type of statement in respect of
Marine Drive ... what do you think?”
Then if we scroll down to the bottom, near
the bottom of this email, it's a little
confusing as to who everything in this email
comes from, but he says:
"Fujitsu's responses thus far haven't really
helped answer the questions posed in each case,
their written responses have been brief to say
the least.
"My own opinion therefore is that PO Ltd
needs to cover off all questions relating to
office misbalancing and transaction details ...
and that Fujitsu should provide us with
a general statement for each case (as per the
statement above from Bill Mitchell) detailing
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calls estimate to the [Helpdesk]."
Did you have any concerns about using
a generic form of words in these cases, such as
the one that is at the top of this page?
A. I don't think we did use a generic form of
words. I think they were prepared to begin with
a generic, and then make it specific to the
events at Marine Drive.
Q._ So the suggestion at the top, if we could go to
‘the top, is that there was some general form of
words. And we may or may not, during the course
of this Inquiry, come to a number of statements
that look very similar in how they're
formulated, certain forms of words. Do you have
any recollection of general statements being
used in witness statements?
A. No. This may have been something that was
utilised in the prosecution's sphere, but they
were tailored and unique insofar as we were
dealing with civil litigation.
Q. Can we look at POL00072692, please. This is the
last document that I'll take you to myself, and
the last document before the break. This is the
attendance note of 7 April 2006 from
Stephen Dilley. It's a document that we have
169
audit data, enhanced ARQ?
A. I'm not an expert in that field. I knew there
were four lines of calls that a subpostmaster
could make to various help desks, et cetera, and
I knew that there was a data that only Fujitsu
had access to, but I didn't know the detail and
I couldn't distinguish one type of data from
another.
Q. And contractually I think it's your evidence
that essentially the Civil Litigation Team were
an afterthought in respect of --
A. Correct.
Q. -- the ability to obtain it?
A. Correct.
MR BLAKE: Thank you.
Sir, we do have some questions from
recognised legal representatives. Not a huge
amount, but, if you're content, I think this may
be the appropriate moment to take a 20-minute
break.
SIR WYN WILLIAMS: Twenty minutes would take us
to 3.50.
MR BLAKE: Sorry, 15-minute break, sorry.
SIR WYN WILLIAMS: Well, okay, 3.45.
I just want to give notice to everyone that
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seen before. It says:
"Before the Post Office joined the call,
Stephen Dilley and Tom Beezer had a telephone
conversation with lan Herbert. Agreeing that
[Post Office] ... had difficulty obtaining
information from Fujitsu and that the strategy
should be to identify key individuals at Fujitsu
who could provide the relevant information ..."
It then says:
"The [Post Office] joined the telephone
conversation and Tom Beezer outlined our
proposal to Mandy Talbot. Mandy broadly
agreed ...” et cetera.
Do you recall problems obtaining information
from Fujitsu?
A. AsImentioned earlier, prosecution was entitled
to 100 reports or analyses per year. We were
left in a situation where, if they hadn't
utilised that 100, we were entitled to request.
Anything over and above that, Fujitsu would
charge. And sometimes POL, I suspect, was not
prepared to bear that cost.
Q. Did you understand the difference in various
types of information that was available from
Fujitsu, such as ARQ data, audit trail, raw
170
just as in the case of Mr Dilley, I do find it
difficult to retain proper levels of
conversation (sic) after about 4.15, so those
questions need to be tailored with that in mind.
I can see you, Mr Blake. What's the
reaction amongst your fellow barristers?
MR BLAKE: A fair few smiles. They agree.
SIR WYN WILLIAMS: All right. Fine. So 15 minutes
then, between 3.45 and 3.50. Yes.
(3.32 pm)
(A short break)
(3.46 pm)
MR BLAKE: Thank you, sir, we have questions from
Ms Page and Mr Stein.
Questioned by MS PAGE
MS PAGE: Mrs Talbot, I act for a number of the
subpostmasters in this case, including
Mr Castleton. There would be little point in
putting documents to you and asking you who gave
you instructions in the Castleton case because
you won't tell, will you?
A. It's not that I won't tell, it's that I cannot
recall, after this period of time, and it was
a revolving selection of managers within Post
Office Limited.
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Well, somebody needed to approve the expenditure
of £321,000 in legal costs for the sake of
a precedent. Which department? Will you tell
us at least that, which department of POL could
have possibly justified that?
I cannot after this period of time, I'm sorry.
There was a clear advantage to your own
department, wasn't there, because by bankrupting
Mr Castleton, you could threaten other
subpostmasters who disputed Horizon shortfalls
and you could threaten them with the same fate,
couldn't you?
I didn't run a department, and it was an
advantage for Post Office Limited, not myself or
my colleagues.
But it was your job, wasn't it, to use the
precedent that you had achieved?
I don't personally ever recall using the case of
Castleton as a precedent.
Well, it was a very expensive precedent. It
must have been used sometimes?
I assume it was, by Post Office Limited and
departments in that.
Do you recall Mr Morgan gave an advice at the
end which was of use as a precedent for POL?
173
of spread over the pages of 33 and 34, this was.
you telling a group of ten people within POL
about the great news, the successful result in
the Castleton trial, and that the judgment had
entirely vindicated the Horizon System.
If we scroll down a little bit further, the
final paragraph of your email was:
"Mr Castleton appeared to be stunned by the
result and did not apply for leave to appeal
against the decision."
"Stunned". Why do you think you would have
mentioned that?
I wasn't present in court at the case involving
Mr Castleton, so this would have been based on
a report given to me by Bond Pearce.
And why did you feel that those ten people
needed to hear that Mr Castleton was "stunned"?
I was just recording the report as had been
provided to me by external agents.
The next point is:
"[He] ... did not apply for leave to appeal
against the decision."
That was a piece of good news, wasn't it?
Yes, because it meant, as far as Post Office
Limited was concerned, that that was the end of
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Excuse me, Mr Morgan gave an advice?
That's right.
Yes, I do recall that and I remember feeding
recommendations back to POL.
So at least that was of use to them, wasn't it?
Correct.
What about the cases of Mr Bajaj and Mr Bilkhu?
What did you instruct your external lawyers to
say to them about the Castleton case?
I don't recall instructing external agents on
Bajaj or Bilkhu. I suspect that Post Office
Limited would have sent those cases directly out
to our external agent.
Do you think they were authorised to refer to
the bankruptcy proceedings as well as just
relying on the judgment?
I have no idea.
I'm just going to refer you to one document, one
document only. It's part of the large document
POL00090437. And when we get there, if we could
just straddle pages 33 and 34, please, there's
an email there. We've looked at it in part
already. I'm just going to draw your attention
to one bit.
If we scroll down a little bit and we sort
174
the matter.
And he had been told that he would need to lodge
some £50,000 in order to appeal, hadn't he?
That I cannot recall. I believe that that may
have had something to do with --
Security for costs; yes?
Security for costs, that's correct.
Exactly. So this was good news, and it seems,
from the way that you've written this email,
that you expected your audience of ten, your
readership of ten, to be pleased to hear that he
was stunned, that he was completely overcome,
that he was unable to appeal and that was that.
I think they were more interested in the fact
that we had brought the case to a satisfactory
conclusion, as far as POL was concerned. That
last paragraph is just me reporting verbatim
from a report which I received from Bond Pearce.
Yes. You reported that he was overpowered,
utterly defeated, and that that was what POL
wanted, wasn't it?
No, that was not POL's objective.
It was part of a culture at POL?
Abs --
Those who stood up to the institution must be
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utterly overcome and defeated?
Absolutely not.
Your task was effectively, metaphorically, to
put Mr Castleton’s head on a spike. And you did
that, didn't you?
Absolutely not.
And it was somebody's idea, not yours, wasn't
it? Somebody in POL came up with that idea, did
they not?
No, This began as a small, relatively small,
deficiency case. It expanded out of all
proportion because of the size of the
counterclaim, and then became a virtual and then
actual test case due to the allegation that
there were substantial defects with the Horizon
System.
Do you still maintain that this case was about
the counterclaim by this point?
It was about the counterclaim up until the time
the counterclaim was reduced to the level of
about £11,000 or so. Thereafter, it was indeed
about the desire on the part of POL to have
a substantial judgment dealing with allegations
about the Horizon System.
That's what you delivered for them, wasn't it?
177
where you got this direction from. Is it your
evidence that you simply can't remember who told
you what the POL line was? Is that actually
your evidence?
The line would have come from POL as an
organisation. There were many different
managers in that organisation, and I was given
instructions by many people during the course of
litigation. Can I put my hand on my heart and
come up with a name of a person? I'm afraid
I can't. I wish I could, for the subpostmasters
who you represent.
Okay. So no one single name comes to your
recollection?
No.
Not one?
I'm sorry.
Okay. If! can take you to your statement,
please, which you should have there.
Yes.
It's WITNO8500100. If we can have on screen
paragraph 7, which is page 2. If you can scroll
down to paragraph 7, I'll be very grateful.
Right.
Now, here we have you saying that:
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A. Yes.
MS PAGE: Thank you.
‘SIR WYN WILLIAMS: Mr Stein?
Questioned by MR STEIN
MR STEIN: Mrs Talbot, my name is Sam Stein,
I represent a very large number of
subpostmasters and mistresses.
You've mentioned in your evidence, and
I just read at a little bit of what you were
saying this morning, you said, I think at about
11.30, 11.35, you believed that the "Post Office
felt the need to demonstrate that it would take
a firm line with any ... challenges to Horizon".
Then you've answered a number of questions
from Mr Blake, and then, more recently, on the
question of whether you have any evidence that
you can tell us about, about where that
direction came from, that firm line.
Again, you said this earlier: no idea where
that direction would have come from.
Now, Mrs Talbot, you don't come across, if
I may say so, as someone that seems to be having
any problems with your memory. So the large
number of people that I represent are finding it
very hard to believe that you cannot recall
178
"By 2004 I was the Team Leader of the Postal
Litigation team within the Civil Litigation
Department. At no time did the team work
predominantly for the Post Office Ltd ... or on
cases involving Sub Post Masters, that was
a small proportion of the work."
Then you go on to say in the next sentence
that:
"... the Postal Litigation team ceased to
exist and was absorbed into the Dispute
Resolution Department which was the new name of
the Civil Litigation Department."
Now let's concentrate on the next couple of
sentences:
“There was no formal structure for upward
report within the Department although my line
managers operated an open-door policy. We were
never provided with guidance on what issues
should be reported."
Okay. So let's see if you can help us
understand the way this worked.
A. Sure.
Q. You're saying clearly in your statement that
there was no formal structure reporting upwards?
A. Correct.
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Right. But you're also saying in your evidence
that there was a structure for you getting the
line or the policy from POL in relation to
subpostmasters. You said repeatedly, as you did
to me a few minutes ago, that POL made it clear
what their attitude was toward issues with the
Horizon System. So are you saying in your
statement no upwards policy or guidance system
but there certainly was a downwards one?
My paragraph 7 describes the position purely
within the Civil Litigation Department. There
was neither a formal upwards escalation for
seeking guidance, neither was there a downwards
sequence of guidance from the solicitor down to
caseworkers.
What you're describing I believe is on the
Post Office Limited side of affairs, and during
the duration of the Castleton litigation, the
identity of the parties that you've seen in the
correspondence to whom I was reporting
backwards, in effect developed. Day 1,
Castleton legislation, there was merely
Ms Woodward from the Error Resolution Team at
Chesterfield.
Isee. Well, let's then turn to the last part
181
Right. So you are saying very clearly none of
those individuals provided you the POL line; is
that right?
Well, they couldn't because they were members of
the Civil Litigation Department.
Were they your managers?
Each and every one of them was my manager.
Right.
Sequentially.
Right. So, these individuals, which were your
managers, sequentially, over the period of time
when you were dealing with litigation, none of
those provided you with the POL line you've been
asked many questions about?
No.
So it didn't come through them?
No.
And you remember very clearly it didn't come
through them?
They were my colleagues who I worked with on
a daily basis.
Do you remember, as clearly as the rest of your
apparent -- the rest of your evidence, that this
POL line didn't come through them? Is that what
you're saying?
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of that paragraph, paragraph 7. Page 3 of your
statement. Let's go through the people that we
have here. See if this helps you.
So we've reached the end of the sentence:
"We were never provided with guidance on
what issues should be reported."
Then you go on to say:
"My first line manager in the Civil
Litigation Department was Joe Ashton ..."
Okay, let's just go through these people and
see if you can help.
Sure.
Did you get the steer about the Post Office and
its line towards people doubting the Horizon
System through your line manager, first of all
Joe Ashton?
No.
Right. Clare Wardle, same question.
No.
No?
No.
Right. Biddy Wyles?
No.
Right? Rebekah Mantle?
No.
182
I genuinely do not believe it came from them.
Right. So, eliminating those, as far as we can,
it's come from some other source; is that
correct?
That would be logical, yes.
Yes, okay.
Now, can I take you then please to how
things developed in relation to 2010. I'll take
you to the document which is the Rod Ismay
report, it's been called generally a whitewash
report.
That's POL00026572. Very grateful. If we
can just enlarge the top. Thank you.
Now you described yourself in your evidence
as being a conduit. Our understanding of what
you're trying to say there is you're a conduit
for the wishes of the Post Office. Yes?
Correct.
I assume you're not trying to portray yourself
as some sort of evil robot?
Absolutely not.
No, okay. So you're a conduit for the
Post Office's intentions and wishes in relation
to the way that matters are dealt with regarding
Horizon. Is that what you're trying to say?
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A. I think what I said was by 2010 I was performing
some conduit actions in respect of information
about the Misra case, and relaying that back to
Mike Granville and Rod Ismay.
Q. Okay. Let's have a look at the heading of this
particular part of what becomes the
Ismay report. Now, obviously under the word
"Confidential" it's got that it's going to
Dave Smith, managing director. It's from
Rod Ismay. And then the other people that are
referred to here.
Now we see yourself referred to:
"Mandy Talbot, Principal Lawyer (Civil)"
Yes?
Mm-hm.
Was that a title you gave yourself?
No, it was a title that emerged.
Yes, because it's "Mandy Talbot, Principal
Lawyer (Civil)", which is distinguishing itself
from "Rob Wilson, Head of Criminal Law"?
p>po>
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Yes.
Q. So it appears, so far as we can tell in this
document, that you are being portrayed as the
principal lawyer in the civil department?
A. That is incorrect. That is incorrect.
185
to as "Mandy Talbot, Principal Lawyer" without
the "Civil" in brackets in some internal
correspondence. In the same way that Royal Mail
Group at one time became Consignia, it was quite
‘open to changing titles.
Q. Mrs Talbot, you've made reference a couple of
times in your evidence to the limitations on the
disclosed material you've seen. You've
commented on it being partial. You've commented
on the fact that if any you had access to your
own files, electronic files and electronic data.
Mrs Talbot, are you trying to say that somewhere
within all this missing material there might be
a document that would portray you in a more
sympathetic light? Is that what you're trying
to say?
A. No, I think the documentation that has been
disclosed portrays me in an accurate light.
MR STEIN: Well, Mrs Talbot, there I think my
clients would agree.
Thank you.
Questioned by THE CHAIR
SIR WYN WILLIAMS: Mrs Talbot, when you used the
word "partial" in relation to disclosure, do
I understand that to mean incomplete as opposed
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Q. Your boss at this time, was that --
A. That --
Q. Rebekah --
A. Rebekah Mantle at this time, yes.
Q. She's not on this email, is she?
A. No.
Q. No. Can you help with why it is that she would
have been not referred to within this email
chain?
A. I'm afraid I can't.
Q. Because the report that follows the Ismay report
is a report that looks at the question of
whether there should be a review or.
investigation into the Horizon System. Why
isn't your boss involved in that?
A. I didn't create the report. I cannot give you
any information about the distribution list.
Q. You see, this suggests, as does other evidence
that you've gone through with Mr Blake, who
asked you questions first of all, that in fact
you're taking a principal lawyer role in
relation to Horizon errors, issues. It's
correct, isn't it?
A. No, it's not. That is merely a title that was
attached to my name. You will see me referred
186
to selectively left out?
A. I think I used the word "partial" only in
respect of the initial report created by
Mr Coyne.
SIR WYN WILLIAMS: Well, I may have misunderstood
that so let me be clear about it. Let me try
and get to it in this way. When you either
sought instructions about a course of action
where you felt the need to seek instructions
either from your line managers or from some
other department within the Post Office, did you
generally seek those instructions in writing or
orally?
A. It would have been a combination of both.
‘SIR WYN WILLIAMS: Well, that I'm prepared to
consider to be quite likely, at the very least.
So one can take it that in respect of some of
the things you've been asked about, where you've
been unable to identify personnel, there ought
to be at least some written exchanges between
you and that person about whatever it was that
you were then seeking instructions and receiving
instructions?
A. Undoubtedly. That's correct.
SIR WYN WILLIAMS: = And so far as you are concerned
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at least, you haven't been shown any of that
documentation? Do I understand you correctly on
that?
A. Thatis correct, though I did have to assimilate
a large amount of material on Tuesday of last
week. But to the best of my knowledge, no.
SIR WYN WILLIAMS: So that, for example -- and I'm
just using this as an example -- when the
strategy in Mr Castleton's case was being
discussed between Mr Dilley and you, can I take
it that, at least on occasions, you would have
escalated what was being discussed either to
your line managers or to some other department
before giving Mr Dilley an answer --
A. Absolutely.
SIR WYN WILLIAMS: -- as to the strategy to be
followed?
A. Absolutely. Both internally up to -- up the
line within civil litigation, and across to POL,
the business.
SIR WYN WILLIAMS: Yes, and just so that -- because
as you know, I am enquiring, so I'd like, if
I could, to understand who it was that would
have been giving you instructions in the sense
of knowing who that person was. All right?
189
have sought instructions from, I'd be grateful
if you'd name them.
A. I sought assistance from a lot of departments
like Security; information from Fujitsu.
SIR WYN WILLIAMS: Can I just stop you there. When
you say you sought information from Fujitsu, did
you do that directly in the sense that you had
a contact in Fujitsu that you could contact
directly, or did you have to go through some
other process?
A. There were some people eventually, as the
litigation progressed, but initially an awful
lot of that material was sought by Mr Stephen
Dilley as a consequence of his letter addressed
to Fujitsu; and then people started responding
to that, sometimes copying me in to those
responses, ultimately, the material being sent
to Stephen. I really wish I could pin it down
to a department or even some persons.
Undoubtedly, Dave Smith was one of the most
senior people within POL who was fairly
regularly copied in to the emails. Indeed, he
is often first on the list on a number of those
early emails. And I think he was possibly
managing director of one of the POL departments
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So I understand that you've said you can't
remember, and I'm not going to probe that any
further, but can you at least say, apart from
your line managers, what other departments might
you have sought instructions from? In other
words, commercial, security? I'm just naming
them at random, but can you tell me the
likelihood of the departments you would have
sought instructions from?
A. The answer I can give categorically is the Error
Resolution Team at Chesterfield.
SIR WYN WILLIAMS: Right, so that's a department
that I might want to investigate. That's
number 1. Number 2, if any?
A. That is the one I can be absolutely certain
about, because they were the parties that sent
it out for litigation in the first place.
SIR WYN WILLIAMS: Yes, but don't worry about being
certain about it. In an Inquiry, you might say,
"Well, I think I might have done this", and then
it's up to me to decide if I want to follow it
up. Do you see what I mean?
A. Indeed.
SIR WYN WILLIAMS: So if there are other departments
that you think it at least likely that you may
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at the time.
SIR WYN WILLIAMS: Well, unless I'm wrong about it,
there were two Mr David Smiths in Post Office in
the relevant period.
A. David X Smith -- oh, pardon, sir. David X Smith
is -
SIR WYN WILLIAMS: No, one of them was certainly
yes. I follow. All right. Thank you very
much.
THE WITNESS: § Thank you, sir.
SIR WYN WILLIAMS: So all that remains is for me to
thank you for making a witness statement and for
coming to the Inquiry to answer a good many
questions during the course of the day.
THE WITNESS: Thank you, sir.
MR BLAKE: Thank you very much, sir. 10.00
tomorrow.
SIR WYN WILLIAMS: Yes, fine. Thank you.
(4.14 pm)
(The hearing adjourned until 10.00 am the following
day)
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INDEX
MANDY TALBOT (sworn) .
Questioned by MR BLAKE ....
Questioned by MS PAGE ...
Questioned by MR STEIN ..
Questioned by THE CHAIR ...
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MR BLAKE: [18] 1/3
116 1/11 47/15 47/22
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13/6 14/16 17/7 20/6
20/12 25/6 25/10
25/23 26/1 30/8 120/5
121/1 180/1
2005 [20] 3/9 13/6
34/18 36/20 43/17
43/17 45/19 46/7
50/15 99/24 121/14
123/4 126/15 145/14
145/16 150/12 150/23
151/2 152/6 152/11
2005/2006 [2] 127/5
162/2
2006 [27] 13/6 47/15
48/17 49/20 50/24
51/21 52/22 53/13
56/23 58/14 61/3
62/11 64/4 64/24
65/11 65/12 77/15
78/3 79/11 83/16
95/18 99/23 126/15
127/5 162/2 162/23
169/24
2007 [7] 13/6 87/7
108/24 126/15 132/17]
134/5 135/19
2008 [4] 13/7 108/24
136/22 141/7
2009 [6] 13/7 79/25
88/17 96/10 106/1
111/17
2010 [35] 13/7 13/10
13/15 80/7 92/25 94/9}
95/24 96/8 96/9 96/10)
103/12 104/10 104/12
104/14 105/2 106/22
108/9 111/15 111/23
111/25 115/20 115/21
116/3 135/19 143/17
145/13 148/13 150/3
152/10 155/1 157/22
159/6 159/7 184/8
185/1
2011 [2] 5/16 12/24
2014 [3] 6/1 161/13
161/22
2020 [1] 106/2
2023 [2] 1/1 1/18
21 [2] 90/10 90/12
21 August 2006 [4]
56/23
223,000 [1] 54/12
23 years [1] 121/2
24 [1] 3/3
24 February [1]
48/17
25 [4] 145/20
25 February [1]
145/19
25 July 2006 [1]
58/14
250,000 [6] 36/17
39/21 45/19 54/17
56/8 86/10
26 February [2]
146/18 155/18
26 July [1] 30/8
27 [2] 12/1 144/20
27,000 [2] 37/5 54/15
28 September 2023
[1] 1/4
29 November [1]
65/15
3
3.27 pm [1] 157/6
3.32 [1] 172/10
3.45 [2] 171/24 172/9
3.46 [1] 172/12
3.50 [2] 171/22 172/9
34 May [1] 1/17
31 October [1] 23/4
321,000 [1] 173/2
33 [3] 132/14 174/21
175/1
34 [2] 174/21 175/1
36 [1] 1/21
4
4 August [1] 120/5
4.10 pm [1] 145/21
4.14 [1] 192/19
4.15 [1] 172/3
43 [1] 90/10
44 [2] 90/10 91/8
49 [1] 33/12
5
5 December [1] 78/3
5 September [1]
61/10
5 September 2006 [2]I
61/3 65/12
50,000 [1] 176/3
500,000 [1] 86/9
54 [1] 95/6
62 [1] 12/2
63 [4] 21/19 131/13
131/15 131/17
65 [2] 56/20 56/22
7
7 November 2005 [1]
43/17
8 March [1] 157/5
8 October [1] 159/6
9
9 December 2010 [1]
108/9
9 November [1]
62/11
9 November 2006 [1]
65/11
90 [1] 21/18
ability [5] 19/4
123/20 124/1 163/1
171/13
able [21] 4/4 16/14
17/5 42/23 45/6 46/15)
62/22 64/11 64/13
73/11 96/12 97/2
102/1 106/20 126/1
126/24 133/16 152/4
157/23 166/21 167/19)
about [148] 2/17 4/7
5/7 10/4 12/5 12/19
13/2 14/9 16/7 16/17
16/20 25/5 25/24 27/1
27/8 27/21 30/18
31/12 37/21 39/20
40/7 40/14 41/15 43/2
43/6 44/24 45/1 46/25
48/24 50/22 51/5
59/11 59/24 60/14
62/14 64/2 64/3 64/7
64/13 64/16 65/3
65/22 68/7 68/9 69/1
70/14 71/7 71/15 73/6I
74/9 76/15 77/21 78/5I
78/18 78/21 79/15
79/17 79/18 81/17
89/9 93/17 93/19
93/22 93/23 94/6
95/18 96/19 102/5
102/11 102/12 102/16)
104/19 106/14 106/21
108/25 110/12 111/3
115/17 116/3 116/4
116/5 116/6 116/13
116/14 117/2 119/6
120/16 120/19 122/16)
122/18 122/19 124/6
124/16 126/20 126/22)
128/4 128/10 128/12
131/20 131/23 133/4
134/21 135/1 136/18
137/16 137/16 137/18)
137/18 140/2 142/5
142/6 144/2 144/10
148/14 148/15 148/17)
150/4 150/17 158/9
158/13 160/1 160/19
162/22 169/2 172/3
(TAIT 174/19 175/3
177/17 177/19 177/21
177/22 177/24 178/10)
178/17 178/17 182/13)
183/14 185/3 186/17
188/6 188/8 188/18
188/21 190/16 190/18)
190/19 192/2
above [14] 33/15
34/24 66/21 70/15
93/12 105/17 107/3
133/9 138/15 147/3
147/4 149/11 168/25
170/20
Abs [1] 176/24
absolutely [16] 28/20
29/22 41/23 47/14
48/14 99/22 104/11
(50) MR BLAKE: - absolutely
A
absolutely... [9]
109/22 124/2 147/14
177/12 17716 184/21
189/15 189/18 190/15}
absorbed [1] 180/10
abuse [1] 153/20
accept [3] 66/24 68/6
69/3
acceptance [1] 77/16
accepted [4] 16/1
51/12 76/17 88/2
accepting [2] 6/22
47/11
accepts [1] 138/2
access [6] 21/18
52/19 119/13 120/10
171/6 187/10
accompanied [1]
159/24
account [5] 31/21
44/7 75/3 81/4 156/13
accountancy [2] 51/2!
67/11
accountants [2]
64/25 75/14
accounting [4] 75/1
133/21 157/9 166/6
accounts [4] 31/3
31/10 67/21 67/22
accurate [3] 27/3
27/5 187/18
accused [1] 145/10
accused's [1] 145/8
achieve [3] 19/4
96/12 162/11
achieved [2] 88/25
173/17
acknowledging [1]
164/11
acquire [2] 78/20
123/16
acquired [1] 78/22
across [6] 106/19
161/4 161/25 166/11
178/21 189/19
act [4] 5/9 7/4 15/20
172/16
acted [1] 69/21
acting [7] 35/25
38/15 62/3 90/17 91/1
131/4 131/10
action [11] 3/7 5/15
7/5 13/4 67/11 101/10)
128/14 129/6 152/22
160/20 188/8
actions [11] 5/11 7/5
9/6 9/15 19/7 82/10
82/11 82/13 88/5
106/21 185/2
activities [1] 147/1
actual [9] 14/4 19/14
55/17 65/13 67/18
68/1 112/17 140/16
177/14
actually [13] 16/12
17/21 20/25 40/6
56/11 80/10 86/9
97/18 138/19 151/7
151/17 166/11 179/3
add [1] 2/4
additional [10] 2/8
13/11 20/3 61/23
84/21 88/10 104/23
111/19 119/22 134/13)
additions [1] 71/3
address [4] 86/21
95/4 162/12 162/17
addressed [4]
136/13 155/8 167/5
191/14
addressees [1] 54/1
addresses [1] 58/9
addressing [1] 84/11
adduce [2] 28/7
103/23
adducing [2] 32/5
103/14
adequacy [3] 38/24
39/3 40/7
adjourned [2] 163/2
192/20
Adjournment [1]
107/18
admit [2] 27/2 66/18
admitted [1] 78/9
adopt [1] 52/3
adopted [8] 12/12
73/16 73/17 74/5
76/25 77/1 77/9 88/1
advantage [3] 52/19
173/7 173/14
advice [12] 16/19
26/18 30/2 40/14
56/19 68/25 74/2
134/25 164/10 165/3
173/24 174/1
advise [2] 16/22
31/19
advised [3] 22/12
23/11 25/6
advisers [1] 60/5
affairs [1] 181/17
affect [1] 167/14
affected [1] 34/7
affects [1] 2/10
afraid [8] 62/21 154/6
155/6 156/24 157/16
164/1 179/10 186/10
after [35] 2/13 4/7 6/3}
7/7 8/3 8/21 11/24
23/17 25/9 25/16
29/12 32/19 35/14
42/9 52/18 62/20 63/4
65/16 66/6 69/8 76/1
87/7 87/12 87/23
88/23 103/10 111/21
116/5 158/18 164/2
164/6 165/10 172/3
172/23 173/6
afternoon [3] 53/17
107/20 107/21
afterthought [1]
171/11
again [24] 22/25
24/12 38/20 40/16
55/10 56/25 64/2
64/17 65/18 70/3
71/25 93/21 97/12
100/14 101/24 104/6
122/1 131/12 133/1
143/14 154/21 157/13
160/21 178/19
against [24] 7/5 9/6
9/16 17/8 33/16 33/19
35/7 36/18 39/1 51/8
51/9 64/9 64/10 77/12
82/11 100/14 115/24
118/5 120/25 134/15
154/18 162/18 175/10
175/22
agent [1] 174/13
agents [21] 2/19 3/13
12/11 16/17 17/22
18/6 18/13 18/22
18/24 19/3 32/4 35/5
44/14 91/12 100/1
101/22 112/13 112/14]
112/25 174/10 175/19}
ago [6] 3/20 26/16
41/14 52/14 64/24
181/5
agree [5] 2/23 72/24
136/4 172/7 187/20
agreed [5] 134/6
134/10 147/1 167/15
170/13
agreeing [3] 135/4
135/8 170/4
agreement [6] 26/21
28/17 29/4 84/17
86/15 149/11
agreements [1]
18/21
AH [2] 147/8 147/11
aimed [1] 54/5
Alan [2] 105/10
105/11
albeit [1] 28/9
all [80] 6/24 8/8 9/17
15/12 16/2 16/10 17/4
23/1 26/3 27/21 28/3
28/16 30/10 42/1 42/5}
46/11 49/25 59/18
60/1 61/17 67/2 67/15
67/16 70/1 78/14 80/2
80/10 80/22 81/7
82/17 85/9 85/16
86/15 95/1 96/1 98/20)
103/14 103/17 106/19}
107/1 108/10 108/11
110/16 111/6 111/14
114/14 116/8 117/9
122/18 122/22 122/24
124/11 124/13 125/15
125/18 127/3 129/4
130/10 132/19 137/16
137/22 140/7 140/17
146/1 146/13 146/24
148/4 156/11 158/9
158/12 159/2 168/21
172/18 177/11 182/15
186/20 187/13 189/25}
192/8 192/11
allegation [1] 177/14
allegations [14]
50/22 64/12 64/16
65/22 71/5 71/7 72/22,
76/15 77/21 102/10
114/4 132/20 142/6
177/23
allege [1] 100/5
alleged [3] 3/6 46/11
154/8
allocation [1] 122/14
alluded [2] 109/20
166/23
alone [2] 17/2 161/10
along [2] 103/25
106/22
already [19] 21/4
57/13 57/21 62/18
71/12 79/1 90/19
91/25 106/23 121/17
126/5 129/23 131/15
141/4 142/1 150/9
160/16 164/24 174/23}
also [24] 2/20 5/11
5/12 11/17 14/8 15/12,
17/12 28/8 41/4 41/13}
45/20 46/24 71/5
86/10 100/7 107/2
117/25 134/14 139/17
145/24 154/10 163/7
165/24 181/1
alternative [1] 71/11
alternatively [2]
22/19 104/21
although [16] 7/7 8/6
16/25 23/13 80/4
81/24 86/8 88/21
100/9 106/18 139/18
144/22 147/25 151/2
160/18 180/16
always [3] 125/11
153/5 153/7
am [20] 1/2 4/5 20/4
27/17 31/19 31/20
43/22 47/24 57/25
78/10 85/19 86/9
86/20 93/7 93/24
100/11 155/18 166/15)
189/22 192/20
Amar [1] 105/10
ambush [1] 163/8
amended [2] 46/18
56/15
amendments [2] 2/6
3/18
amongst [2] 141/23
172/16
amount [12] 12/18
45/20 54/14 64/10
64/14 137/14 138/11
138/12 138/15 145/9
171/18 189/5
analyse [1] 167/11
analyses [1] 170/17
analysing [2] 110/19
167/17
analysis [1] 110/24
Andrew [5] 136/24
137/1 137/2 144/25
145/22
Andrew Winn [3]
136/24 137/1 137/2
Andrew/Jason [1]
145/22
Andy [10] 94/7
127/14 139/2 145/1
145/1 145/6 146/18
147/11 147/18 148/6
anecdotally [1] 11/7
annual [1] 137/5
anomalies [1] 49/9
another [12] 83/19
95/16 99/7 100/14
104/7 112/2 127/1
129/24 144/16 156/7
164/5 171/8
answer [10] 58/17
58/21 62/8 65/19
72/24 163/21 168/17
189/14 190/10 192/13}
answered [1] 178/14
answers [1] 21/22
anticipate [1] 93/17
anxious [2] 31/22
32/12
any [102] 3/22 3/23
9/20 10/3 10/19 17/6
21/10 25/4 36/16 37/7I
37/10 45/9 46/10
46/15 49/8 49/12
49/25 51/12 52/24
55/2 57/11 58/19
60/16 60/18 63/12
63/15 67/1 69/24
70/18 71/9 71/14 77/8I
82/1 83/14 84/10
84/13 86/4 86/9 90/5
90/8 91/14 92/2 94/5
94/5 94/16 96/5
101/21 101/21 102/21
102/23 104/1 105/16
105/17 106/12 107/2
107/3 107/5 107/7
109/12 114/15 116/11
116/25 117/9 118/14
118/15 120/18 127/22!
132/22 133/18 136/17)
139/2 141/13 143/10
145/9 148/6 150/8
150/21 151/4 152/16
152/25 154/17 156/17)
158/5 159/12 159/17
159/20 161/22 162/9
163/6 164/23 166/6
166/18 169/2 169/15
(61) absolutely... - any
A
any... [8] 178/13
178/16 178/23 186/17)
187/10 189/1 190/2
190/14
anybody [6] 6/18 9/8
75/24 118/10 136/18
143/21
anyone [3] 9/16
139/2 166/11
anything [11] 13/1
19/2 48/6 60/3 81/16
101/8 109/3 120/16
129/20 159/15 170/20)
anywhere [1] 139/3
apart [3] 10/7 116/22
190/3
apparent [4] 75/1
82/4 143/19 183/23
apparently [3] 49/6
78/7 83/14
appeal [8] 154/15
154/16 154/16 155/2
175/9 175/21 176/3
176/13
appealing [1] 134/15
appear [1] 31/16
appearance [1]
102/5
appeared [2] 100/17
175/8
appears [5] 56/21
99/8 143/13 154/1
185/22
appendices [1] 80/6
apple [2] 45/23
101/25
apple-pie [2] 45/23
101/25
application [4] 90/18
90/23 91/2 92/11
apply [4] 96/15 119/7
175/9 175/21
applying [1] 130/19
appointed [4] 20/16
24/20 28/8 43/9
appraised [2] 92/17
151/13
appreciate [2] 41/23
109/8
appreciates [1]
163/12
apprised [1] 92/14
approach [13] 27/20
55/14 56/5 64/19
71/20 71/20 76/23
76/23 76/25 77/1 77/5
77/9 163/15
approached [1]
104/16
approaches [2] 54/4
104/24
appropriate [17] 3/11
33/21 47/16 56/10
63/10 71/14 82/18
91/2 95/2 100/24
107/11 125/18 130/4
130/10 135/12 160/2
171/19
approve [1] 173/1
approximately [2]
37/5 147/24
April [1] 169/24
April 2006 [1] 169/24
Architect [1] 157/4
are [94] 2/3 3/25 4/4
10/9 10/9 16/10 16/17)
18/1 18/15 21/19 22/2
26/17 27/2 27/4 27/12
27/13 29/1 29/5 38/10
42/23 43/20 49/3 49/8)
49/13 49/15 50/9
53/12 55/5 55/8 56/2
57/2 57/11 58/11
58/12 59/2 62/1 62/22
63/6 66/13 71/4 73/18
75/2 75/4 76/6 80/15
80/23 87/11 93/19
99/14 107/1 107/3
110/7 113/17 113/19
113/20 113/25 115/8
117/22 118/24 121/25)
123/8 128/13 128/18
128/22 129/4 135/2
139/5 140/12 140/19
140/22 141/13 144/23}
147/25 153/5 153/8
153/10 153/17 157/7
157/12 158/14 159/12)
161/5 161/13 164/9
166/16 178/24 181/7
183/1 184/24 185/10
185/23 187/12 188/25)
190/24
area [2] 58/6 85/7
aren't [1] 18/2
arena [2] 34/1 77/7
argue [1] 153/17
arguments [1] 93/9
arise [1] 30/17
arisen [1] 31/2
arising [2] 13/13
115/17
arithmetic [2] 58/16
102/1
arose [9] 33/2 66/20
66/22 66/24 67/7 67/8
67/14 157/24 158/1
around [4] 137/10
141/14 148/13 166/15)
ARQ [2] 170/25 171/1
arrange [2] 5/24
117/19
arranging [1] 135/6
arrears [1] 5/12
article [7] 111/16
111/17 123/4 134/21
145/11 146/8 146/12
articles [1] 4/15
as [244]
Ashton [6] 7/24 8/2
8/18 97/5 182/9
182/16
ask [7] 1/20 69/4
135/9 139/25 143/6
161/9 168/9
asked [42] 10/22
15/10 15/12 31/19
31/20 36/24 60/7
76/10 81/3 91/16
92/13 92/19 94/14
94/15 101/20 104/18
105/22 106/2 106/18
119/7 119/12 119/15
119/18 119/21 122/18I
129/25 134/20 136/3
136/11 136/14 140/2
140/6 145/6 147/23
158/6 158/16 159/2
160/25 164/25 183/14]
186/20 188/18
asking [6] 72/20 73/6
73/7 111/10 165/25
172/19
asks [2] 129/3
129/11
asserting [1] 131/4
assess [1] 162/8
assessed [1] 80/23
assessment [2]
54/21 82/17
asset [1] 55/3
assimilate [1] 189/4
assist [38] 4/4 5/13
6/14 19/3 30/20 38/9
42/23 53/3 62/12
62/21 62/22 63/15
69/24 70/2 90/20
95/10 97/2 104/3
104/25 105/19 120/6
136/3 139/19 145/17
148/7 150/8 152/16
155/25 157/17 157/23}
158/21 164/3 164/14
164/23 165/1 165/9
166/17 166/19
assistance [9] 21/1
42/21 99/5 135/5
139/21 143/4 165/25
166/22 191/3
assistant [1] 4/19
assists [1] 65/12
assume [12] 87/2
135/16 136/1 136/16
136/17 147/12 156/3
159/17 160/24 161/19]
173/22 184/19
assumed [1] 116/17
assuming [1] 90/19
assumption [1]
116/18
assurance [1] 11/2
assurances [1] 110/6I
assure [1] 133/16
assured [4] 13/17
25/10 25/25 76/8
assuring [1] 109/22
at [301]
at page 2 [1] 30/7
attach [3] 53/17
103/25 165/23
attached [4] 98/9
99/9 146/8 186/25
attaches [1] 145/11
attack [1] 133/8
attempt [2] 71/25
81/12
attendance [7] 46/7
48/16 90/1 147/15
162/20 164/5 169/24
attended [1] 157/15
attention [6] 42/8
89/22 102/21 114/19
141/8 174/23
attitude [2] 158/25
181/6
audience [1] 176/10
audit [2] 170/25
171/1
auditors [1] 135/8
August [8] 56/23
79/10 80/6 94/9
115/18 120/5 136/22
157/22
August 2008 [1]
136/22
author [1] 30/8
authorise [2] 111/2
117/18
authorised [2] 35/7
174/14
authority [2] 45/5
80/15
available [7] 15/14
16/9 28/3 31/15 59/15)
166/14 170/24
avoid [4] 33/24 34/5
40/15 69/2
awaiting [4] 87/11
114/6 115/3 116/7
aware [26] 2/11
16/10 17/7 19/23 20/4}
20/5 20/10 20/15
20/18 75/5 76/7 77/6
82/3 84/10 84/13
86/12 86/20 87/20
91/13 111/15 116/18
141/13 141/22 144/1
145/23 149/22
awareness [1]
119/24
away [6] 27/8 27/14
31/13 58/7 137/5
141/41
awful [3] 47/4 110/22
191/12
B
back [34] 12/4 14/25
28/1 30/6 33/7 35/15
36/8 38/6 42/2 65/9
77/4 77/18 79/1 97/3
107/6 107/14 108/7
4111/1 111/21 114/12
120/4 120/4 132/7
141/25 147/19 150/12)
152/11 156/18 164/22)
174/4 185/3
backwards [1]
181/21
bad [2] 23/2 128/17
Baines [9] 41/4 63/8
98/7 120/2 120/6
120/9 120/14 120/18
134/8
Bajaj [6] 105/10
122/25 123/3 124/5
174/7 174/11
balance [3] 16/15
69/12 167/14
balanced [1] 26/23
balances [1] 23/6
bandwagon [3]
109/8 109/17 111/7
bankrupt [5] 87/10
87/19 88/23 89/3 89/5
bankruptcy [5] 82/24
86/21 87/17 89/15
174/15
bankrupting [1]
173/8
Barjarge [1] 50/7
Barker [1] 70/13
barrister [7] 104/3
104/18 106/5 106/7
106/24 113/12 161/8
barristers [1] 172/6
based [9] 16/9 37/24
44/9 50/8 50/21 75/12)
95/21 129/12 175/14
Basically [1] 140/14
basing [1] 95/19
basis [10] 3/15 16/25
24/5 33/15 51/14
80/23 81/8 101/11
125/12 183/21
Bates [6] 12/18 12/20
77/7 77/10 77/13
105/11
bee'd [1] 145/1
BDO [14] 61/3 61/20
61/21 62/5 64/24 65/7
65/11 65/14 65/17
74/20 75/12 77/15
116/4 158/11
BDO's [1] 74/23
be [179] 2/15 3/17
5/7 7/17 9/7 11/15
11/23 16/13 16/14
17/5 18/7 21/20 23/4
24/24 25/4 26/23
27/20 28/12 28/22
28/23 29/20 31/23
32/13 33/3 33/15
34/14 36/6 36/13
36/18 38/8 38/20
40/12 41/16 42/20
43/14 43/21 46/1
46/12 47/16 50/9
(62) any... - be
B
be... [139] 50/11
50/14 52/23 54/3
54/13 54/20 54/23
56/2 58/16 58/22
59/11 59/16 60/13
64/11 64/14 64/17
65/6 65/20 66/3 66/21
67/13 67/15 67/18
68/2 68/10 68/23
70/18 73/24 76/13
78/7 79/6 79/6 81/1
81/9 81/10 81/21 82/3
84/8 86/7 86/16 92/14,
96/17 99/5 100/20
101/6 102/1 104/7
105/14 107/9 108/2
108/14 109/4 109/9
109/11 109/16 110/9
113/14 113/16 114/7
114/16 114/21 115/13)
116/24 117/17 117/19}
118/16 119/9 119/10
123/11 123/14 123/22)
125/14 125/21 126/24)
128/24 130/11 130/12)
132/4 133/3 133/16
133/22 133/22 134/24}
135/14 135/25 136/8
137/10 138/9 138/12
140/1 143/13 145/17
146/10 149/2 149/8
150/12 152/7 152/24
153/1 153/14 153/20
154/1 154/3 154/11
154/15 154/17 154/19)
154/22 155/1 156/23
157/23 159/10 162/3
162/15 163/11 163/21
164/25 166/25 167/19}
170/7 171/19 172/4
172/18 175/8 176/11
176/25 178/22 179/23)
180/19 182/6 184/5
186/13 187/13 188/6
188/16 188/20 189/16)
190/15 191/1
bear [2] 58/20 170/22
became [9] 4/23 5/16
5/21 30/21 104/12
106/15 123/10 177/13}
187/4
because [56] 3/19
3/25 9/12 18/1 18/3
25/25 34/7 35/18 36/3,
36/5 39/22 39/24
45/17 48/9 48/11 51/2
54/21 55/3 55/23
59/12 59/16 63/8
67/20 68/12 68/20
69/17 77/24 78/8
82/14 87/3 96/7 96/9
99/6 101/23 109/21
110/5 112/2 112/12
130/3 139/23 140/4
150/19 159/19 160/19)
161/7 163/9 163/22
172/20 173/8 175/24
177/12 183/4 185/18
186/11 189/21 190/16)
become [10] 64/20
68/13 76/7 77/6 77/10
92/10 112/10 116/10
160/12 160/13
becomes [2] 87/14
185/6
becoming [4] 51/3
55/17 110/2 142/20
bed [1] 83/9
been [154] 2/14 2/24
3/19 6/10 7/1 8/17
8/18 10/6 13/11 13/16)
14/20 15/6 16/10
17/18 19/19 19/23
20/10 20/17 20/25
24/9 24/18 25/13
25/19 26/17 28/25
29/8 31/14 32/4 32/6
34/4 36/23 37/10
37/11 37/13 37/18
38/14 39/23 39/25
43/8 43/12 45/18
45/21 45/24 46/19
46/22 49/21 51/13
51/19 56/8 56/15
57/21 59/22 60/17
60/17 62/13 63/16
63/19 64/22 65/17
67/25 68/21 69/18
71/14 72/5 72/8 72/13)
72/20 73/11 73/13
83/8 85/25 86/3 86/11
87/4 88/8 88/11 88/12
89/9 89/14 90/2 91/10)
91/13 92/11 92/20
95/9 96/12 98/15
100/15 101/11 102/2
104/19 105/9 106/1
106/20 107/6 107/7
108/16 110/1 110/5
114/4 114/5 115/2
115/4 115/16 116/14
116/18 120/10 120/14)
125/17 126/5 126/9
127/11 129/14 130/5
132/19 137/4 137/23
141/4 141/22 150/16
151/22 153/4 153/6
153/7 156/19 156/21
158/6 158/9 160/23
160/25 161/9 162/5
162/7 163/22 165/3
165/6 165/21 165/24
167/13 168/18 169/17)
173/21 175/14 175/18)
176/2 183/13 184/10
186/8 187/17 188/14
188/18 188/19 189/1
189/24
Beezer [5] 56/24
57/16 128/3 170/3
170/11
Beezer's [1] 57/23
before [36] 4/7 10/7
14/14 36/11 40/14
45/8 48/3 61/24 79/19
81/14 84/22 91/4
92/10 94/25 98/3
99/24 100/16 102/4
107/23 108/8 114/21
121/22 123/11 127/18}
130/5 131/19 138/18
139/2 155/2 156/24
162/13 165/11 169/23
170/1 170/2 189/14
began [4] 104/14
112/24 112/25 177/10}
begin [5] 6/8 14/13
100/23 115/14 169/6
beginning [5] 7/24
30/6 47/7 55/24
109/19
begins [1] 89/19
begun [2] 112/12
115/13
behalf [12] 61/5
90/18 104/4 104/17
129/20 131/5 148/6
151/25 152/13 161/6
162/9 162/16
behind [3] 73/1 73/7
81/15
being [73] 13/17
13/25 14/6 14/9 24/7
24/13 24/25 28/24
33/9 35/20 35/24 36/7
36/10 39/1 39/4 40/1
47/9 50/18 51/16
54/23 55/12 55/14
56/5 57/1 73/17 76/9
79/15 79/18 83/21
95/24 99/14 101/19
102/4 102/5 102/10
102/11 102/20 105/21
110/13 114/7 114/22
119/15 121/12 125/18
126/1 127/3 129/17
136/19 140/4 140/25
141/7 142/8 144/2
147/4 150/23 151/24
152/4 152/12 153/12
153/23 154/1 157/14
160/9 160/21 167/8
169/15 184/15 185/23}
187/9 189/9 189/12
190/18 191/17
belief [3] 2/1 26/19
156/16
believe [50] 2/3 4/6
7/15 9/4 13/12 17/17
18/7 18/8 24/5 24/9
25/9 29/10 38/13 41/1
41/1 46/8 46/13 49/23,
53/5 55/23 60/20
74/14 77/24 78/16
97/3 97/4 97/9 101/20
102/18 104/9 105/24
106/3 106/21 109/2
118/9 119/6 121/15
137/2 137/23 147/10
150/16 160/8 160/18
161/10 166/11 166/20
176/4 178/25 181/16
184/1
believed [6] 12/11
49/22 50/22 51/1 51/5)
178/11
believes [1] 48/25
below [8] 41/13
83/24 91/8 129/9
146/25 155/10 167/24}
167/25
beneficial [1] 81/9
benefit [4] 21/1 64/9
64/22 119/10
Bentley [2] 37/19
38/1
Bentley Jennison [1]
38/1
best [17] 2/1 6/20 9/1
16/8 19/4 19/14 26/18}
27/20 50/19 55/4
60/20 72/3 91/16
125/14 126/12 159/3
189/6
better [1] 126/1
between [16] 34/8
41/2 52/21 60/18 62/3)
69/21 73/15 75/21
84/17 85/8 110/17
160/10 167/9 172/9
188/20 189/10
beyond [1] 36/13
Biddy [10] 7/25 8/4
8/19 62/16 70/11
139/4 139/11 140/11
141/2 182/22
Bilkhu [2] 174/7
174/11
bill [3] 134/10 167/23
168/25
bit [10] 48/19 98/4
111/6 122/10 163/11
167/5 174/24 174/25
175/6 178/9
BLAKE [8] 1/10
47/20 69/15 95/2
172/5 178/15 186/19
193/4
blamed.pdf [1]
145/12
blaming [1] 15/5
blank [2] 37/16 38/22
block [1] 95/13
blue [2] 22/1 22/11
board [1] 7/16
Bond [19] 3/4 35/5
35/25 44/17 46/7 46/9)
56/24 57/6 84/17 85/8)
85/15 85/23 92/1
101/20 129/18 129/22,
131/5 175/15 176/18
boss [4] 26/10 26/12
186/1 186/15
both [14] 11/19 19/24I
30/18 73/24 74/1 74/3}
74/5 74/12 75/15
140/16 152/2 165/19
188/14 189/18
bothered [1] 161/21
bottom [42] 1/22
12/3 30/4 33/13 34/21
37/21 38/7 40/20
41/10 42/11 42/14
56/22 62/10 66/10
70/5 71/6 79/4 80/6
83/2 83/22 85/12
88/18 89/18 89/19
97/15 98/2 98/3 98/4
103/4 122/11 122/11
128/2 132/16 136/23
142/3 144/21 145/20
146/17 151/8 167/6
168/12 168/13
bought [1] 42/7
boxes [1] 113/19
brackets [1] 187/2
brains [1] 75/22
branch [9] 10/24
18/11 67/22 98/12
122/22 133/21 135/10)
138/7 138/19
branches [9] 102/2
133/16 137/8 137/12
137/20 138/2 139/7
139/15 140/18
Brander [1] 144/25
breach [1] 30/24
break [13] 14/14
25/18 47/17 47/18
47/25 107/24 162/13
162/14 165/11 169/23)
171/20 171/23 172/11
Brian [1] 167/23
Brian Pinder's [1]
167/23
brief [2] 147/1 168/18)
briefed [2] 159/18
159/19
briefly [3] 5/4 122/5
162/17
bring [3] 53/21 58/20
93/9
bringing [5] 50/7
82/10 88/4 108/15
162/10
brinkmanship [1]
162/25
Bristow [1] 108/25
broader [4] 49/13
55/5 79/6 92/18
broadly [4] 97/13
120/8 158/16 170/12
broke [1] 48/3
brought [8] 2/24
102/20 108/2 110/11
110/13 141/7 146/9
176/15
Brown [4] 78/6 78/7
(53) be... - Brown
B
c
Brown... [2] 78/16
105/11
bug [1] 10/19
bugs [1] 10/4
bullying [1] 85/19
bundle [1] 131/14
burden [1] 116/11
business [20] 3/12
36/8 39/5 39/9 40/5
81/10 103/13 111/1
112/8 114/11 118/9
124/3 125/24 132/4
137/11 152/4 160/10
162/9 165/7 189/20
busy [1] 163/14
but [146] 5/11 7/7
7/13 8/2 8/15 10/7
10/17 11/4 11/17 12/7)
13/14 13/23 14/6
15/13 16/1 20/3 22/3
23/1 24/10 24/13
25/22 27/18 28/8
28/17 29/20 30/19
32/6 34/9 35/12 36/12
36/16 37/17 40/2
40/10 41/23 44/14
45/6 46/14 47/18
48/12 49/1 51/2 52/14)
54/15 54/16 56/2
56/13 56/19 57/7
57/15 62/1 62/20
62/23 64/5 65/2 65/16)
66/1 66/23 68/1 69/11
69/14 69/22 69/24
70/17 72/19 72/24
76/8 77/1 77/9 79/6
81/6 83/8 89/5 90/24
91/12 93/7 94/15
97/16 98/23 103/8
108/6 108/7 110/16
110/20 111/18 112/13}
113/17 114/21 115/2
115/17 118/20 119/13}
119/18 119/21 123/14}
125/23 126/2 126/6
127/9 129/18 136/10
136/15 139/13 140/17)
141/1 143/3 143/14
144/24 145/25 146/14)
149/4 149/7 149/25
150/6 150/19 150/21
152/23 155/6 156/5
157/17 157/23 158/7
158/18 161/25 162/2
163/1 163/5 163/23
164/2 165/7 165/20
166/1 167/9 167/16
168/15 169/18 171/6
171/18 173/16 181/1
181/9 189/6 190/3
190/7 190/18 191/12
button [1] 67/17
Byfleet [4] 145/24
calculated [1] 138/9
call [16] 16/9 22/5
23/2 23/9 78/17 84/1
122/15 129/7 146/25
147/5 149/7 150/1
156/12 156/25 159/21
170/2
called [8] 39/17 78/6
84/18 93/5 122/21
145/6 149/5 184/10
Callendar [3] 106/13
106/16 106/16
calling [1] 21/21
calls [5] 122/18
168/1 168/3 169/1
171/3
Camberwell [1]
98/11
came [11] 42/23 58/1
60/2 74/2 82/2 125/4
130/23 161/4 177/8
178/18 184/1
Cameron [1] 4/10
can [168] 1/3 1/5
1/11 1/20 2/15 5/4
6/14 11/17 11/25
12/13 14/2 14/14
14/17 15/15 17/1 17/3
19/14 21/2 25/15
25/18 26/5 30/1 30/4
30/6 30/7 32/23 33/12
33/15 34/15 34/18
34/19 34/23 34/25
38/6 38/9 40/19 40/23)
41/10 42/10 43/16
46/5 48/15 48/18 53/2
53/12 53/24 56/17
58/20 60/23 62/9
62/12 63/5 64/5 65/9
65/18 66/5 66/9 67/13
67/15 70/15 70/19
72/24 74/19 78/2
78/25 83/1 83/17
86/21 87/15 88/15
90/9 90/20 92/22
95/10 97/3 97/11
97/18 99/23 103/3
103/4 104/1 104/3
104/16 105/2 105/7
105/16 105/21 107/2
107/14 108/7 109/10
111/20 113/16 113/21
114/14 117/13 119/25)
120/5 120/9 121/6
121/7 121/11 123/1
127/24 127/25 131/13)
131/15 132/14 133/13)
133/17 135/16 136/1
136/11 136/21 136/22)
138/15 138/18 139/3
141/20 141/25 142/2
144/19 144/20 145/19)
146/16 147/14 151/6
151/11 152/17 155/6
155/25 156/7 157/7
157/20 159/5 159/16
159/18 160/24 161/12
161/18 162/19 163/23
164/4 165/14 166/6
166/15 167/8 169/21
172/5 178/17 179/9
179/18 179/21 179/22
180/20 182/11 184/2
184/7 184/13 185/22
186/7 188/17 189/10
190/3 190/7 190/10
190/15 191/5
can't [40] 4/7 10/2
25/17 32/16 34/9 41/6
52/18 62/8 62/21 69/8
69/22 69/24 72/16
84/24 85/11 90/24
104/23 114/25 118/14
119/11 119/14 119/21
121/3 122/4 125/21
126/6 132/13 141/18
146/14 150/7 151/5
152/16 157/17 164/1
164/3 165/9 179/2
179/11 186/10 190/1
cannot [24] 11/4 14/3
16/13 32/19 33/11
42/9 61/25 63/4 74/15)
75/23 76/1 103/9
143/23 144/4 150/6
151/2 156/24 157/16
158/20 172/22 173/6
176/4 178/25 186/16
capable [3] 28/24
76/9 99/19
capacity [2] 84/3
123/18
Carl [4] 40/21 40/22
40/24 41/11
Carol [4] 38/10 38/16
42/3 42/11
carried [1] 18/17
carry [5] 107/5 125/8
126/11 148/25 156/19)
carrying [2] 153/18
154/2
case [230]
caseload [1] 94/22
cases [103] 3/4 3/5
3/12 5/4 5/6 5/12 5/15)
9/18 12/5 18/15 47/5
51/24 52/1 60/15 63/1
63/3 73/22 73/24 74/1
74/13 74/18 75/15
78/21 80/22 82/13
85/3 85/6 85/10 85/14
85/16 85/24 86/2
86/19 90/3 94/7 94/18
95/4 96/11 97/14 98/1
101/6 101/13 101/22
102/20 102/22 104/6
104/19 104/22 105/8
105/13 105/16 106/19}
107/1 107/3 107/6
107/9 108/14 108/16
110/2 110/11 110/19
113/8 113/25 114/3
114/5 114/16 115/2
115/8 115/15 115/25
116/7 117/21 118/23
120/7 123/10 124/13
124/25 125/5 129/8
129/17 129/22 130/20}
130/22 130/23 133/3
135/11 140/6 145/7
145/18 145/23 145/25
146/3 147/20 148/18
150/18 153/15 155/3
166/16 166/24 169/3
174/7 174/12 180/5
casework [2] 97/20
167/3
caseworkers [2]
8/14 181/15
cash [2] 67/22 75/3
cast [2] 12/22 13/8
Castleton [108]
27/24 34/18 35/7
35/14 36/21 37/6
37/19 39/1 39/20 44/4,
46/5 47/11 48/8 48/9
48/12 48/25 49/14
49/15 50/6 50/10
50/15 50/17 51/8 51/9)
53/19 55/21 58/2 61/4
62/14 63/18 64/2
64/10 66/14 66/17
68/11 69/5 72/1 72/5
73/3 73/13 75/20
76/14 77/12 77/20
78/4 78/16 83/7 84/2
84/23 84/24 86/3 87/8
88/3 88/24 89/4 89/5
89/23 89/23 91/25
94/18 100/23 101/16
105/9 106/3 106/9
113/20 114/22 116/5
117/4 119/1 121/11
121/13 122/9 122/14
124/5 125/18 128/5
128/23 129/24 130/4
131/11 131/21 132/10}
132/12 132/20 133/5
133/6 134/5 134/10
134/14 148/9 148/15
158/11 160/17 162/18}
163/7 166/20 172/18
172/20 173/9 173/19
174/9 175/4 175/8
175/14 175/17 181/18)
181/22
Castleton's [19] 6/9
37/23 44/8 52/4 55/3
58/14 58/19 81/4
82/23 83/21 83/24
84/2 88/7 92/17 93/25)
101/18 163/16 177/4
189/9
categorically [2]
34/15 190/10
Catherine [4] 7/12
97/7 164/8 164/20
Catherine Churchard
[1] 164/20
cause [7] 24/22 25/4
31/9 58/20 75/17
78/13 103/17
caused [3] 15/11
37/8 138/9
causing [2] 30/15
94/1
CC [2] 15/17 161/25
ceased [1] 180/9
cent [1] 100/21
Central [1] 95/21
certain [13] 29/11
42/12 45/2 58/1 63/22
100/21 108/1 121/10
130/10 140/17 169/14)
190/15 190/19
certainly [10] 22/23
34/16 46/14 70/11
70/20 80/24 112/13
163/20 181/9 192/7
certainty [1] 67/14
cetera [11] 80/21
90/1 93/11 131/19
134/9 135/11 160/3
163/14 164/13 170/13)
171/4
chain [11] 34/20 38/7
40/19 41/5 42/5 56/20
144/23 146/16 156/8
157/5 186/9
chains [1] 151/10
Chair [3] 74/10
187/22 193/10
chairman's [13] 5/13
142/11 142/23 143/1
143/3 143/5 143/6
143/12 143/16 143/18)
143/22 144/1 144/4
challenge [4] 39/11
40/13 123/20 153/8
challenged [9] 16/13
39/1 39/4 101/19
104/21 117/23 118/25)
123/14 124/15
challenges [10] 50/1
124/4 147/4 147/21
147/25 149/16 153/4
153/5 156/17 178/13
challenging [4]
100/18 100/20 123/9
166/25
Chambers [1] 58/3
chance [1] 126/1
change [1] 138/8
changes [1] 2/4
changing [1] 187/5
chap [1] 108/23
charge [2] 111/12
170/21
chased [1] 83/25
check [1] 84/2
cheque [1] 138/14
Cheryl [12] 34/22
(64) Brown... - Cheryl
Cc
Cheryl... [11] 35/1
35/2 35/3 35/17 44/13,
44/24 45/4 45/6 79/11
100/1 100/22
Chesterfield [5]
15/13 44/14 131/1
181/24 190/11
chose [3] 39/5 73/14
89/5
chosen [1] 62/24
chronologically [1]
97/13
Churchard [3] 7/13
97/7 164/20
circa [1] 54/14
circumstances [3]
33/22 59/14 105/14
City [1] 81/24
civil [72] 3/13 4/21
7/19 7/21 7/22 9/7
9/10 9/14 10/2 12/9
12/24 13/5 14/3 14/22
18/24 35/21 41/25
51/23 57/5 57/14
62/17 85/7 90/25
91/16 95/7 95/17 96/4
96/22 97/6 104/19
104/20 106/21 108/13
108/16 109/19 109/25
110/24 114/13 114/16}
116/22 117/5 117/10
118/6 118/7 118/19
120/25 135/21 136/5
136/10 139/18 145/18}
148/17 150/17 155/10)
155/15 160/20 162/8
162/10 165/3 166/24
169/20 171/10 180/2
180/12 181/11 182/8
183/5 185/13 185/19
185/24 187/2 189/19
claim [16] 33/16
33/19 37/4 39/3 44/17
45/6 45/11 45/17
45/22 49/14 50/8
50/11 54/14 87/25
122/13 129/12
claiming [2] 31/7
110/7
claims [6] 30/13
30/17 49/18 114/24
118/6 135/1
Claire [1] 164/8
Clare [8] 7/24 8/4
8/18 38/12 62/17
70/11 164/18 182/18
Clare Wardle [2]
164/18 182/18
class [4] 13/4 101/10
128/14 129/6
clear [7] 4/2 44/19
50/8 137/9 173/7
181/5 188/6
clearly [14] 22/2
23/23 23/25 24/21
37/6 56/2 58/11 67/5
152/22 153/18 180/23)
183/1 183/18 183/22
clerk [2] 98/11
104/16
Cleveleys [30] 2/21
14/13 23/22 39/16
40/16 43/3 43/6 45/13
46/2 47/12 48/5 48/12
59/6 59/10 65/25
68/15 68/25 71/13
71/18 71/21 71/25
73/16 75/10 102/15
116/4 117/3 120/13
148/10 148/14 158/10)
client [3] 36/18 85/15
90/8
clients [4] 112/23
118/8 133/16 187/20
close [2] 78/3 78/13
co [1] 129/15
co-ordination [1]
129/15
Cohen [1] 83/4
coincidence [1] 74/4
Cole [2] 134/9 165/25)
Colin [2] 2/21 26/6
collation [1] 166/10
colleagues [4] 10/1
44/23 173/15 183/20
collection [1] 121/19
Collins [4] 144/25
combination [1]
188/14
come [28] 11/11 12/8
24/14 36/8 49/16 50/5)
52/12 52/16 59/17
91/23 107/14 108/6
110/20 112/15 113/1
113/17 140/19 161/25)
166/10 169/12 178/20}
178/21 179/5 179/10
183/16 183/18 183/24)
184/3
comes [4] 79/21 81/5
168/15 179/13
coming [11] 32/15
51/25 52/13 52/16
52/25 53/3 53/5 53/10)
73/25 82/6 192/13
commence [1]
152/24
commenced [1]
90/19
comment [12] 23/10
24/8 32/16 45/4 73/11
73/13 115/1 119/11
134/17 139/7 140/6
167/11
commented [3]
24/10 187/9 187/9
commenting [3] 71/2
135/24 167/25
comments [5] 2/9
2/14 103/15 137/24
156/13
commercial [5]
38/14 83/4 84/19
110/16 190/6
commission [2]
126/21 130/13
commissioned [2]
126/16 126/18
common [2] 131/18
133/2
comms [7] 133/13
133/18 133/20 133/25I
134/1 139/2 139/13
communicate [3]
62/19 63/11 137/21
communicated [9]
33/7 59/19 61/16
74/16 121/20 124/11
137/10 141/15 141/23
communicating [1]
135/3
communication [10]
20/9 22/19 27/16
35/13 60/16 125/10
125/22 127/8 136/12
138/5
communications [4]
57/10 133/20 133/23
139/10
company [4] 5/25
30/11 52/15 142/16
compensate [1]
138/13
compensation [2]
96/15 162/8
[4] 3/11
complaint [4] 59/24
116/5 116/6 144/10
complaints [10]
93/17 93/19 93/22
110/12 116/14 117/5
117/5 122/19 127/22
144/1
complete [4] 109/9
110/10 127/17 149/18
completed [1] 166/3
completely [2]
132/19 176/12
compliance [1]
161/23
comply [1] 128/21
comprehensive [4]
59/20 59/22 60/1 60/3)
compromise [1]
49/15
compromised [3]
123/22 123/23 123/25)
computer [25] 15/11
15/19 16/3 16/8 22/4
23/20 30/9 30/14
30/22 31/7 31/13
31/15 31/22 32/13
32/25 33/3 37/11 44/6
74/25 75/5 75/11
75/16 111/16 124/23
166/5
Coms [1] 137/8
concede [1] 27/2
concentrate [1]
180/13
concern [5] 39/19
40/6 44/24 129/21
154/1
concerned [18]
16/17 39/23 43/7
45/20 45/23 74/7
74/12 78/1 101/2
115/16 124/5 126/18
126/20 148/4 163/5
175/25 176/16 188/25]
concerns [14] 2/16
12/4 13/13 19/11
35/18 65/1 71/15
102/11 102/16 120/19)
128/6 136/17 156/2
169/2
conclude [6] 44/5
63/5 77/25 114/14
120/9 136/11
concluded [6] 33/16
43/8 73/10 84/8 95/9
108/13
concludes [1] 31/14
conclusion [4] 38/5
72/3 114/17 176/16
conclusions [4]
24/12 74/24 149/13
149/14
conclusions/report
[1] 149/13
condition [2] 83/11
92/15
conducive [1] 3/2
conduct [4] 33/22
35/14 148/23 149/11
conducted [4] 18/20
90/16 149/3 153/13
conduit [10] 116/24
118/4 118/7 118/9
160/9 161/11 184/15
184/16 184/22 185/2
conference [9]
146/25 147/5 149/7
150/1 151/19 151/21
155/20 156/12 156/25}
confidence [3] 34/3
51/6 153/19
confident [2] 59/2
66/3
confidential [2]
50/12 185/8
confidentiality [3]
26/21 28/17 29/3
confirm [6] 46/15
58/25 138/15 156/13
156/16 157/7
confirmation [1]
139/3
conflicted [1] 48/23
confusing [1] 168/14
connection [2] 96/11
144/14
consent [2] 129/13
130/1
consequence [5]
78/15 84/23 99/17
152/24 191/14
consider [9] 58/22
59/16 59/19 59/21
77/8 77/19 86/2 90/21
188/16
consideration [5]
10/12 72/10 80/25
91/3 91/7
considerations [2]
81/3 81/6
considered [8] 21/21
77/3 81/10 82/19
90/14 91/10 91/15
113/14
considers [2] 26/22
52/23
Consignia [1] 187/4
consistent [5] 68/24
75/9 150/11 150/23
157/13
constantly [1] 109/22)
contact [8] 36/24
61/10 63/11 137/12
140/13 143/9 191/8
191/8
contacted [4] 19/19
30/17 105/25 165/24
contacting [1] 36/19
contacts [1] 126/14
contain [1] 128/13
contemporaneous
[4] 132/2
contend [1] 100/7
contended [1]
132/21
content [3] 10/9 84/1
171/18
contention [1]
103/16
contents [3] 2/23
27/2 57/23
context [1] 85/20
continuation [1]
124/2
continue [10] 31/4
32/21 53/23 72/5
72/21 94/24 152/25
153/20 154/7 154/8
continued [1] 31/5
continues [2] 46/1
157/4
continuing [2] 92/6
92/7
contract [7] 4/15
15/18 17/2 41/7
110/17 120/2 124/14
contracted [1] 7/6
contractor [1] 121/24
contracts [1] 36/16
contractually [2]
(65) Cheryl... - contractually
Cc
37/7 171/19
contrary [2] 31/25
67/3
contribute [2] 67/1
67/6
control [2] 131/4
134/23
conversation [9]
48/18 52/21 53/16
60/18 136/2 164/7
170/4 170/11 172/3
conversations [1]
151/4
conviction [2] 25/2
98/15
convictions [2]
154/12 154/23
convinced [1] 13/25
convincing [2] 64/15
65/21
cooperating [1]
155/13
coordinate [2]
101/12 129/20
coordinating [2]
125/5 127/4
copied [32] 11/18
13/22 34/23 35/2
35/12 35/17 35/24
36/3 36/5 36/10 36/13,
41/13 42/12 44/15
56/24 57/1 57/9
100/19 100/20 100/25}
101/11 121/10 144/22)
156/7 157/5 157/21
159/8 161/19 162/3
162/5 165/20 191/22
copies [3] 15/12
38/21 113/13
copy [6] 24/9 61/18
75/7 79/23 99/11
159/16
copying [2] 100/11
191/16
Core [1] 162/16
corporation [1] 9/3
correct [37] 1/16
1/18 1/19 2/5 4/20
4/22 5/2 5/3 5/18 7/20)
8/23 17/11 17/14
26/13 26/14 35/11
35/23 39/14 48/7
48/10 50/18 60/6
76/23 113/10 138/11
153/11 158/24 171/12)
171/14 174/6 176/7
180/25 184/4 184/18
186/23 188/24 189/4
correcting [1] 140/21
corrections [1] 10/8
correctly [5] 59/3
109/13 167/12 167/13}
189/2
contractually... [2]
correspondence [12]
11/18 57/20 65/16
65/17 129/1 139/20
142/13 143/8 144/18
146/13 181/20 187/3
corridor [2] 95/16
95/25
corridors [1] 95/15
cost [14] 3/15 39/21
40/12 49/2 49/13
53/17 80/17 88/12
89/15 98/22 109/11
111/3 113/22 170/22
costing [2] 79/15
7917
costs [26] 19/1 37/5
53/21 54/11 54/13
54/20 54/23 56/3
78/25 79/5 79/18
80/19 81/1 81/19
82/23 88/6 88/10
88/14 89/8 89/22
134/6 134/11 134/13
173/2 176/6 176/7
could [56] 2/25 14/16
16/4 18/23 21/20
22/14 38/18 44/25
47/19 51/13 61/5 61/7
63/25 67/17 68/2 73/4
78/21 82/12 85/12
88/14 89/8 89/11
91/23 97/15 100/2
101/4 105/15 122/10
123/11 124/23 126/11
137/4 137/23 138/17
145/7 148/7 154/10
154/19 154/22 162/8
163/3 163/6 165/18
166/11 166/25 169/9
170/8 171/4 173/4
173/9 173/11 174/20
179/11 189/23 191/8
191/18
couldn't [4] 26/2
171/7 173/12 183/4
counsel [12] 2/19
7/11 7/14 7/17 19/13
30/5 30/8 31/5 32/3
105/12 162/24 163/8
counsel's [4] 33/7
40/14 68/25 164/9
counter [1] 98/11
counterclaim [26]
15/17 15/21 35/20
36/17 39/2 39/21
40/11 45/18 46/17
48/10 50/21 51/11
51/15 54/16 54/18
56/7 56/12 56/15 68/8
68/10 130/8 133/7
177/13 177/18 177/19)
177/20
countering [1] 41/18
counters [3] 19/20
22/11 23/13
County [2] 5/8 7/4
couple [4] 106/7
128/1 180/13 187/6
13/23 33/22 77/13
86/12 101/15 107/15
169/11 179/8 188/8
192/14
courses [1] 5/10
court [32] 5/8 7/5
28/11 28/23 28/25
90/23 91/3 92/12
96/15 100/17 102/5
118/21 119/8 134/12
134/16 135/15 153/5
154/16 154/16 155/2
175/13
courts [2] 104/20
153/16
cover [2] 55/25
168/21
covering [1] 38/17
coversheet [1] 80/4
Coyne [13] 3/2 19/17
24/10 24/13 27/22
59/13 117/2 158/11
188/4
19/15
crashing [3] 22/18
49/16 50/5
create [2] 28/6
186/16
created [13] 20/25
24/4 27/15 27/16
51/18 59/13 75/8
84/22 114/7 115/18
127/13 129/14 188/3
creating [3] 28/9
41/15 120/11
creation [2] 60/2
126/22
creditor [2] 87/15
89/8
criminal [48] 8/11
8/14 8/15 9/7 82/21
95/4 95/8 95/15 95/20)
96/3 96/22 97/6 97/14
97/25 99/1 99/15
100/13 102/20 104/6
104/12 104/14 104/17
105/5 105/24 107/9
114/12 114/25 115/23}
116/18 116/21 116/25}
117/2 117/11 118/4
118/8 119/5 150/20
151/12 152/25 153/16
153/21 153/25 155/15}
161/4 161/17 162/4
162/6 185/20
criteria [1] 86/5
critical [1] 154/17
course [15] 3/18 9/22
136/25 137/15 155/10
16/24 21/1 26/25 28/6
29/18 32/5 87/8 90/18
117/16 117/17 118/18}
19/23 21/4 21/15 24/4
Coyne's [3] 2/13 2/17
criticised [2] 73/4
1
criticism [4] 13/16
74/6 154/15 155/1
criticisms [2] 105/18
107/4
crop [1] 121/25
Crown [5] 105/3
117/16 118/18 118/21
119/8
Croydon [1] 95/13
crucial [1] 124/2
Cruise [7] 2/12 2/16
14/17 14/18 17/15
20/10 26/8
Cruise's [2] 26/11
34/11
culture [1] 176/23
currently [5] 54/15
58/13 114/3 128/16
129/8
D
daily [2] 44/8 183/21
Daley [1] 144/25
damages [1] 17/5
damaging [1] 50/11
data [30] 3/4 3/11
25/8 49/8 59/15 59/18
76/11 110/25 122/18
123/9 123/16 123/18
123/21 124/12 124/15)
125/15 125/18 127/22}
145/9 153/3 166/4
167/8 167/11 167/16
168/4 170/25 171/1
1714/5 1714/7 187/11
date [9] 4/8 26/16
65/10 80/5 84/24
89/24 138/4 145/21
157/22
dated [4] 1/17 22/6
61/3 111/24
dates [1] 79/24
Dave [14] 40/21
40/25 41/11 42/11
108/21 111/11 147/17
147/18 151/9 152/20
157/3 168/6 185/9
191/20
Dave Hulbert [2]
40/21 40/25
Dave Smith [2] 185/9)
191/20
Dave's [1] 111/10
David [10] 3/9 108/25}
121/8 121/15 126/13
131/19 165/24 192/3
192/5 192/5
dawning [1] 34/13
day [5] 66/6 100/16
181/21 192/14 192/21
Day 1 [4] 181/21
days [8] 83/19 97/4
106/8 106/25 113/15
128/1 162/6 164/6
deal [8] 11/13 26/18
51/24 52/1 130/23
143/7 143/18 163/3
dealing [24] 7/19
8/11 11/19 28/13
36/25 43/22 53/7 57/6I
59/24 63/1 68/22
74/17 91/23 93/21
94/18 110/23 113/8
139/23 143/16 160/11
161/6 169/20 177/23
183/12
dealings [1] 11/12
deals [1] 142/12
dealt [16] 7/2 11/15
29/11 36/7 74/1 85/23}
102/25 104/20 121/1
129/17 137/3 137/4
137/23 141/4 158/22
184/24
Dear [3] 53/15 83/23
108/11
debt [24] 3/8 5/11 7/5
42/4 44/14 66/22
66/24 67/6 67/8 67/11
67/14 67/16 67/24
68/1 68/4 80/17 80/18)
80/19 80/25 81/2
91/24 94/8 96/13
100/2
December [17] 78/3
79/25 80/5 89/25
92/25 99/23 99/24
106/1 106/22 108/9
111/25 115/19 152/6
163/1 163/4 163/13
164/10
December 2005 [2]
99/24 152/6
December 2006 [1]
99/23
December 2009 [1]
106/1
December 2010 [1]
92/25
decide [1] 190/21
decided [1] 30/23
deciding [1] 91/4
decimated [1] 6/24
decision [14] 19/12
80/16 91/11 108/17
114/6 114/14 114/17
115/3 116/8 134/15
148/2 154/18 175/10
175/22
decision-making [1]
80/16
decisions [1] 91/14
declare [2] 66/25
87/19
declared [1] 87/10
decline [1] 93/18
declined [1] 15/25
default [3] 35/19 36/6
128/10
(66) contractually... - default
D
defeated [2] 176/20
17/1
defective [5] 23/23
23/25 24/21 31/8
31/17
defects [3] 10/5 33/2
177/115
defence [8] 37/23
39/22 44/9 46/17
130/7 145/8 153/15
153/17
defend [1] 89/1
defendant [4] 90/17
91/1 92/15 105/7
Defendant's [1]
90/14
Defendants [2] 153/8
154/19
defended [1] 31/6
defending [3] 40/13
132/19 135/1
deficiencies [1] 31/2
deficiency [11] 50/20
87/4 87/6 91/24 94/7
94/21 110/2 114/15
121/19 150/18 177/11
defined [4] 158/17
definitely [1] 140/17
delivered [1] 177/25
demonstrate [4]
49/24 64/11 67/23
178/12
Denise [1] 43/24
department [34] 4/21
5/2 5/22 8/15 51/23
82/21 87/5 94/12
95/16 103/10 104/14
105/25 127/11 139/18)
141/15 142/19 148/20)
156/4 173/3 173/4
173/8 173/13 180/3
180/11 180/12 180/16)
181/11 182/9 183/5
185/24 188/11 189/13
190/12 191/19
departments [11]
35/3 82/15 95/14
139/19 140/7 173/23
190/4 190/8 190/24
191/3 191/25
depends [1] 159/2
described [7] 6/10
8/6 10/13 26/11
130/15 151/22 184/14}
describes [2] 135/13
181/10
describing [3] 29/2
43/10 181/16
description [2] 74/11
156/20
desire [5] 9/2 11/9
28/20 33/23 177/22
desks [1] 171/4
despite [5] 3/14 44/6
50/25 64/12 140/25
detail [2] 157/16
171/16
detailed [3] 22/5
131/25 163/17
detailing [1] 168/25
details [5] 87/11
105/15 118/1 146/5
168/22
determine [1] 154/10
detrimental [2]
154/11 154/22
developed [3] 86/6
181/21 184/8
development [2]
120/15 120/17
developments [2]
159/13 161/1
Dhale [4] 105/3 108/1
111/23 115/24
dictated [1] 129/7
dictating [1] 73/20
did [87] 4/14 6/3 7/11
9/16 9/20 10/12 11/10)
11/13 12/16 13/7
20/13 20/14 20/15
20/22 24/3 24/21 28/8)
29/14 30/9 31/16 32/3
32/17 44/19 45/12
47/10 52/12 55/24
59/5 59/9 59/10 59/21
60/12 60/21 67/1
71/13 71/18 75/16
75/24 76/3 77/1 78/13
88/5 90/21 92/16
94/12 94/15 96/5
96/19 97/1 98/22
98/24 101/16 102/8
102/13 102/14 102/20)
107/5 110/20 116/10
116/25 120/18 123/24}
129/24 133/19 136/17,
139/22 143/7 150/15
151/3 158/20 166/10
169/2 169/5 170/23
174/8 175/9 175/16
175/21 177/4 177/8
180/3 181/4 182/13
188/11 189/4 191/6
191/9
didn't [39] 12/21 13/1
13/10 25/4 29/24
34/16 48/5 59/15
59/19 60/4 61/22 67/5)
68/19 68/20 72/23
72/25 73/9 81/25
84/21 92/16 96/24
104/10 107/10 110/13)
111/18 116/16 117/8
127/1 130/3 131/12
141/5 160/7 171/6
173/13 177/5 183/16
183/18 183/24 186/16)
difference [1] 170/23
differences [1] 75/2
different [22] 5/19
9/12 10/7 12/25 18/8
25/7 40/22 41/14
56/18 59/4 62/2 75/12
78/24 82/22 90/5 90/7
94/23 119/23 140/7
142/17 143/15 179/6
difficult [2] 55/2
172/2
difficulties [3] 30/14
93/24 94/2
difficulty [7] 49/6
93/10 152/21 154/14
154/25 165/12 170/5
diktat [1] 73/20
igence [2] 156/15
156/23
Dilley [41] 34/22
35/13 35/24 37/1
43/18 44/20 48/16
49/20 51/18 52/22
53/13 56/25 57/17
60/24 61/11 65/1
65/17 71/2 74/22
75/22 78/5 78/23 79/3
79/11 83/5 83/17 84/6
88/15 99/3 113/21
134/20 162/21 163/19}
165/15 166/21 169/25)
170/3 172/1 189/10
189/14 191/14
Dilley's [4] 27/10
41/20 60/25 88/18
direct [3] 8/2 8/3 35/9
cting [1] 19/7
direction [7] 48/24
53/10 63/17 129/5
178/18 178/20 179/1
directly [11] 18/5
18/23 31/25 35/6
35/15 60/7 97/7 158/2
174/12 191/7 191/9
director [2] 185/9
191/25
disallowed [1] 54/21
appeared [1] 8/3
disbursements [1]
54/12
disclosable [3] 107/9
153/14 154/3
disclosed [14] 2/16
3/8 28/23 28/25 57/21
60/18 75/19 75/23
141/3 141/11 146/22
160/8 187/8 187/18
disclosure [14] 2/10
20/3 51/19 57/19
61/23 79/20 84/21
95/19 102/22 111/19
119/22 122/18 122/21
187/24
discrepancies [4]
23/16 41/16 41/22
42/19
discrepancies' [1]
23/6
discrepancy [2]
137/13 138/9
discretion [1] 18/17
discuss [3] 25/1 59/3
75/24
discussed [14] 53/18
54/13 54/25 57/25
79/5 83/21 98/9
156/12 156/21 157/7
158/3 160/15 189/10
189/12
discussing [2] 54/3
155/5
discussion [4] 48/21
137/18 150/3 156/19
discussions [5] 58/2
93/4 153/23 153/24
155/17
disillusioned [1]
30/22
disposed [1] 25/8
disproportionate [5]
54/13 54/23 56/3 79/6)
81/18
dispute [3] 142/16
142/21 180/10
disputed [2] 146/3
173/10
disputing [1] 24/12
dissuade [3] 88/4
114/23 119/3
dissuaded [1] 156/3
distinct [3] 10/18
11/4 141/19
distinction [2] 71/17
71119
distinguish [4] 171/7
distinguishing [1]
185/19
distribution [10]
62/12 62/14 66/12
70/4 70/6 121/12
133/2 133/3 134/8
186/17
disturbed [1] 128/8
ided [1] 95/25
Division [4] 105/5
Divisions [2] 116/21
116/22
Dixon [4] 103/11
103/25 142/14 143/10}
do [112] 2/6 3/23
8/24 9/25 11/21 12/20)
16/13 21/22 23/14
32/1 32/14 36/15 41/8)
41/21 42/22 43/11
51/10 55/25 60/20
65/5 67/12 71/9 73/15
76/12 77/4 77/7 77/19)
79/17 81/6 84/11
84/19 86/2 86/25 89/3
90/4 90/7 91/14 92/16
92/19 96/8 96/8
103/21 105/22 108/3
108/5 108/8 111/25
114/21 115/24 119/12}
119/15 120/14 125/8
127/9 132/11 133/13
134/11 135/12 135/17)
135/23 136/8 136/11
137/1 137/9 137/21
138/21 141/7 141/12
144/7 144/12 145/2
146/1 146/12 146/20
147/5 148/2 148/13
149/5 150/3 150/15
150/19 150/24 151/4
151/14 151/18 153/18)
155/4 155/12 158/1
158/25 160/21 161/22)
163/5 166/18 167/9
168/11 169/14 170/14)
171/16 172/1 173/24
174/3 174/14 175/11
176/5 177/17 183/22
184/1 187/24 189/2
190/22 191/7
doctor's [1] 83/9
document [52] 18/9
24/7 51/18 53/19 54/6
60/16 60/24 61/1
61/17 74/22 79/1 79/9I
80/1 80/3 81/11 84/20
94/8 97/12 104/25
111/22 115/12 115/18)
121/7 127/18 131/21
132/7 132/14 134/3
135/17 137/25 138/23}
141/25 142/8 144/17
147/13 149/8 150/7
150/10 155/7 157/1
158/1 160/7 162/1
169/22 169/23 169/25)
174/18 174/19 174/19)
184/9 185/23 187/14
documentary [3]
68/5 101/24 158/19
documentation [16]
2/15 13/11 27/24
27/25 28/2 29/7 39/24)
48/11 52/20 67/23
106/6 118/18 130/6
130/11 187/17 189/2
documentation’ [2]
37/25 44/10
documents [18] 10/7
23/14 46/15 56/18
60/17 79/10 86/23
98/25 114/20 120/22
122/1 122/22 122/24
132/7 141/3 165/1
166/13 172/19
does [14] 23/15
42/18 51/15 63/14
73/18 85/4 100/10
105/19 118/3 119/1
164/14 164/23 165/1
186/18
doesn't [5] 27/17
52/2 64/5 69/16
130/18
doing [3] 53/21
130/25 136/8
(67) defeated - doing
D
domain [3] 12/8
12/15 26/24
don't [37] 7/15 27/18
51/20 55/23 69/3
70/13 77/3 84/22 90/7
91/3 91/6 94/9 111/7
112/18 116/2 118/7
119/18 120/16 133/24}
136/1 137/2 137/2
147/7 149/7 149/24
149/25 151/17 151/17
153/24 154/6 155/6
159/2 169/5 173/18
174/10 178/21 190/18}
done [5] 5/11 30/20
109/2 159/3 190/20
door [4] 180/17
doors [1] 96/3
double [1] 96/3
doubt [6] 13/8 21/19
33/5 33/9 74/9 76/5
doubting [1] 182/14
doubts [2] 12/22
117/3
Doug [1] 155/8
Douglas [1] 4/16
Douglas-Jones [1]
4/16
down [49] 14/16
15/22 16/4 16/21 21/2)
22/21 37/21 38/18
41/11 44/2 44/12
44/25 48/19 50/5
51/25 53/23 54/9
57/22 58/9 64/8 66/13,
70/15 80/14 85/1
85/12 86/1 95/16 96/4
96/4 97/18 100/3
105/2 108/21 122/10
127/20 134/6 138/17
144/21 147/14 162/22)
165/18 167/4 168/5
168/12 174/25 175/6
179/23 181/14 191/18
down' [1] 49/17
downside [1] 49/1
downwards [3] 82/6
181/9 181/13
draft [6] 42/22 53/17
65/14 71/11 74/20
140/6
drafted [1] 70/24
drafting [5] 70/21
139/13 139/20 158/4
158/8
draw [5] 71/17 71/19
89/21 114/19 174/23
drawing [2] 72/2
1417/9
drawn [3] 135/23
149/14 151/24
draws [1] 89/14
Drive [4] 66/18
167/16 168/11 169/8
driven [1] 51/10
driving [3] 51/16
64/18 163/24
due [12] 3/18 13/23
22/3 22/17 66/22
68/13 129/2 136/25
137/15 156/14 156/23)
177/14
duly [1] 30/25
duration [1] 181/18
during [13] 4/23 6/9
13/5 43/12 87/20
87/21 112/4 122/23
143/22 169/11 179/8
181/17 192/14
duties [2] 62/23
102/21
dwarfs [1] 39/2
E
each [12] 102/25
123/8 123/13 124/14
125/3 125/4 125/11
126/25 158/22 168/17)
168/24 183/7
earlier [18] 2/25 14/6
14/21 34/4 46/19 50/3
55/10 68/7 68/12 69/1
94/17 128/2 130/15
131/22 151/9 160/1
161/8 170/16
earlier: [1] 178/19
earlier: no [1] 178/19
early [11] 9/23 26/8
47/17 61/8 89/25 97/4
106/1 120/15 120/16
124/13 191/24
earth [2] 32/11 34/4
economic [1] 28/14
edit [1] 140/7
edition [1] 123/5
editorial [1] 134/23
effect [18] 6/17 6/24
TIT 7/13 17/23 29/18
41/5 51/2 69/21 73/5
73/7 81/13 95/16
133/7 134/25 152/3
168/3 181/21
effective [3] 28/7
28/13 30/20
effectively [5] 29/6
71/22 73/18 163/8
177/3
efficiently [1] 152/5
eg [1] 80/20
eg insufficient [1]
80/20
egg [1] 49/17
either [6] 22/18 96/21
105/25 188/7 188/10
189/12
Elaine [1] 21/5
Eleanor [1] 103/11
electronic [3] 61/14
187/11 187/11
elements [1] 23/23
eliminating [1] 184/2
else [8] 44/1 52/12
63/3 67/13 69/6 70/24
143/21 157/25
else's [1] 131/5
elsewhere [1] 6/3
email [89] 2/20 3/9
14/17 17/15 19/9 20/1
20/9 20/12 26/6 34/11
34/22 35/24 38/7 38/9
38/17 40/21 41/10
41/20 43/18 45/14
53/13 54/5 56/20
56/23 57/23 62/11
65/16 66/7 66/11 70/3
70/4 70/6 75/21 78/4
79/2 79/19 83/2 83/3
83/19 83/22 84/5
86/24 88/15 88/18
92/23 93/23 97/15
97/16 99/9 103/5
108/10 113/15 121/8
122/5 128/2 131/17
136/24 137/3 137/16
137/17 138/25 140/9
140/25 142/4 142/8
144/24 144/24 145/20)
146/19 146/21 148/5
151/6 152/18 154/2
155/25 156/7 156/8
156/18 157/5 159/7
165/15 165/20 168/13
168/14 174/22 175/7
176/9 186/5 186/8
email from [1]
108/10
emailing [1] 83/5
emails [10] 34/21
42/5 44/15 57/2 62/2
122/3 143/24 144/19
191/22 191/24
emanated [1] 69/13
embedded [1]
161/23
embryonic [3]
101/10 114/15 128/13
emerged [1] 185/17
eminently [2] 27/12
27/18
employee [1] 112/17
employees [2] 38/16
66/2
employment [1]
85/24
enabled [1] 82/15
encountering [1]
30/19
end [13] 15/23 89/18
94/8 94/8 96/4 96/4
96/9 126/15 127/1
147/13 173/25 175/25)
182/4
endeavour [1] 58/6
endeavouring [1]
114/2
ended [1] 26/9
endorsed [1] 19/12
ends [3] 46/20 46/20
95/25
enforce [1] 55/2
engagement [1] 3/2
engineers [1] 24/14
English [4] 49/7
enhanced [1] 171/1
enlarge [1] 184/13
enormous [1] 30/14
enough [1] 13/8
enquire [1] 117/17
enquiries [4] 142/11
142/22 144/12 159/1
enquiring [1] 189/22
ensure [6] 101/23
125/10 129/4 131/10
151/11 165/4
ensuring [1] 73/18
entered [3] 13/2 36/6
36/18
enterprise [1] 152/13
entire [1] 132/17
entirely [9] 4/2 5/20
9/12 68/24 74/4
125/22 132/24 150/11
175/5
entitled [4] 18/4 35/4
170/16 170/19
entry [2] 44/7 44/7
epic [1] 165/20
equipment [4] 16/2
16/3 33/18 42/17
equivalent [4] 8/10
8/12 8/17 86/17
ergo [2] 35/6 112/16
Ernst [1] 149/17
error [12] 15/12 37/9
37/12 66/25 67/7 67/8
67/12 67/15 87/2
131/1 181/23 190/10
errors [10] 10/5 22/1
31/1 33/2 66/20 67/1
67/6 100/8 101/7
186/22
escalated [1] 189/12
escalating [1] 165/2
escalation [2] 165/6
181/12
essentially [3] 79/5
88/2 171/10
established [3] 127/4I
154/14 154/25
estate [2] 81/14
127/15
estimate [3] 53/20
109/11 169/1
estimated [1] 54/11
et [11] 80/21 90/1
93/11 131/19 134/9
135/11 160/3 163/14
164/13 170/13 171/4
et cetera [11] 80/21
90/1 93/11 131/19
134/9 135/11 160/3
163/14 164/13 170/13}
1711/4
ethical [1] 76/23
Evans [1] 155/8
even [18] 13/14
16/14 38/14 45/19
49/12 50/10 51/4 55/1
88/16 94/9 106/7
108/18 126/22 129/5
132/16 162/2 164/11
191/19
event [4] 17/6 45/9
78/11 164/12
events [2] 60/1 169/8
eventual [1] 13/4
eventually [4] 109/5
157/19 166/21 191/11
ever [18] 7/15 10/22
41/24 42/7 77/11
80/10 94/10 104/16
106/20 120/18 127/6
127/13 136/6 136/17
137/3 146/15 149/22
173/18
every [10] 80/22
102/25 109/24 109/24)
113/25 115/8 116/1
125/11 125/13 183/7
everybody [1] 6/18
everyone [1] 171/25
everything [2]
113/13 168/14
evidence [61] 13/24
16/18 19/6 21/17 25/2)
27/10 28/11 30/2
31/20 32/1 33/5 33/9
34/4 38/25 39/8 40/3
41/18 46/1 46/4 46/11
48/5 48/13 60/25
62/18 63/9 66/3 67/7
67/9 68/5 69/19 80/20I
88/18 89/24 99/1
101/24 118/5 122/15
123/11 125/2 129/12
130/15 140/24 153/9
153/15 154/4 154/20
158/19 158/22 164/24)
166/10 167/1 171/9
178/8 178/16 179/2
179/4 181/1 183/23
184/14 186/18 187/7
evil [2] 103/17
184/20
exactly [7] 29/5
98/19 142/19 147/15
160/3 167/17 176/8
examination [1]
22/24
examine [1] 135/9
example [25] 10/13
19/8 22/15 43/3 49/4
50/16 67/17 68/25
71/4 71/12 76/24
81/18 86/18 88/3
102/9 102/14 111/16
114/23 117/2 141/17
144/5 148/9 165/2
(68) domain - example
E
example... [2] 189/7
189/8
examples [1] 85/18
excess [1] 86/8
exchange [1] 75/21
exchanges [1]
188/20
excluded [1] 76/10
Excuse [4] 65/9
65/18 161/18 174/1
exercise [6] 107/5
112/2 112/19 156/15
156/20 156/23
exist [1] 180/10
existing [1] 122/16
expanded [1] 177/11
expect [1] 93/8
expected [3] 87/11
87/18 176/10
expenditure [2]
81/18 173/1
expense [2] 40/12
111/18
expensive [5] 49/4
109/9 110/9 130/7
173/20
experience [6] 9/25
39/15 42/16 45/12
60/14 82/1
experienced [2] 22/8
113/7
expert [18] 16/8
17/12 20/13 20/16
28/8 34/12 43/4 43/9
59/6 75/9 75/15 76/16
102/10 102/16 163/6
166/1 166/5 171/2
expert's [6] 24/19
28/22 31/13 32/13
32/24 34/6
expertise [1] 155/14
experts [3] 65/24
75/14 166/1
experts’ [4] 31/22
33/25 41/19 44/4
expired [1] 56/1
explain [2] 9/23 36/9
explaining [1] 140/20
explains [1] 38/22
exploring [1] 89/15
expressed [8] 19/11
24/24 27/19 43/14
44/24 47/9 49/21 53/6)
expressing [1] 51/21
expression [2] 69/15
71/24
extent [4] 63/22
118/3 133/24 160/8
external [26] 17/22
18/5 18/16 18/22
18/23 19/3 19/13 32/4
82/16 91/5 101/22
112/25 113/8 125/7
126/10 126/25 135/5
149/14 149/21 159/18)
166/1 166/5 174/8
174/10 174/13 175/19)
extract [1] 111/4
extracting [1] 124/12
extraordinary [1]
94/19
extreme [3] 76/6 76/9I
165/22
extremely [1] 96/6
eye [1] 19/1
facility [1] 113/23
fact [24] 8/7 22/5
31/9 36/5 45/21 46/24
55/21 64/20 65/5 65/6
65/23 81/5 90/9 90/11
100/16 101/5 115/2
125/16 149/19 149/24)
166/24 176/14 186/20)
187/10
factor [3] 64/18
91/11 92/5
facts [10] 26/1 75/12
103/1 117/23 118/25
120/12 121/11 121/13)
122/8 125/13
fail [1] 33/17
failed [2] 44/7 153/5
failure [3] 15/12
33/20 162/7
failures [1] 21/20
fair [8] 8/22 54/5 56/4
89/3 109/17 130/21
156/20 172/7
fairly [2] 80/15
191/21
fairness [2] 20/19
20/23
falling [1] 86/4
familiar [1] 80/2
family [1] 6/4
far [16] 43/7 44/10
48/4 63/12 78/1 85/25
93/9 101/2 120/3
146/5 168/16 175/24
176/16 184/2 185/22
188/25
fashion [1] 77/25
fate [1] 173/11
father [1] 6/6
fault [11] 3/7 15/11
16/1 16/16 17/2 17/10
21/18 22/2 22/9 109/3
110/4
faults [1] 49/3
faulty [1] 22/4
favour [1] 150/24
feast [3] 63/22 114/2
121/23
feature [1] 81/6
February [13] 15/6
48/17 49/20 50/24
51/20 52/22 55/11
134/5 145/12 145/19
146/18 150/3 155/18
February 2000 [1]
15/6
February 2006 [2]
50/24 52/22
February 2010 [1]
150/3
fed [2] 135/3 148/19
feeding [1] 174/3
feel [7] 2/6 3/23 13/7
109/19 116/11 128/21
175/16
feels [1] 48/23
fellow [1] 172/6
Felstead [1] 98/14
felt [6] 49/23 49/24
63/9 139/21 178/12
188/9
few [6] 8/21 46/16
120/22 163/22 172/7
181/5
field [2] 166/5 171/2
fifteen [1] 163/10
fifth [2] 127/20
127/23
fight [1] 50/12
figure [1] 16/24
figures [6] 23/6 23/7
30/16 67/25 141/16
153/10
figures’ [1] 23/8
file [2] 46/14 147/24
filed [1] 102/19
files [3] 148/3 187/11
187/11
fill [1] 1314/7
filling [1] 129/16
final [15] 1/20 15/8
16/21 22/21 30/3 40/2I
61/6 65/15 123/1
134/16 157/1 157/3
162/15 165/11 175/7
financial [7] 88/21
93/10 93/23 94/2 94/5
137/13 157/8
find [4] 46/15 55/2
98/9 172/1
finding [1] 178/24
fine [3] 47/20 172/8
192/18
finish [2] 162/13
162/14
firm [15] 4/17 19/8
19/20 35/18 35/25
43/25 46/21 49/25
50/10 75/13 125/8
126/10 149/21 178/13
178/18
firm's [1] 35/16
firmly [1] 161/23
firms [7] 17/22 18/16
81/24 82/4 85/10
113/1 124/23
first [28] 15/1 17/16
17/17 36/20 37/2
39/24 40/19 40/20
44/16 45/25 56/19
67/15 71/1 74/23
81/12 82/1 95/12
100/16 104/15 124/9
140/9 140/23 146/19
182/8 182/15 186/20
190/17 191/23
firsthand [1] 22/7
Fis [4] 145/25
fit [2] 13/18 83/14
five [2] 124/7 126/19
floors [1] 95/15
flotation [1] 5/24
focus [1] 58/7
folders [1] 113/15
follow [3] 164/9
190/21 192/8
followed [4] 18/19
42/20 149/4 189/17
following [6] 39/15
112/7 133/18 139/8
146/25 192/20
follows [5] 37/17
66/15 100/2 146/23
186/11
footprint [1] 10/20
force [1] 51/16
ford [1] 105/11
fore [1] 146/10
forgot [1] 96/14
forgotten [1] 59/11
form [16] 42/24
66/14 67/4 69/5 69/20)
69/23 70/20 71/10
73/2 73/8 120/11
135/4 135/7 169/3
169/5 169/10
formal [5] 91/2 92/11
180/15 180/24 181/12)
formally [2] 67/2
135/9
former [6] 2/23 66/17
103/14 103/15 122/16)
142/6
Formerly [1] 14/19
forms [1] 169/14
formulated [1]
169/14
forward [4] 45/10
126/9 130/14 139/22
forwarded [5] 83/5
83/17 97/16 137/1
142/8
forwarding [2] 38/8
167/2
forwards [1] 151/9
found [2] 61/12
167/22
four [3] 6/21 144/19
171/3
fourth [3] 15/22
127/8 127/20
frank [1] 89/9
fraud [2] 147/23
148/18
free [6] 2/6 3/24 72/5
72/14 72/21 73/13
Freedom [1] 5/14
freeing’ [2] 22/17
22/25
freeze [1] 23/1
freezes [1] 22/1
freezing [1] 22/16
frequently [2] 23/16
30/15
front [3] 1/14 1/17
133/13
frustrated [4] 109/20
110/5 111/5 125/16
frustrating [2] 84/7
88/20
FUJ00080715 [1]
2/22
FUJ00121637 [1]
26/5
FUJ00121724 [1]
2/20
Fujitsu [77] 2/14 2/18I
2/24 10/22 11/6 11/12I
11/14 11/15 12/12
14/7 14/11 16/11 24/7I
24/11 24/25 25/6
25/14 26/6 28/5 28/12)
29/20 34/9 41/2 41/3
49/5 49/8 58/10 58/11
58/12 58/17 58/20
58/24 59/2 59/17 66/2I
67/9 76/8 76/10 76/17
77/16 78/20 99/18
109/10 109/21 110/17
110/18 110/25 111/9
111/12 116/19 117/22!
118/24 120/3 124/21
125/7 129/20 135/6
155/13 165/13 166/3
166/13 166/23 167/1
167/9 167/19 168/9
168/23 170/6 170/7
170/15 170/20 170/25)
171/5 191/4 191/6
191/8 191/15
Fujitsu's [1] 168/16
fulfil [1] 112/22
fulfilling [1] 129/16
full [20] 1/12 39/22
40/13 52/20 59/16
59/20 59/21 60/1 60/3
64/10 64/13 128/24
128/25 149/1 149/5
149/12 149/19 150/4
150/13 150/25
fully [3] 22/19 128/22
155/13
function [4] 121/4
133/24 139/17 161/11
functioned [1] 5/20
functioning [5] 71/8
71/15 72/7 117/16
120/19
further [23] 2/9 22/24
(69) example... - further
F
further... [21] 25/1
25/2 44/12 58/5 58/9
63/21 69/25 71/3
73/11 78/12 92/25
98/4 118/19 122/11
150/8 150/21 152/16
157/18 158/21 175/6
190/3
future [7] 58/21
114/23 123/22 123/24}
124/6 135/11 155/16
G
gain [4] 138/12
138/19 138/22 149/14)
Gammack [1] 43/25
gather [1] 126/23
gathering [1] 118/5
gave [7] 11/21 41/25
100/22 172/19 173/24}
174/1 185/16
general [17] 7/11
7/114 717 9/17 21/13
91/9 92/20 95/17
120/11 124/25 156/23}
162/17 163/15 168/2
168/24 169/10 169/15)
generality [1] 18/15
generally [6] 10/11
21/12 58/24 120/24
184/10 188/12
generated [1] 37/11
generic [4] 93/19
169/3 169/5 169/7
genuine [3] 33/4 33/8)
132/21
genuinely [6] 12/11
32/19 49/22 69/8 76/1
184/1
geographically [1]
95/22
get [25] 13/23 26/20
36/12 49/5 49/7 62/1
68/10 68/18 72/1 73/1
76/13 77/20 82/19
110/9 1141/1 111/8
127/15 134/18 139/3
160/2 163/2 163/14
174/20 182/13 188/7
gets [1] 23/2
getting [11] 46/25
52/7 52/8 57/19 71/22
93/8 104/5 109/16
166/15 166/18 181/2
give [20] 1/11 10/12
16/20 17/3 18/23 23/2)
25/15 32/17 33/20
39/5 69/16 84/3
105/15 125/25 126/24}
149/15 159/21 171/25)
186/16 190/10
given [39] 8/20 10/18
11/2 19/11 25/19
31/23 32/1 32/14
33/23 40/25 45/24
46/22 57/13 59/14
62/18 63/9 76/12 77/6
77/9 84/7 87/25 87/25)
109/10 110/6 116/19
129/5 134/24 137/24
145/10 151/1 152/5
152/9 155/3 155/17
156/2 164/24 165/3
175/15 179/7
gives [5] 22/12 22/15
58/4 85/18 159/22
giving [5] 5/10 17/4
99/19 189/14 189/24
glitch [9] 10/20
106/15 137/17 137/19}
137/20 139/9 139/16
140/15 141/8
glitches [5] 76/7
76/12 76/18 77/17
141/14
global [1] 54/11
go [48] 12/24 15/15
15/22 19/13 22/14
23/18 27/8 27/14 28/6
37/14 38/6 42/2 48/24)
57/18 58/17 61/5
63/25 64/5 69/21 70/3
71/1 78/19 78/25 79/9)
82/15 83/2 85/12 90/9)
97/3 98/2 100/3 108/8
110/25 111/7 114/19
117/16 134/12 138/23)
138/24 144/18 147/19)
164/10 169/9 180/7
182/2 182/7 182/10
191/9
go-between [1]
69/21
goal [3] 56/4 88/24
89/4
goes [3] 26/25 49/10
122/7
going [49] 1/7 5/7 9/9
9/14 16/20 32/21
34/17 34/18 35/15
38/17 47/15 48/3
58/11 65/13 66/3 78/7)
78/17 78/24 79/14
79/16 79/21 84/1
94/23 97/13 101/16
108/6 112/3 112/19
112/24 115/23 119/9
119/23 120/1 122/3
123/14 126/15 130/11
130/14 144/16 144/18)
146/20 152/11 152/18)
156/22 163/21 174/18)
174/23 185/8 190/2
gone [5] 29/18 46/14
50/15 67/20 186/19
good [16] 1/3 6/19
15/5 64/1 88/25
107/20 107/21 131/20}
137/14 138/7 138/10
152/9 152/15 175/23
176/8 192/13
got [10] 11/4 11/10
32/11 77/15 77/16
99/5 115/21 127/6
179/1 185/8
GP [1] 84/2
Graham [8] 97/17
97/17 99/4 144/25
145/5 165/23 166/13
167/3
grant [1] 96/16
Granville [4] 118/12
159/8 160/25 185/4
grateful [7] 58/22
70/18 105/15 141/5
179/23 184/12 191/1
Graves [5] 103/7
103/7 142/5 143/14
143/20
gravitas’ [1] 149/16
great [3] 32/6 133/11
175/3
greater [1] 134/24
Greening [3] 94/8
115/12 127/14
grip [1] 127/15
ground [1] 115/21
group [21] 5/17 5/23
5/25 13/3 19/15 62/24
62/25 63/2 83/4 112/8}
121/3 121/20 132/17
134/1 139/20 140/8
143/8 151/12 161/24
175/2 187/4
groups [1] 121/22
guidance [5] 180/18
181/8 181/13 181/14
182/5
Guildford [3] 117/16
118/17 119/8
Gurdeep [1] 105/3
guys [1] 145/6
H
had [179] 2/14 2/16
2/24 3/6 6/15 7/1 7/6
7/8 7/11 7/15 9/8 13/7,
14/19 14/21 15/6 18/9
18/16 19/9 19/23
21/11 21/17 24/4
24/18 25/24 26/1
27/23 28/5 28/19
28/20 28/20 29/12
29/18 29/19 30/13
31/2 32/7 32/7 34/2
35/14 36/6 36/8 36/9
36/15 36/21 39/23
43/3 43/4 43/7 43/9
44/17 44/23 45/5 45/7
45/18 45/21 45/24
46/14 46/18 46/19
46/21 48/13 48/18
50/24 51/6 51/11
52/19 55/16 55/20
56/1 56/8 56/15 57/3
59/5 60/7 60/25 63/6
63/9 64/20 64/25
65/16 65/24 66/1
66/21 67/10 67/20
68/13 70/24 71/15
72/8 72/13 72/19 73/3
73/9 76/7 76/16 76/17,
77/18 77/23 78/17
81/24 88/8 88/11
88/11 90/19 90/22
91/1 92/11 93/4 95/9
96/12 99/6 99/16
101/9 101/17 102/2
102/9 102/14 102/16
102/21 104/19 106/4
106/11 106/13 106/23}
107/6 107/7 108/16
108/20 112/9 112/12
114/13 115/13 116/9
116/14 117/5 118/8
120/6 120/10 120/19
124/4 125/17 127/11
128/6 130/5 132/9
139/16 141/4 143/10
148/7 148/17 150/1
150/17 151/1 152/3
152/8 156/19 158/7
158/16 159/4 160/12
160/13 160/18 160/24}
161/8 161/21 161/24
164/7 168/3 170/3
170/5 171/6 173/17
175/4 175/18 176/2
176/5 176/15 187/10
191/7
hadn't [7] 52/19
61/24 115/21 130/5
135/19 170/18 176/3
half [5] 132/15 134/7
136/23 144/21 146/17I
halfway [6] 16/21
37/21 64/7 100/3
109/6 162/22
Hamilton [6] 100/1
100/5 100/14 102/4
105/10 106/10
hand [2] 125/1 179/9
handed [1] 61/18
handle [1] 57/3
handled [1] 129/2
handwriting [1]
141/2
happen [5] 26/2
26/25 32/7 32/8 64/5
happened [6] 27/3
27/5 28/19 28/21
132/2 149/9
happening [2] 92/14
132/3
happy [8] 26/22 28/5
79/15 79/18 150/14
163/5 163/15 164/9
harassment [1]
85/19
hard [4] 38/21 51/8
61/18 178/25
hardware [3] 22/4
22/18 23/24
has [55] 1/17 12/8
13/16 16/10 22/11
26/8 26/17 31/6 31/14)
33/18 34/4 37/10
37/11 37/13 38/25
44/4 44/7 45/9 51/19
53/1 60/17 62/18 71/4I
74/10 77/6 84/3 85/1
87/10 87/12 98/15
100/15 105/9 106/18
108/12 109/2 109/7
123/3 126/4 128/8
128/20 132/24 134/6
134/10 134/14 134/20)
135/17 138/8 138/19
146/18 147/19 153/7
164/8 165/21 167/15
187/17
hasn't [1] 57/20
have [280]
haven't [4] 24/9
63/12 168/16 189/1
having [21] 2/9 29/7
34/11 34/11 41/16
52/19 64/9 71/9 75/4
81/8 92/2 104/5
110/11 111/8 120/14
125/15 129/14 141/22)
150/24 151/22 178/22)
Hayward [9] 61/4
65/8 74/20 75/13
145/1 145/1 146/18
147/11 147/18
he [126] 14/19 14/19
14/21 14/24 14/25
15/1 15/22 15/24
16/19 16/19 16/20
17/20 17/23 19/18
20/24 21/24 22/14
22/15 22/22 23/9 23/9I
23/18 23/19 26/7
35/14 37/3 37/14
37/18 37/20 38/2 38/3I
41/7 42/12 43/19
43/19 44/3 46/9 46/18
48/17 48/18 48/21
51/11 52/22 52/23
54/3 54/10 54/24
55/24 58/4 58/4 58/9
58/10 59/7 60/8 71/2
71/4 72/8 72/10 72/11
72/13 72/13 72/19
72/20 73/3 73/4 73/9
73/9 73/10 78/17 79/4I
83/4 83/6 83/8 83/13
84/1 87/10 87/12
87/18 88/19 88/23
93/3 97/23 97/24 98/5)
99/6 104/21 104/22
107/1 109/2 109/2
109/5 109/7 111/11
111/12 113/14 113/14}
120/19 122/11 127/9
127/9 128/5 132/21
132/22 133/20 139/23)
(60) further... -he
H
he... [21] 145/11
146/7 151/10 151/20
158/16 159/2 163/9
167/16 168/5 168/7
168/15 175/21 176/2
176/2 176/3 176/11
176/12 176/13 176/19
191/22 191/24
he's [2] 42/12 48/21
head [17] 6/17 7/20
7/21 8/15 38/13 38/15
62/17 96/22 97/5 97/6
118/12 121/16 133/20)
150/20 151/11 177/4
185/20
headcount [5] 8/13
9/4 112/4 112/20
127/12
headed [1] 139/13
heading [1] 185/5
Headquarters [1]
134/2
heads [1] 87/14
health [3] 82/23
84/15 91/7
hear [5] 1/3 1/7
167/17 175/17 176/11
heard [5] 19/17 42/24I
42/25 121/17 155/3
hearing [3] 117/19
118/2 192/20
heart [1] 179/9
held [1] 114/23
help [6] 6/5 30/10
171/4 180/20 182/11
186/7
helpdesk [6] 21/10
21/22 27/4 42/21
168/1 169/1
helped [1] 168/17
helpful [2] 43/21
74/11
helpline [1] 30/18
helps [2] 89/1 182/3
her [24] 15/7 15/11
16/1 17/2 17/9 18/11
21/7 22/9 26/16 29/6
30/14 30/24 31/10
33/19 44/16 45/7 93/5)
93/19 98/15 100/9
100/10 100/18 102/4
129/13
Herbert [1] 170/4
here [21] 3/25 14/15
29/2 36/20 52/8 60/7
62/2 73/17 77/15
104/7 113/15 116/24
117/14 124/4 133/14
160/4 160/21 161/12
179/25 182/3 185/11
Hi [1] 139/2
hide [10] 28/19 28/20
29/17 29/22 29/24
32/9 48/6 48/13 48/14,
51/7
high [8] 51/25 73/20
80/18 81/1 90/2 92/20
142/12 143/7
Highcliffe [4] 142/14
higher [2] 38/6 41/4
highlight [2] 21/3
123/7
highlighted [2] 65/7
70/16
highly [4] 154/17
him [28] 24/14 24/15
25/1 59/17 59/19
60/22 64/10 64/14
66/16 68/16 68/18
72/18 72/20 73/5 73/7
83/25 83/25 84/3 91/1
104/18 106/21 109/4
122/3 139/25 145/2
158/18 158/20 159/3
himself [5] 13/21
18/9 87/10 87/19 89/5)
hindsight [3] 12/7
12/14 103/23
hint [4] 100/10
his [35] 2/13 8/17
13/22 20/12 22/15
23/19 26/9 27/12
35/15 35/16 35/18
37/2 39/2 40/25 64/12
65/4 72/1 72/11 83/8
83/9 83/12 86/21
87/13 90/17 97/19
120/22 120/24 121/3
122/4 127/10 133/22
133/24 151/14 158/15)
191/14
historical [1] 145/25
hm [15] 32/10 42/6
66/8 70/8 80/13 82/25)
86/14 93/2 98/8 98/16
102/7 120/23 122/6
165/17 185/15
Hogg [1] 159/24
Hoggard [2] 37/20
38/4
hold [5] 37/23 44/9
114/5 115/3 127/22
holiday [1] 141/1
Holmes [8] 2/22 26/6
27/16 29/2 98/10 99/6
99/9 99/11
Holmes' [1] 98/18
home [2] 53/21 88/7
hopefully [2] 84/8
162/13
hoping [2] 78/10
130/12
Horizon [169] 3/5 3/6
9/20 10/14 12/6 12/19
12/23 13/2 13/9 14/1
14/10 15/5 17/9 21/10
24/15 24/23 27/4 28/3
30/9 34/3 34/13 39/4
39/7 39/11 39/16
39/17 40/3 40/7 41/7
44/6 49/1 49/22 50/1
50/8 50/23 50/25 51/4
51/6 56/8 58/7 59/24
60/10 60/13 61/9
61/13 63/3 64/13 65/7
65/24 66/23 66/25
67/5 68/23 69/9 71/7
71/16 72/6 72/14 73/4
73/12 73/19 74/6 74/8
76/4 76/11 76/15
77/22 89/1 93/7 93/18
93/19 93/22 100/6
100/8 100/18 100/20
101/7 101/19 102/11
102/12 102/16 102/24
103/17 104/20 105/8
105/18 107/4 107/8
108/13 109/4 109/23
110/4 110/13 114/1
114/5 115/9 115/11
116/1 116/6 116/14
117/7 117/22 118/24
120/15 120/17 120/20}
122/17 122/20 123/10
123/13 123/21 124/1
124/12 124/15 124/25)
126/11 128/14 129/3
129/7 129/12 129/15
130/20 130/22 132/23
132/24 133/8 133/17
137/17 138/8 139/24
140/3 140/5 140/15
141/9 142/7 144/2
144/10 145/8 145/12
146/3 147/5 147/21
152/22 153/2 153/7
153/19 154/10 156/15}
157/9 158/13 159/9
159/14 159/16 159/21
160/4 160/12 160/14
167/7 167/11 173/10
175/5 177/15 177/24
178/13 181/7 182/14
184/25 186/14 186/22
hospitalisation [1]
83/12
hospitalised [1]
84/12
hostile [1] 16/12
hour [1] 9/22
hours [2] 47/6 94/20
house [10] 6/16
17/23 18/6 82/17
87/14 92/1 92/3 96/1
112/16 131/8
how [22] 18/14 18/17
26/18 27/13 29/11
51/23 52/1 67/13
67/15 67/17 68/2
95/10 96/19 112/9
113/21 129/7 135/14
140/21 142/25 155/25}
169/13 184/7
however [9] 37/9
50/24 54/17 55/4
98/21 100/10 152/24
166/4 166/23
HSH [2] 24/6 28/4
huge [1] 171/17
Hugh [7] 100/24
101/5 101/9 101/16
101/21 128/12 129/2
Hulbert [4] 40/21
40/25 111/12 165/24
human [6] 15/20
66/25 67/7 67/8 67/12,
67/15
hypothetical [1]
72/23
l acquired [1] 78/22
lact [1] 172/16
l actually [1] 86/9
l adopted [1] 76/25
lagree [2] 72/24
136/4
lalso [1] 163/7
lam [12] 4/5 20/4
27/17 31/19 31/20
43/22 57/25 86/20
100/11 155/18 166/15]
189/22
land [1] 152/2
I appreciate [1]
109/8
lask [1] 1/20
l assume [8] 87/2
136/16 147/12 156/3
159/17 161/19 173/22}
184/19
l assumed [1] 116/17
lattach [1] 103/25
I became [1] 5/21
I believe [41] 2/3 4/6
9/4 13/12 17/17 18/7
18/8 24/5 24/9 25/9
29/10 38/13 41/1 41/1
46/8 46/13 49/23 53/5)
74/14 77/24 78/16
97/3 97/4 97/9 101/20)
102/18 104/9 105/24
106/3 106/21 118/9
119/6 121/15 137/23
150/16 160/8 160/18
161/10 166/20 176/4
181/16
lean [22] 1/5 14/2
34/15 63/5 88/15 97/3,
104/16 114/14 120/9
135/16 136/1 136/11
141/20 155/6 157/7
160/24 161/18 167/8
172/5 179/18 190/10
190/15
I can't [31] 4/7 10/2
25/17 32/16 34/9 41/6)
52/18 62/8 62/21
69/24 72/16 85/11
90/24 104/23 114/25
118/14 119/11 119/14}
121/3 132/13 141/18
146/14 150/7 151/5
152/16 157/17 164/1
164/3 165/9 179/11
186/10
I cannot [18] 11/4
14/3 33/11 42/9 61/25)
63/4 74/15 75/23
103/9 143/23 144/4
150/6 151/2 156/24
157/16 158/20 173/6
186/16
I confirm [1] 138/15
I considered [1] 77/3
I copied [1] 165/20
I could [5] 78/21
82/12 179/11 189/23
191/18
I couldn't [1] 1741/7
I dealt [4] 11/15 74/1
102/25 121/41
I declare [1] 66/25
I did [11] 4/14 20/14
32/3 47/10 59/9 60/21
71/18 102/13 110/20
129/24 189/4
I didn't [17] 13/1
59/15 59/19 68/20
81/25 84/21 104/10
107/10 111/18 116/16)
117/8 130/3 141/5
160/7 171/6 173/13
186/16
Ido [14] 16/13 55/25
60/20 77/7 90/7
103/21 108/8 114/21
141/12 150/19 158/1
167/9 172/1 174/3
I don't [19] 7/15
51/20 55/23 84/22
91/3 112/18 116/2
133/24 147/7 149/7
149/25 151/17 151/17
153/24 154/6 155/6
169/5 173/18 174/10
I draw [4] 71/17
lended [1] 26/9
lentered [1] 13/2
lever [1] 137/3
l expressed [1] 47/9
I feel [1] 128/21
I felt [1] 63/9
I first [2] 82/1 95/12
I follow [1] 192/8
I genuinely [4] 32/19
69/8 76/1 184/1
I got [1] 11/4
Ihad [19] 7/1 7/8
28/20 29/12 36/15
59/5 66/21 81/24
106/13 118/8 148/7
148/17 150/17 151/1
158/7 159/4 160/18
160/24 164/7
I hadn't [1] 52/19
Ihave [21] 21/17
21/19 40/24 61/17
(61) he... -Thave
Ihave... [17] 70/17
70/23 80/3 80/9 83/25)
94/4 104/25 105/7
111/18 119/5 134/22
146/8 147/23 160/23
162/12 167/21 174/17)
I haven't [1] 24/9
linformed [1] 44/23
lintend [1] 16/22
joined [1] 4/5
I just [5] 84/24 91/6
130/23 171/25 178/9
I knew [5] 143/5
143/8 143/9 171/2
171/15
I know [6] 13/16
56/19 60/24 119/7
164/25 167/14
Ileft [1] 12/24
I made [3] 20/2 67/2
126/20
I may [6] 2/8 28/17
54/6 101/10 158/6
178/22
I maybe [1] 98/23
I mean [11] 20/5
29/16 39/19 52/25
86/15 101/4 110/10
110/16 121/25 125/13
145/13
I mentioned [1]
170/16
I merely [1] 102/18
I might [4] 36/23
115/16 143/24 190/20)
I moved [1] 112/7
I never [1] 92/12
Ino [1] 5/20
I now [1] 66/23
lonly [1] 113/15
I personally [1]
141/21
I presume [1] 93/18
I probably [1] 19/12
I put [1] 179/9
I qualified [1] 4/6
I really [3] 13/10
27/18 51/10
I recall [1] 63/8
I received [3] 9/22
20/9 176/18
I recently [1] 43/24
I recognise [2] 141/2
145/3
I refer [2] 53/16
89/25
l referred [2] 92/9
161/7
I remember [1] 174/3
l represent [1] 178/6
I right [2] 85/19 93/24
I said [5] 40/10 94/17
104/9 163/3 185/1
I say [5] 11/6 51/3
96/21 115/18 151/17
I see [1] 181/25
I seem [2] 55/23
98/21
sent [1] 158/20
I should [3] 60/13
162/13 168/9
I sought [1] 191/3
I spoke [2] 44/15
128/7
I suspect [5] 149/25
151/3 161/18 170/21
174/11
I take [1] 189/10
I talking [1] 128/10
I think [66] 5/1 6/1
6/10 6/20 34/7 35/1
38/20 47/18 51/12
52/13 55/16 69/12
70/12 71/3 71/24
77/11 79/3 81/14 87/3)
87/23 94/24 94/25
96/6 97/17 99/4
104/11 106/6 107/1
107/11 108/20 109/20;
111/11 111/24 112/2
112/22 113/2 115/6
116/17 117/13 121/18)
126/12 126/19 127/9
127/13 131/21 137/9
139/25 141/2 142/15
143/19 147/12 155/22)
160/15 163/21 166/2
169/6 171/9 171/18
176/14 178/10 185/1
187/17 187/19 188/2
190/20 191/24
I thought [2] 43/21
113/12
I took [5] 24/25 28/10
60/24 74/22 111/21
I tried [2] 11/23 106/3
l understand [8] 48/4
58/12 58/25 60/9
105/12 187/25 189/2
190/1
lused [3] 62/19
103/21 188/2
I viewed [1] 43/15
I want [7] 6/8 10/4
14/13 82/22 86/21
162/17 190/21
I wanted [3] 101/23
111/14 130/9
Iwas [78] 2/11 2/22
3/10 5/22 7/21 7/25
8/1 8/2 8/3 10/17
11/19 12/5 25/6 25/10
25/13 25/25 36/5
36/10 39/22 45/6
45/20 45/23 51/21
52/8 57/5 57/7 57/19
59/12 66/20 66/24
68/5 76/19 85/7 85/9
92/19 94/14 101/2
104/16 109/19 111/10;
112/5 113/5 118/7
118/9 119/7 121/2
125/15 125/20 125/23
126/2 126/20 126/21
130/11 130/17 130/22]
136/3 136/11 137/5
142/19 143/16 145/16
145/16 149/22 150/14
155/19 160/8 161/11
161/19 161/20 161/22
163/5 163/5 163/18
175/18 179/7 180/1
181/20 185/1
I wasn't [7] 43/6 82/2
84/13 94/17 111/13
152/6 175/13
I were [1] 141/1
Iwill [2] 3/21 78/12
I wish [4] 2/8 125/10
152/15 179/11
I worked [2] 96/21
183/20
I would [31] 11/23
19/9 20/10 20/17
54/17 57/18 58/17
58/21 75/7 91/13
94/19 98/18 99/11
105/14 106/11 106/19}
106/23 117/25 119/19!
138/5 139/14 141/4
148/16 150/16 158/17
159/3 161/21 161/25
162/5 164/1 165/5
I wouldn't [1] 148/16
I'd [14] 5/11 27/19
79/9 79/19 79/25
80/11 89/10 89/13
122/5 124/7 162/22
165/3 189/22 191/1
il [16] 21/2 48/19
61/20 62/1 94/24
94/25 108/6 114/19
121/5 144/23 157/1
157/2 162/14 169/22
179/23 184/8
I'm [58] 2/11 11/24
25/16 27/24 29/11
32/20 34/17 34/18
38/17 48/3 62/21
65/12 69/24 73/1 73/6
78/24 79/21 85/23
94/23 95/18 97/13
100/21 108/6 110/16
110/20 111/3 114/2
119/13 119/23 120/1
121/1 132/13 144/16
144/18 145/23 146/19)
151/5 152/15 152/18
154/6 155/6 156/24
157/16 157/17 164/1
164/2 171/2 173/6
174/18 174/23 179/10
179/17 186/10 188/15
189/7 190/2 190/6
192/2
I've [21] 2/20 41/13
54/11 57/13 60/14
68/12 71/17 75/21
75/22 79/13 82/14
89/14 103/22 109/20
121/22 130/3 141/12
146/14 151/19 156/24}
166/23
lan [2] 146/11 170/4
lan Herbert [1] 170/4
idea [8] 40/24 69/4
94/4 151/20 174/17
177/7 177/8 178/19
identification [1]
139/8
identified [5] 10/20
75/4 76/9 76/16 105/8I
identify [8] 42/19
99/18 105/16 107/2
123/17 125/7 170/7
188/19
identifying [7] 63/15
75/16 124/17 124/22
126/10 127/23 164/14}
identities [1] 143/9
identity [2] 165/9
181/19
ie [4] 49/3 49/17
80/18 162/25
ie it [1] 49/17
ie push [1] 162/25
ie that [1] 49/3
ie very [1] 80/18
if [181] 2/8 2/23 3/22
5/13 10/22 11/23 15/8}
15/22 16/4 16/11 17/6}
19/1 19/17 22/21 23/2)
23/18 26/23 26/25
27/20 28/10 28/16
28/21 28/23 29/6
29/14 29/18 30/2 30/3)
31/4 32/7 32/9 33/24
34/2 37/2 37/14 38/17,
39/7 39/10 40/3 42/2
42/2 42/10 42/18 44/2)
44/25 47/22 49/8
49/12 49/14 51/6
51/11 53/23 53/23
54/9 54/19 55/1 55/7
56/20 57/20 57/22
58/8 58/22 59/4 61/6
62/9 64/21 65/12 66/9)
66/13 67/16 68/3 68/9)
68/19 69/6 70/2 70/3
70/15 70/24 71/1 72/8)
72/19 73/3 73/9 80/5
80/14 83/2 83/16
83/22 84/5 84/11
84/16 84/22 86/1
86/15 87/12 91/8
91/15 92/11 96/14
97/1 97/3 97/14 97/18
98/2 99/5 100/2 101/4,
104/10 105/15 107/7
110/23 115/13 115/25}
117/14 117/16 117/23}
118/9 123/20 125/1
126/4 127/17 127/20
128/2 130/8 133/1
133/9 134/6 138/17
138/23 138/24 139/20)
140/12 140/22 141/1
142/7 143/10 143/17
143/23 146/17 147/14)
147/19 149/10 149/22)
151/8 151/14 152/21
153/17 154/7 154/11
154/22 158/16 159/14)
161/18 163/2 163/4
165/18 166/19 167/4
168/5 168/6 168/12
169/9 170/18 171/18
174/20 174/25 175/6
178/21 179/18 179/21
179/22 180/20 182/3
182/11 184/12 187/10)
189/22 190/14 190/21
190/24 191/2
imagine [1] 165/5
immediate [3] 38/12
62/16 164/19
impact [6] 25/5 25/24)
29/19 96/1 114/13
159/13
imperative [1]
152/23
implemented [3]
80/10 94/10 115/14
implication [1]
101/21
implications [6] 53/2
53/21 55/6 79/7 128/8I
155/21
importance [5] 20/19
20/22 55/5 133/6
155/13
important [6] 56/12
69/10 80/21 81/10
119/2 129/5
impress [1] 155/12
impression [9] 8/20
10/18 11/5 11/10
11/11 11/22 32/12
32/17 93/8
improvements [1]
70/18
inaccuracies [1]
30/16
inadequately [1]
100/6
inappropriate [2]
136/8 153/1
inbox [1] 130/24
inception [2] 122/20
153/7
Incidentally [2]
159/17 159/22
incidents [1] 152/10
include [1] 118/1
included [2] 133/25
146/18
including [4] 54/12
78/16 168/1 172/17
(62) I have... - including
187/25
incorrect [2] 185/25
185/25
incorrectly [1]
138/10
increasing [1] 12/18
incredibly [1] 11/6
incurs [1] 134/12
indeed [5] 34/14
143/7 177/21 190/23
191/22
independent [10]
24/19 43/9 102/15
124/24 125/8 125/12
155/23
independently [1]
59/7
indicated [1] 78/17
indicates [1] 134/14
indicating [1] 46/13
indication [1] 61/12
indications [2] 61/8
74/25
indicative [1] 115/10
individual [11] 19/22
52/16 53/7 55/22
73/23 96/14 102/2
167/25
individually [3] 74/2
125/4 158/23
individuals [11]
52/17 62/25 63/12
63/23 124/22 128/4
132/9 148/14 170/7
183/2 183/10
industry [2] 50/9
52/11
inevitably [2] 153/17
154/17
infallibility [1] 76/4
infallible [6] 10/15
10/17 10/25 11/22
12/17 34/14
inflammatory [1]
133/14
inflated [1] 137/14
influence [1] 45/13
info [1] 98/6
inform [1] 117/1
information [71] 5/14
5/14 10/23 12/15
12/21 13/8 38/2 45/2
45/15 53/18 61/14
62/7 62/13 63/11
63/17 69/17 77/6
77/10 77/18 77/22
78/18 78/21 78/22
101/2 104/19 104/23
106/2 106/4 106/12
106/13 106/19 106/20}
108/1 111/8 111/13
incomplete [1]
126/10 126/16 126/21
126/23 137/19 139/15)
117/11 118/10 119/6
123/5 144/6 144/8
146/2 147/20 148/6
148/17 148/23 149/3
150/17 156/4 156/9
157/10 158/6 158/16
159/4 161/9 161/16
167/17 170/6 170/8
170/14 170/24 185/2
186/17 191/4 191/6
informed [5] 44/23
83/8 101/9 112/5
128/22
inherited [2] 43/24
44/1
initial [9] 2/13 2/17
20/24 24/24 61/14
64/25 148/23 149/3
188/3
initially [1] 191/12
initials [4] 147/13
injunctions [1] 5/10
injury [1] 5/12
input [1] 159/20
Inquiry [10] 3/18
19/17 27/11 51/19
61/24 62/19 150/8
insofar [3] 18/24
113/16 169/19
installation [1] 23/20
installed [4] 23/22
24/21 31/8 31/16
instance [3] 52/5
88/21 143/13
instead [1] 39/6
institution [1] 176/25
instruct [3] 32/3 35/5
174/8
instructed [10] 2/19
12/9 18/18 19/24 36/1
45/9 59/7 61/4 72/11
129/23
instructing [7] 18/1
33/24 35/16 35/17
45/8 131/5 174/10
instruction [4] 32/2
32/18 35/9 54/7
instructions [33]
18/23 35/6 44/13
44/16 44/20 45/24
46/22 52/7 57/7 57/16
57/20 63/13 63/17
82/6 83/10 83/15 84/3
100/23 126/25 163/21
164/2 164/17 172/20
179/8 188/8 188/9
188/12 188/22 188/23)
189/24 190/5 190/9
191/1
insufficient [1] 80/20
insurance [1] 55/25
integrity [12] 58/24
59/8 74/8 133/17
111/14 116/13 116/24,
165/13 166/12 166/25)
169/12 190/19 192/13)
149/12 149/20 150/4
150/25 153/2 156/15
157/9 168/3
intend [4] 16/22
122/15 138/21 140/2
intended [2] 72/18
73/5
intensive [1] 13/1
intention [2] 134/15
156/5
intentions [2] 34/10
184/23
interest [8] 16/25
37/5 63/6 63/7 95/8
132/10 146/11 152/4
interested [6] 63/2
101/6 132/4 132/12
159/12 176/14
interesting [1] 22/23
interfaces [3] 22/4
22/18 23/24
internal [3] 106/6
153/12 187/2
internally [3] 13/24
48/23 189/18
interpret [2] 123/18
166/12
interpretation [1]
124/18
interpreted [1]
139/14
interrupt [1] 161/18
intervention [2]
150/19 151/7
into [37] 2/24 12/8
12/25 14/22 16/24
29/18 31/20 39/17
50/25 57/2 57/9 60/2
72/10 81/3 82/2 91/7
92/9 93/24 101/8
150/4 150/25 151/25
156/8 156/13 157/21
159/16 159/20 162/3
introduced [1] 15/6
investigate [3] 78/12
78/20 190/13
investigate’ [1] 23/3
investigated [2]
123/12 149/13
investigating [3]
3/12 127/21 157/8
investigation [23]
97/21 122/23 124/18
126/11 149/1 149/4
149/5 149/19 150/4
150/13 150/25 153/13}
153/14 153/18 154/3
154/9 154/13 154/14
154/24 154/25 155/24
158/15 186/14
investigations [4]
97/23 110/22 148/24
intermittent [1] 23/12
126/15 130/23 135/23
148/20 149/12 149/19)
165/20 180/10 186/14
149/12
investigators [2]
146/4 148/19
invited [3] 151/15
151/20 155/19
inviting [2] 24/13
25/1
involve [1] 105/23
involved [26] 5/5
6/23 9/15 12/5 18/25
35/21 36/14 55/22
73/23 74/12 82/20
99/14 104/5 104/7
104/12 107/6 118/6
120/14 148/21 152/7
152/12 158/4 160/2
160/23 161/3 186/15
involvement [15]
17/16 17/17 19/10
1
97/14 99/16 116/19
119/24 120/6 120/24
140/2 158/7
involving [5] 3/5
86/10 107/8 175/13
180/5
irrelevance [1] 87/14
irrespective [2] 81/5
140/2
is [372]
Ismay [33] 13/15
13/20 14/7 62/18
66/13 70/12 118/11
121/5 121/9 121/17
122/2 131/19 133/10
133/10 133/19 134/9
138/25 139/6 139/11
139/22 147/17 157/20
157/22 158/7 158/15
159/1 159/8 160/25
184/9 185/4 185/7
185/10 186/11
Ismay report [1]
185/7
isn't [12] 4/2 24/1
40/17 43/4 56/12
60/16 65/10 68/24
137/4 150/11 186/15
186/23
isolated [1] 99/21
isolation [1] 43/15
issue [24] 3/4 35/6
37/9 45/5 45/24 46/22
49/18 51/2 65/24 66/1
76/16 91/5 92/11
106/16 114/1 115/9
122/23 129/11 129/23
129/25 130/8 138/3
146/9 154/20
issued [14] 18/10
35/20 39/23 40/1
44/17 45/18 45/21
45/24 77/12 101/24
125/17 127/2 128/14
130/5
issues [24] 21/25
29/12 36/21 95/4 95/8)
46/16 49/13 58/15
59/1 60/10 60/13
68/23 82/23 107/8
116/1 123/7 139/24
146/5 149/12 149/20
150/5 150/25 165/12
166/18 180/18 181/6
182/6 186/22
issuing [3] 5/10
44/24 131/11
Issy [1] 159/24
it [467]
it’ [1] 83/14
It'll [1] 38/20
it's [94] 12/1 12/2
19/16 21/6 27/5 27/7
27/15 27/15 30/4 32/4I
34/20 34/25 37/17
43/1 47/10 47/17
52/25 56/18 61/3 61/3
61/8 61/10 64/3 64/6
70/4 70/6 70/22 72/23}
74/21 79/22 79/25
80/12 84/7 85/22
86/22 86/24 87/7
88/16 88/18 89/13
89/16 90/10 92/22
95/5 97/12 97/16
99/25 105/1 105/3
108/8 112/2 114/1
117/15 131/13 131/21
131/22 131/25 132/1
132/2 132/15 134/4
137/16 139/13 140/10}
142/3 142/15 142/19
143/19 144/7 144/11
145/3 147/15 156/8
157/2 162/21 162/23
165/14 167/2 168/13
169/25 171/9 172/22
172/22 174/19 179/21
184/3 184/10 185/8
185/8 185/9 185/18
186/22 186/24 190/21
item [1] 103/2
itemised [1] 60/19
items [1] 7/4
its [12] 10/20 15/19
23/23 29/20 59/7
68/13 71/8 88/6 103/1
134/13 134/24 182/14)
itself [5] 5/23 13/14
51/1 84/14 185/19
qe
James [7] 100/25
101/5 101/9 101/17
101/21 128/13 129/2
Jan [7] 26/6 27/16
98/10 98/18 99/6 99/9I
99/10
January [6] 12/24
15/1 20/6 103/12
106/2 112/7
January 2004 [1]
20/6
(63) incomplete - January 2004
J
12/24
January 2020 [1]
106/2
Jarnail [6] 105/4
105/4 107/25 112/1
159/7 160/11
Jarnail Singh [2]
107/25 112/1
Jason [4] 144/25
145/5 145/22 158/10
Jason/Graham [1]
145/5
Jennifer [4] 38/11
42/4 121/9 121/18
Jennison [2] 37/20
38/1
Jim [8] 2/12 14/17
14/18 18/9 20/9 26/8
26/11 34/11
Jim's [1] 17/18
JMS1 [3] 46/8 46/10
46/16
Jo [2] 105/10 106/10
77/24 133/22 142/25
143/2 173/16
Joe [7] 7/24 8/2 8/18
93/13 97/5 182/9
182/16
John [4] 30/5 38/15
134/9 165/25
joined [5] 4/5 4/18
95/12 170/2 170/10
joint [4] 31/13 43/4
59/6 96/5
jointly [5] 19/24
jointly-appointed [1]
43/9
Jones [1] 4/16
Joseph [1] 92/23
Josephine [3] 99/25
100/14 102/3
journal [1] 134/21
Judge [1] 117/23
judging [1] 144/15
judgment [17] 35/19
36/6 55/2 64/9 64/21
81/9 88/25 108/18
128/10 128/16 132/24
134/16 134/19 135/24}
174/16 175/4 177/23
Julian [1] 46/8
Julie [2] 19/21
105/11
July [2] 30/8 58/14
jump [1] 3/22
jumped [1] 109/7
junior [1] 4/14
just [60] 9/11 13/12
21/2 27/6 27/7 32/1
34/23 34/24 48/19
49/14 53/7 58/25 65/9)
January 2011 [1]
job [8] 13/1 39/8 40/4
20/16 24/19 28/8 43/9
71/11 79/8 80/11
88/12 89/15 91/6
111/21 124/7 125/2
126/2 126/12 127/17
129/21 130/3 130/16
137/6 138/18 142/19
150/21 151/22 156/6
158/3 158/17 160/9
161/20 171/25 172/1
178/9 182/10 184/13
189/8 189/21 190/6
191/5
Justice [2] 109/8
159/23
justified [1] 173/5
K
Katherine [1] 93/5
[1] 93/5
keep [10] 26/24 27/8
27/14 28/18 71/23
72/1 92/13 92/16
100/25 161/1
57/9 94/5
Keith [10] 41/4 63/8
120/9 120/14 120/18
134/8
kept [3] 116/22
128/22 151/12
key [2] 147/1 170/7
kids [1] 87/13
kind [1] 145/13
kinds [5] 5/4 5/6
86/19 113/8 122/3
King [5] 38/10 38/16
42/3 147/17 157/4
knew [17] 40/12 65/5
71/12 88/22 92/12
101/6 116/3 116/4
116/5 139/23 141/21
143/5 143/8 143/9
4144/5 171/2 171/5
knocked [1] 163/11
know [44] 8/24 12/16
13/14 13/16 42/22
46/10 51/20 55/25
56/19 59/1 60/10
60/24 70/13 7/1
84/22 86/12 91/3 91/6
91/15 94/9 98/13
100/15 103/13 106/15
110/21 113/21 115/24
116/2 119/7 120/16
130/14 132/11 132/18
133/24 136/1 142/13
158/1 159/2 159/14
159/19 164/25 167/14)
81/11 82/7 83/7 84/24
130/23 132/18 135/13)
174/15 174/18 174/21
174/23 175/18 176/17,
justify [1] 36/18
Karl [1] 40/22
Katherine McAlerney
keeping [4] 19/1 50/4
98/6 98/7 120/2 120/6
171/6 189/22
knowing [5] 12/5
71/12 116/11 154/9
189/25
knowledge [23] 2/1
5/22 10/4 12/7 80/9
91/17 92/2 102/23
109/10 116/9 116/13
140/5 143/25 154/12
167/7 167/10 189/6
known [5] 19/16
65/23 106/15 123/13
164/22
L
lack [2] 16/17 82/3
lady [3] 100/22 104/2
159/24
land [1] 93/11
landing [1] 96/2
language [2] 103/21
131/2
large [6] 6/15 160/8
174/19 178/6 178/23
189/5
largest [1] 87/15
last [9] 44/15 57/25
83/12 89/20 169/22
189/5
late [3] 106/1 127/14
163/2
later [10] 72/10 77/13
79/22 81/6 83/20
88/17 93/21 99/24
137/15 138/4
latter [1] 95/23
Laura [2] 45/5 45/8
18/16 19/7 19/20
35/25 105/5 105/25
150/20 151/12 185/20
lawyer [16] 4/1 6/12
7/18 8/7 13/3 35/10
35/12 35/21 36/4
105/5 110/16 185/13
185/19 185/24 186/21
187/1
lawyers [7] 58/15
58/19 59/23 82/16
112/14 113/9 174/8
leader [7] 6/11 7/1
8/1 8/7 8/8 96/21
180/1
leadership [1]
119/25
leading [2] 124/13
130/7
learnt [1] 60/14
least [12] 76/16
135/9 164/15 168/19
173/4 174/5 188/16
123/18 126/24 131/16
154/19 154/23 160/19}
knows [1] 50/6
labour [4] 12/25
169/23 176/17 181/25
law [12] 6/6 8/14 8/15]
188/20 189/1 189/11
190/3 190/25
leave [4] 137/5 157/2
175/9 175/21
leaving [1] 17/19
led [2] 83/12 109/4
Lee [9] 34/17 76/13
77/20 86/2 105/9
128/4
left [7] 12/24 28/4
43/25 107/23 153/8
170/18 188/1
leg’ [1] 98/23
legal [45] 4/19 4/23
5/21 5/22 6/15 6/17
6/21 7/9 12/10 17/19
36/14 36/19 38/15
60/5 70/12 80/18 81/1
94/11 95/12 95/13
112/3 112/6 112/9
112/20 112/25 113/2
113/6 134/13 134/21
134/25 139/4 140/22
171/17 173/2
legalities [1] 80/20
Legg [1] 38/15
legislation [1] 181/22
legitimate [2] 89/6
89/6
Lenton [2] 2/21 26/7
Lenton-Smith [2]
2/21 26/7
less [5] 60/3 70/10
98/19 126/20 160/18
let [7] 16/1 113/21
132/18 159/14 159/18}
188/6 188/6
let's [9] 134/3 137/6
140/9 180/13 180/20
181/25 182/2 182/10
185/5
letter [18] 58/14
58/21 62/5 65/1 65/11
99/25 100/10 100/11
101/5 102/18 107/25
108/3 117/14 117/15
119/19 139/13 139/14}
191/14
letters [3] 133/15
133/15 140/7
level [4] 120/24
149/15 157/12 177/20}
levels [2] 80/15
172/2
liability [1] 27/7
liaise [5] 101/20
124/21 142/25 143/2
143/11
liaised [1] 143/21
liaison [3] 41/2 85/8
85/9
life [4] 53/2
114/22 122/14 125/17)
18/5 24/11 36/9 36/12)
82/2 82/17 85/1 88/14,
141/19 160/22 164/19)
light [7] 16/12 77/22
100/11 100/19 155/21
187/15 187/18
like [29] 2/4 8/14
27/17 29/2 35/5 47/12
48/12 58/17 68/15
69/15 78/11 78/12
79/9 79/25 80/11
85/24 89/10 89/13
94/18 114/22 119/1
119/19 122/5 124/7
130/18 145/13 162/22!
189/22 191/4
likelihood [1] 190/8
likely [9] 33/21 62/4
65/5 78/18 100/5
140/3 144/7 188/16
190/25
limitations [1] 187/7
limited [60] 14/4
14/11 16/9 18/4 18/11
18/22 31/15 32/6 34/8)
35/4 36/25 37/24
38/16 42/1 44/10 52/1
52/9 52/13 52/15 53/6I
57/8 64/23 66/19
67/10 67/20 68/21
69/10 69/13 69/16
69/19 72/4 73/12 74/7I
74/10 74/15 74/16
76/21 78/1 78/19
81/13 84/14 88/11
89/7 90/24 92/13
97/21 103/8 118/16
119/6 119/11 131/9
138/13 165/21 166/2
172/25 173/14 173/22)
174/12 175/25 181/17
Limited’ [1] 19/21
Limited's [1] 88/24
line [33] 15/16 30/10
38/12 49/25 50/9
50/10 50/15 51/8 54/7I
57/9 62/17 89/20
137/24 139/12 141/1
152/2 164/19 178/13
178/18 179/3 179/5
180/16 181/3 182/8
182/14 182/15 183/2
183/13 183/24 188/10)
189/13 189/19 190/4
lines [5] 22/20 104/41
106/23 138/6 171/3
link [1] 155/25
linked [1] 155/24
list [25] 23/14 62/12
62/15 66/12 70/4 70/6
78/15 86/1 104/22
114/2 121/12 121/16
126/5 126/8 126/14
127/8 131/18 131/24
132/6 133/2 133/3
134/8 147/12 186/17
191/23
listed [2] 105/17
107/3
(64) January 2011 - listed
L
lists [41] 121/24
litigate [3] 125/15
126/2 152/5
gated [1] 125/11
gating [1] 90/5
litigation [78] 3/13
4/21 6/11 7/21 7/22
8/6 9/10 9/14 10/2
14/3 14/23 18/25
28/13 35/21 41/25
54/4 54/24 55/13
55/15 55/24 57/5
57/14 62/18 72/2
73/10 73/21 74/17
76/20 77/25 82/21
84/19 85/7 85/21
85/22 88/13 90/2
90/16 90/19 90/25
91/16 92/21 95/7
95/18 96/22 97/6
165/3 169/20 171/10
179/9 180/2 180/2
180/9 180/12 181/11
181/18 182/9 183/5
191/12
litigator [3] 129/21
136/5 136/10
litigators [2] 142/20
152/3
litigious [1] 123/10
little [17] 24/22 30/19
31/23 32/14 48/19
57/18 98/3 99/16
103/20 122/10 128/7
167/4 168/13 172/18
174/25 175/6 178/9
locate [1] 104/1
locating [1] 122/24
locks [1] 22/1
lodge [1] 176/2
log [2] 22/9 23/9
logged [1] 122/19
logical [1] 184/5
logically [1] 114/12
logs [5] 16/10 21/18
23/5 24/6 28/4
London [2] 95/21
112/14
long [5] 8/1 52/14
112/1 134/22 155/2
longer [5] 5/20 28/3
59/15 77/8 113/3
look [85] 14/14 15/8
19/14 19/18 25/19
26/5 30/1 30/3 32/23
33/12 34/19 37/2
40/19 42/2 43/16 46/5)
Lister [1] 43/18
11/16 12/9 12/24 13/6)
51/22 51/23 52/6 53/8
109/19 109/25 129/19}
135/21 139/18 145/18)
148/18 155/11 155/16)
183/12 189/19 190/17)
48/15 53/12 56/17
78/2 79/21 80/5 83/1
83/22 84/5 84/16
86/22 89/11 89/13
91/8 92/22 94/14
94/15 97/11 97/15
99/23 103/3 107/6
117/13 117/15 120/1
121/7 123/1 126/4
127/17 128/2 131/13
131/15 132/14 133/9
134/3 136/21 136/22
137/6 139/12 140/9
141/6 141/25 142/2
151/6 151/8 152/17
156/7 157/11 157/20
159/5 162/19 162/22
164/4 165/14 167/15
169/13 169/21 185/5
looked [11] 14/14
20/2 21/4 48/16 79/1
131/14 131/22 132/7
135/18 142/1 174/22
looking [17] 6/8 12/4
13/10 41/10 58/13
77/4 77/17 97/14 99/7
105/13 106/8 108/21
114/12 121/6 156/14
156/18 163/17
looks [1] 186/12
lose [2] 42/18 50/13
loses [1] 42/16
loss [8] 39/7 67/18
68/1 137/13 138/7
138/11 138/12 138/14)
loss/gain [1] 138/12
losses [15] 15/3 15/5
15/11 15/25 16/15
16/18 17/1 31/9 37/6
37/7 102/1 109/14
109/15 132/21 132/23)
lost [2] 7/4 55/20
lot [8] 18/20 47/4
49/13 110/22 112/14
152/19 191/3 191/13
lots [4] 9/23 143/14
150/1 150/2
Lotus [1] 113/16
lower [1] 54/18
Lowther [4] 147/18
150/18 156/9 158/2
Ltd [2] 168/20 180/4
lunch [3] 25/18
107/12 111/21
lying [4] 11/23
made [32] 3/19 10/8
10/21 20/2 20/10
26/16 46/7 58/5 67/2
78/19 88/23 90/18
90/22 91/2 92/11
95/19 102/10 114/4
56/20 59/18 62/9 66/5)
66/9 70/2 74/19 76/11
146/16 146/17 149/10)
149/22 153/4 159/1
1814/5 187/6
magazine [1] 146/9
Magistrates [1]
100/17
Mail [18] 4/23 5/17
5/23 5/25 7/6 13/3
112/8 121/3 134/1
139/20 140/8 151/12
161/24 187/3
Mail/Post [2] 59/1
60/9
main [2] 58/6 88/24
maintain [2] 134/23
ATTN7
maintained [1] 97/10
Maitland [1] 58/3
major [2] 39/19 89/7
majority [1] 21/25
make [11] 2/6 2/8
15/4 72/21 76/3 88/2
124/7 130/10 163/6
169/7 171/4
makes [4] 37/8 129/6
134/3 138/7
making [16] 22/3
28/14 50/16 76/14
77/21 80/16 93/6
111/19 125/9 134/18
135/14 135/23 137/14]
144/10 144/13 192/12
malfunction [1]
66/23
malfunctioned [1]
30/15
manage [1] 26/20
management [10]
81/22 82/1 82/10
86/18 96/19 96/20
96/24 119/25 130/20
131/16
manager [21] 21/6
38/12 41/7 42/4 54/7
57/9 62/17 79/13 97/1
97/20 120/3 130/22
137/24 139/12 141/1
152/2 164/19 167/3
182/8 182/15 183/7
managers [13] 45/7
57/12 57/14 97/1
121/2 172/24 179/7
180/17 183/6 183/11
188/10 189/13 190/4
managing [3] 135/21
185/9 191/25
Manchester [1] 30/5
mandatory [1] 131/3
Mandy [35] 1/7 1/9
1/13 26/9 43/23 44/14
44/15 44/23 45/6 45/9
46/13 49/4 50/6 53/15)
79/14 83/23 98/6
114/15 116/14 118/15)
126/20 128/20 132/20
138/10 138/19 142/11
43/21 46/12 59/1 60/9
100/12 128/7 128/20
129/3 129/11 133/11
139/4 147/9 147/16
163/11 164/7 167/5
185/18 187/1 193/2
Mandy Talbot [1]
185/13
Mandy's [3] 26/19
45/4 49/11
manned [1] 30/11
manner [1] 90/15
Mantle [7] 7/25 8/5
8/19 147/17 152/3
182/24 186/4
manual [1] 46/15
manufactured [1]
132/23
manuscript [1]
137/24
110/11 110/12 129/7
139/19 179/6 179/8
183/14 192/13
March [5] 2/12 14/15
17/7 20/12 157/5
March 2004 [1] 17/7
Marine [4] 66/18
167/16 168/11 169/8
Marine Drive [3]
167/16 168/11 169/8
Mark [1] 83/3
marks [2] 50/2 50/3
Martyn [1] 86/24
Marx [4] 40/22 40/22
40/23 40/24
mass [3] 9/5 17/19
18/3
massive [3] 18/19
35/19 50/21
Masters [1] 180/5
material [9] 104/1
106/24 127/3 141/11
187/8 187/13 189/5
191/13 191/17
materials [2] 67/21
106/8
matter [33] 2/24 17/6
18/6 19/1 28/10 28/21
28/23 29/7 29/12
31/12 32/3 35/15
39/20 56/12 57/6
58/11 58/16 79/15
88/9 91/4 91/12 91/12,
93/14 102/3 109/24
125/17 128/8 128/23
134/17 135/3 136/3
166/20 176/1
matters [24] 3/13 5/9
7/3 7/19 8/11 11/19
18/5 25/1 42/1 58/13
81/21 82/5 85/9 94/20)
99/14 100/20 114/13
118/4 118/8 129/2
135/2 158/14 160/2
184/24
170/12 170/12 185/13)
many [10] 8/14 62/20
maximum [1] 47/7
may [49] 1/17 2/8
22/6 25/24 28/17 40/8I
45/4 49/21 53/13 54/6)
54/20 54/23 55/1
55/11 63/15 65/6
67/25 70/2 70/22
88/17 91/10 92/14
93/18 100/7 100/24
101/10 104/2 104/21
104/25 106/7 118/16
133/25 138/3 146/9
146/10 157/23 158/6
159/10 159/20 159/21
167/14 169/11 169/11
169/17 171/18 176/4
178/22 188/5 190/25
May 2006 [1] 53/13
maybe [5] 13/13
60/12 72/9 94/19
98/23
McAlerney [2] 93/5
93/10
McKenna [1] 4/10
me [58] 1/4 2/16 3/8
6/5 17/23 27/17 33/24I
35/18 45/9 47/5 53/6
59/3 61/18 65/9 65/18)
65/19 66/19 69/16
69/19 70/13 78/19
83/15 100/25 101/1
101/9 104/22 105/15
105/25 106/2 106/18
110/15 112/5 118/17
131/7 131/9 141/3
144/6 145/6 148/4
148/21 159/2 159/14
161/18 161/21 165/2
174/1 175/15 175/19
176/17 181/5 186/25
187/18 188/6 188/6
190/7 190/21 191/16
192/11
mean [17] 20/5 29/16
39/19 52/25 86/15
90/20 96/8 96/8 101/4I
110/10 110/16 121/25)
123/24 125/13 145/13)
187/25 190/22
means [5] 85/21
86/16 95/1 134/11
146/1
meant [5] 3/5 7/9
20/18 36/7 175/24
mediate [1] 51/12
mediation [2] 45/10
53/20
medication [2] 83/11
83/13
meeting [8] 135/6
149/24 151/16 156/22)
156/25 157/14 157/17)
157/24
meetings [1] 96/5
member [2] 14/19
14/20
(65) Lister - member
members [10] 6/21
28/5 112/11 113/1
127/23 141/18 143/15)
160/5 160/10 183/4
memo [1] 152/23
memory [4] 32/22
79/8 152/15 178/23
mental [6] 84/3 84/15)
91/7 91/9 92/4 92/15
mention [1] 60/21
mentioned [6] 14/7
68/7 93/22 170/16
175/12 178/8
mentioning [1]
142/22
mentions [1] 43/23
Mercer [1] 4/16
merely [4] 102/18
144/5 181/22 186/24
merit [2] 37/24 44/9
message [12] 22/11
22/12 52/11 55/6
55/10 55/11 55/19
56/13 65/4 108/21
167/2 167/3
messages [2] 157/11
159/17
met [2] 123/20
159/23
metaphorically [1]
177/3
methods [1] 88/14
Michele [7] 103/5
103/6 103/7 103/7
142/4 143/13 143/20
mid [1] 47/17
mid-morning [1]
477
middle [3] 86/24
95/23 100/3
might [28] 18/7 25/5
25/20 29/19 32/22
34/7 34/13 36/23
38/14 43/11 47/16
50/11 56/2 65/22
68/23 71/14 99/5
107/8 114/21 115/16
143/24 154/21 161/24
187/13 190/4 190/13
190/19 190/20
Mike [8] 118/11
159/8 159/12 159/16
159/19 160/25 161/6
185/4
mind [2] 29/14 172/4
minded [1] 96/16
mindset [1] 109/18
mine [1] 137/4
minimises [1] 17/25
minimum [1] 113/3
Minister [1] 159/23
minor [1] 10/19
minus [1] 23/7
minute [4] 27/15
136/2 171/19 171/23
minutes [4] 94/25
171/21 172/8 181/5
misbalancing [1]
168/22
Misra [25] 93/16
104/15 105/14 106/25)
108/12 108/17 108/18)
113/13 114/6 114/9
114/11 114/17 114/20)
115/3 115/4 115/24
116/8 116/9 118/15
144/14 159/10 160/13)
160/15 161/8 185/3
Misra's [1] 114/22
missing [6] 45/1 45/2
48/11 130/6 136/2
187/13
mistake [1] 161/19
mistaken [1] 66/24
mistresses [1] 178/7
misunderstood [1]
188/5
Mitchell [3] 86/25
167/23 168/25
Mm [19] 6/13 32/10
42/6 66/8 70/8 80/13
82/25 86/14 93/2 98/8)
98/16 102/7 103/19
120/23 122/6 126/7
148/12 165/17 185/15)
Mm-hm [15] 32/10
42/6 66/8 70/8 80/13
82/25 86/14 93/2 98/8
98/16 102/7 120/23
122/6 165/17 185/15
moment [3] 47/16
64/24 171/19
money [8] 12/10
26/20 45/20 49/2
66/19 110/14 118/15
153/9
monies [1] 46/11
month [4] 31/13
113/25 115/8 116/1
months [5] 4/7 25/9
112/15 113/3 135/10
months’ [3] 16/24
17/3 39/6
more [28] 3/1 25/10
25/22 29/12 37/15
43/13 54/17 70/9
70/13 85/25 98/19
101/3 112/5 120/7
129/5 129/8 134/23
137/21 140/3 146/5
147/25 152/10 160/5
160/10 162/12 176/14)
178/15 187/14
Morgan [4] 58/3 58/5
173/24 174/1
morning [10] 1/3 1/6
10/6 10/8 47/17 61/19)
115/13 125/3 128/12
178/10
morphed [2] 50/25
55/16
most [12] 22/3 22/17
58/22 80/6 82/4 82/4
113/20 114/5 121/15
126/14 149/17 191/20}
mother [1] 6/6
motivation [1] 51/16
mouth [6] 27/8 27/14
28/18 50/4 71/23 72/1
movable [3] 63/22
114/1 121/23
move [14] 34/17
47/15 58/6 78/24
82/22 94/23 108/6
111/20 119/23 121/5
121/23 127/25 144/16}
161/12
moved [2] 112/7
135/19
moving [3] 9/24
120/3 162/3
MR [129] 1/10 2/12
2/13 2/16 2/17 2/22
3/2 6/9 7/24 13/20
14/7 17/15 19/15
19/17 19/23 21/4
21/15 24/4 24/10
24/13 27/22 29/2 35/7
35/24 37/1 37/6 37/19
37/23 44/4 44/8 47/11
47/20 48/16 50/6
50/15 50/17 51/8 51/9
51/18 52/4 53/19
55/21 59/13 60/24
60/25 61/11 64/10
65/1 65/17 66/14
66/17 68/11 69/5
69/15 70/12 71/2 72/1
72/5 73/3 74/22 75/20
77/12 78/16 78/16
78/23 81/4 82/23 83/7
83/21 84/2 88/3 88/7
88/18 88/24 89/4 89/5
89/23 91/25 92/17
93/25 94/18 95/2
96/23 101/18 105/24
106/18 115/12 115/24
118/11 123/3 125/17
127/7 132/10 132/12
132/20 134/5 155/8
156/2 157/22 158/7
160/11 162/18 162/21
163/16 172/1 172/5
172/14 172/18 173/9
173/24 174/1 174/7
174/7 175/8 175/14
175/17 177/4 178/3
178/4 178/15 186/19
188/4 189/9 189/10
189/14 191/13 192/3
193/4 193/8
Mr Bajaj [2] 123/3
174/7
Mr Bilkhu [1] 174/7
MR BLAKE [8] 1/10
47/20 69/15 95/2
172/5 178/15 186/19
193/4
Mr Brown [1] 78/16
Mr Castleton [40]
35/7 37/6 37/19 44/4
47/11 50/6 50/15
50/17 51/8 51/9 53/19)
55/21 64/10 66/14
68/11 69/5 72/1 72/5
73/3 75/20 77/12
78/16 83/7 88/3 88/24
89/4 89/5 89/23 91/25
94/18 132/10 132/12
132/20 134/5 162/18
172/18 173/9 175/8
175/14 175/17
Mr Castleton's [15]
6/9 37/23 44/8 52/4
81/4 82/23 83/21 84/2
88/7 92/17 93/25
101/18 163/16 177/4
189/9
Mr Coyne [11] 3/2
19/17 19/23 21/4
21/15 24/4 24/10
24/13 27/22 59/13
188/4
Mr Coyne's [3] 2/13
2/17 19/15
Mr Cruise [2] 2/16
17/15
Mr David [1] 192/3
Mr Dhale [1] 115/24
Mr Dilley [14] 35/24
37/1 48/16 60/24
61/11 65/1 65/17 71/2
74/22 78/23 162/21
172/1 189/10 189/14
Mr Dilley's [2] 60/25
88/18
Mr Doug [1] 155/8
Mr Greening [1]
115/12
Mr Holmes [2] 2/22
29/2
Mr Ismay [4] 14/7
70/12 157/22 158/7
Mr Jarnail Singh [1]
160/11
Mr Jim [1] 2/12
Mr Joe [1] 7/24
Mr L [4] 66/17
Mr Lee [1] 125/17
Mr Morgan [2]
173/24 174/1
Mr Phil [1] 105/24
Mr Rob [1] 96/23
Mr Rod [2] 13/20
118/11
Mr Singh [1] 106/18
Mr Stein [4] 172/14
178/3 178/4 193/8
Mr Stephen [2] 51/18
191/13
Mr Tony [1] 127/7
Mr Wilson [1] 156/2
Mrs [35] 1/13 1/14
3/16 14/25 15/10
16/23 17/8 19/21
19/25 21/9 21/21 22/3)
22/8 27/25 28/16 29/3
30/13 30/21 31/3 31/6I
33/1 33/17 48/3 70/2
89/12 107/23 142/14
143/10 172/16 178/5
178/21 187/6 187/12
187/19 187/23
Mrs Julie
Wolstenholme [1]
19/21
Mrs Mandy [1] 1/13
Mrs Nixon [2] 142/14
143/10
Mrs Talbot [13] 1/14
3/16 28/16 48/3 70/2
107/23 172/16 178/5
178/21 187/6 187/12
187/19 187/23
Mrs Talbot's [1]
89/12
Mrs Wolstenholme
[14] 14/25 15/10
16/23 17/8 19/25 21/9}
21/21 22/8 27/25 29/3}
30/13 30/21 31/6
33/17
Mrs Wolstenholme's
[3] 22/3 31/3 33/1
Ms [12] 21/5 22/6
35/8 92/1 100/5 102/3
104/15 115/24 172/14)
172/15 181/23 193/6
Ms Elaine [1] 21/5
Ms Hamilton [1]
100/5
Ms Josephine [1]
102/3
Ms Misra [2] 104/15
115/24
Ms Page [1] 172/14
Ms Tagg [1] 22/6
Ms Woodward [3]
35/8 92/1 181/23
MT [5] 46/12 46/25
147/8 147/9 147/16
much [32] 1/6 1/11
1/25 3/16 16/5 25/10
27/8 27/13 29/12 34/2I
40/17 43/19 54/18
68/15 69/16 77/13
78/21 103/21 107/16
113/21 116/6 116/22
125/3 130/18 132/2
134/19 145/13 157/3
160/16 160/18 192/9
192/16
must [13] 33/3 37/12
49/12 50/9 52/15
52/24 66/21 69/17
128/21 149/8 150/7
173/21 176/25
my [84] 2/10 3/3 3/3
(66) members - my
my... [81] 4/14 6/5
6/6 6/20 9/1 9/2 11/7
13/12 14/19 17/17
20/2 21/16 23/21 34/9
38/12 39/19 44/23
46/4 50/19 54/7 57/9
58/1 60/14 60/20
62/16 69/14 75/22
77/24 81/11 82/12
85/7 91/17 92/9 94/22]
96/21 103/22 105/14
106/21 109/21 116/16
119/13 119/20 125/10
126/12 129/19 129/21
130/24 131/7 137/10
137/24 139/10 139/11
1441/1 143/2 150/21
152/2 152/6 152/15
153/1 154/11 156/3
156/6 159/3 161/24
164/18 165/20 167/7
167/21 168/20 173/15
178/5 179/9 179/9
180/16 181/10 182/8
183/7 183/20 186/25
187/19 189/6
myself [11] 8/12 8/14
18/21 27/19 60/19
74/16 75/22 126/1
139/11 169/22 173/14
N
name [21] 1/12 1/17
7/2 11/4 11/23 40/25
52/15 53/25 57/1
57/11 93/16 120/22
138/15 139/22 145/3
178/5 179/10 179/13
180/11 186/25 191/2
named [2] 63/12
107/1
namely [1] 105/9
names [9] 25/15
66/12 121/25 131/18
131/18 134/8 143/6
143/24 166/7
naming [1] 190/6
Napier [2] 92/24
92/24
natural [1] 47/18
nature [2] 148/1
155/17
near [2] 58/21 168/12
nearest [1] 127/6
nearly [1] 54/12
necessarily [1] 51/9
necessary [6] 6/5
29/9 123/16 124/12
125/1 163/4
need [16] 28/22 49/5
49/24 51/7 98/19
117/21 118/23 134/18}
138/13 153/10 155/12)
163/3 172/4 176/2
178/12 188/9
needed [6] 52/10
81/21 139/21 152/23
173/1 175/17
needs [2] 167/17
168/21
negative [5] 31/22
32/13 32/24 33/25
49/3
negligence [1] 37/8
negotiations [3]
29/10 131/23 132/1
neither [3] 9/10
181/12 181/13
net [1] 37/6
network [6] 18/21
21/6 64/12 123/23
123/25 124/6
never [24] 7/21 41/24
59/18 60/2 79/19
82/12 91/16 92/12
92/19 94/4 94/14
106/11 119/19 120/21
129/11 129/25 130/22)
140/24 149/22 160/23)
161/20 161/25 180/18
182/5
new [2] 153/6 180/11
news [7] 64/1 128/17
131/20 133/11 175/3
175/23 176/8
next [16] 16/4 16/19
45/4 57/22 90/9 90/13
97/19 109/6 133/12
147/2 159/13 160/12
160/13 175/20 180/7
180/13
Nicky [2] 38/10 38/13
nine [1] 112/15
Nixon [2] 142/14
143/10
no [122] 4/14 5/20
6/4 6/23 7/20 8/9 9/19
19/10 20/8 25/25 26/3
26/4 28/3 28/20 28/22
29/16 29/23 29/25
34/15 35/13 39/19
40/18 40/24 43/1
45/17 46/2 49/3 51/22
51/24 53/9 53/11 59/1
59/9 59/15 60/10
61/17 63/23 68/17
71/11 72/2 73/20 74/9
75/18 79/19 80/3 80/9)
81/8 81/15 81/17
81/20 81/21 81/24
86/20 87/23 88/20
90/21 94/4 95/7 96/9
99/17 101/2 101/14
101/14 102/13 102/25)
107/10 110/15 110/15)
111/10 112/5 117/12
121/22 123/14 126/17)
127/12 131/7 132/21
134/14 134/22 136/20)
137/23 141/12 141/12)
141/24 146/22 148/4
148/16 151/17 151/19}
157/8 158/6 158/7
158/19 163/22 168/6
169/17 174/17 176/22
177/10 178/19 179/13
179/15 180/3 180/15
180/24 181/8 182/17
182/19 182/20 182/21
182/23 182/25 183/15}
183/17 184/22 185/17)
186/6 186/7 186/24
187/17 189/6 192/7
nodded [1] 41/9
Noel [1] 105/10
noises [1] 93/6
non [1] 13/3
none [2] 183/1
183/12
nonentity [1] 7/10
normal [4] 88/13
90/5 92/20 98/22
not [166] 3/4 7/20
9/10 10/17 12/16
12/20 13/7 15/14 16/1
16/12 16/13 18/18
20/1 20/2 20/8 21/13
21/16 22/2 23/14 24/3
24/21 25/23 26/21
26/23 28/24 29/5 29/7
29/11 29/14 30/9 32/2
32/3 32/5 34/12 34/13
35/10 39/8 40/3 40/22
41/23 42/7 43/1 45/5
46/15 46/21 47/14
49/12 51/5 52/24 53/6
54/15 54/16 55/25
56/15 56/18 59/9
60/12 60/20 62/22
63/24 65/2 65/2 67/1
67/13 70/25 71/18
72/6 72/16 73/4 73/6
73/10 73/15 73/18
74/11 75/14 75/17
76/3 76/14 77/7 77/21
79/15 79/17 83/14
85/20 87/12 90/14
91/13 91/15 92/3
92/20 93/7 93/25
94/12 94/16 96/12
100/9 100/21 101/8
101/24 102/13 108/14
110/3 110/15 110/16
110/20 115/10 118/14
119/22 123/20 127/21
128/13 129/14 129/19}
129/24 132/1 133/1
134/11 136/4 137/9
138/21 140/12 140/17!
141/12 141/22 143/2
144/22 146/22 150/19}
151/23 152/8 152/11
152/23 153/6 153/10
153/18 154/4 155/5
155/19 157/23 158/1
158/20 160/20 166/16
167/10 167/12 169/11
170/21 1714/2 171/17
172/22 173/14 175/9
175/21 176/22 177/2
17716 177/7 17/9
179/16 184/1 184/19
184/21 186/5 186/8
186/24 190/2
note [9] 46/7 48/16
80/21 90/1 131/25
147/23 162/20 164/5
169/24
84/7
notes [2] 22/10
113/16
nothing [12] 29/17
29/22 32/9 32/17
36/15 48/13 48/14
51/7 109/23 110/6
142/13 161/21
notice [4] 17/4 33/20
39/6 171/25
notices [1] 15/13
notified [1] 86/16
notify [2] 85/15 86/18
November [16] 22/6
22/24 30/21 43/17
46/6 62/10 62/11 64/4)
65/10 65/11 65/15
66/6 66/11 83/16
83/20 123/4
November 2000 [2]
22/24 30/21
now [71] 2/4 2/7 2/11
2/16 2/20 3/8 3/20
12/5 14/7 17/1 20/4
26/11 27/10 27/12
31/12 31/25 34/2
36/10 41/21 42/22
45/12 47/15 50/16
53/12 55/11 56/8
56/22 60/23 62/10
66/23 76/4 77/4 78/2
79/9 85/19 86/21 87/7
88/17 89/15 92/25
100/13 106/10 108/12)
108/13 110/20 114/7
118/14 120/3 125/21
129/14 132/17 134/4
136/22 139/6 142/15
142/20 145/19 145/21
146/18 152/11 155/16
159/5 159/6 161/13
178/21 179/25 180/13}
184/7 184/14 185/7
185/12
number [26] 6/15 7/8
8/22 9/15 10/6 14/21
23/5 31/1 54/9 62/2
105/13 106/25 114/19}
124/22 127/22 128/20}
159/22 162/15 169/12)
172/16 178/6 178/14
178/24 190/14 190/14}
191/23
noted [3] 23/10 23/17I
number 1 [1] 190/14
Number 2 [1] 190/14
number 4 [1] 54/9
numbers [2] 112/17
115/17
numerous [3] 11/12
11/18 113/19
fe)
objection [1] 134/22
objective [1] 176/22
obligations [2] 30/24
112/23
obliged [1] 110/18
observations [1]
20/24
obtain [10] 12/10
17/5 99/3 111/13
118/18 162/7 166/22
166/25 167/8 171/13
obtained [8] 12/14
31/14 37/19 39/3 44/4
64/21 164/1 166/12
obtaining [5] 76/19
82/6 165/12 170/5
170/14
obviously [2] 12/4
185/7
occasion [4] 98/24
112/6 131/25 143/19
occasions [2] 82/18
189/11
occur [4] 23/16 72/23}
72/25 131/12
occurred [9] 19/2
26/1 36/9 72/17
132/22 136/7 149/22
150/7 159/15
occurring [1] 23/12
October [5] 23/4
36/20 159/6 159/6
162/23
October 2005 [1]
36/20
odd [1] 143/15
off [8] 50/20 78/10
80/15 80/17 80/25
107/23 115/21 168/21
offenders [1] 154/8
offer [8] 6/22 9/5
16/7 26/15 45/10
59/17 127/7 167/19
offered [2] 6/18 8/24
offers [1] 51/12
office [191] 4/1 4/6
4/18 5/6 5/13 13/25
14/4 14/11 15/7 16/2
16/20 16/23 17/3
17/13 18/1 18/4 18/10)
18/22 19/20 19/24
23/22 26/17 30/18
30/24 31/3 31/8 31/16
31/21 32/6 32/12 33/6
33/10 33/16 33/19
33/24 34/2 34/8 35/4
35/10 35/22 36/24
(67) my... - office
[e)
office... [150] 37/8
37/12 38/16 38/25
40/15 41/8 42/1 42/3
42/18 43/13 48/23
48/25 49/7 49/11
49/15 49/22 49/24
51/25 52/8 52/13
52/15 52/24 53/5
55/20 57/1 57/8 59/1
66/18 66/19 66/21
67/10 67/19 67/20
69/13 69/16 69/18
70/7 72/4 73/12 74/7
74/10 74/14 74/15
75/25 76/21 78/1 78/8
78/19 81/12 81/23
82/2 82/8 84/11 84/13,
84/17 85/5 86/17
86/25 88/1 88/6 88/11
88/23 89/7 89/21 90/4
90/15 90/21 90/24
91/13 91/21 92/13
94/12 97/8 97/21
98/12 103/8 104/2
106/8 112/10 115/5
115/6 118/16 119/3
119/11 119/25 122/22)
123/21 124/21 125/7
131/8 135/20 138/3
138/13 138/21 140/18
141/17 141/19 142/12)
142/17 142/23 143/1
143/3 143/5 143/6
143/12 143/16 143/18
143/22 144/1 144/4
152/1 152/14 160/6
163/14 163/24 164/9
164/15 164/21 166/14}
167/4 167/9 167/14
168/22 170/2 170/5
170/10 172/25 173/14
173/22 174/11 175/24}
178/11 180/4 181/17
182/13 184/17 188/11
192/3
Office's [10] 34/10
37/4 44/5 49/2 50/8
55/5 63/14 64/18
132/4 184/23
officer [1] 121/16
officers [1] 57/8
often [3] 142/25
143/3 191/23
oh [6] 25/16 65/10
99/10 99/22 119/17
192/5
OK [1] 139/5
okay [16] 13/23
25/18 47/23 62/16
79/21 121/5 157/19
165/11 171/24 179/13)
53/25 54/19 55/1 55/8)
60/10 61/5 62/4 64/22
68/2 68/21 69/1 69/10
179/18 180/20 182/10)
184/6 184/22 185/5
old [1] 98/14
older [1] 148/10
on [277]
once [3] 55/10
149/13 160/21
one [42] 4/1 6/11
9/22 17/22 22/10
31/12 35/3 37/15
37/19 37/20 45/18
47/6 58/15 58/23
76/16 78/10 86/7
94/19 96/4 110/6
119/19 127/21 136/6
136/14 152/10 157/41
167/22 169/4 171/7
174/18 174/18 174/24)
179/13 179/16 181/9
183/7 187/4 188/17
190/15 191/20 191/25)
192/7
one/two [1] 47/6
ongoing [6] 113/25
115/8 115/25 144/9
145/23 154/9
only [37] 6/21 14/2
18/11 21/20 28/9
53/24 56/25 59/21
63/5 74/25 92/10
96/10 96/16 106/13
106/20 110/1 110/18
113/15 114/14 115/19)
116/17 120/9 135/16
136/1 136/6 136/11
137/11 141/20 148/16)
152/23 153/8 156/3
160/24 163/13 171/5
174/19 188/2
onwards [2] 127/5
162/2
Ooh [1] 4/5
open [6] 24/13 24/25
154/15 155/1 180/17
187/5
open-door [1] 180/17
operate [2] 18/14
30/9
operated [1] 180/17
operates [1] 59/3
operation [2] 21/13
22/9
operative [1] 23/11
operator [2] 22/13
23/1
opinion [24] 2/17 9/2
13/13 21/16 22/15
23/19 23/21 24/10
25/24 27/6 34/9 59/12
68/3 69/14 81/12
82/12 86/9 111/10
126/13 150/22 153/25)
156/3 156/6 168/20
opportunities [2]
88/8 110/23
opportunity [1] 24/8
opposed [1] 187/25
option [1] 27/1
6/11 8/7 9/7 9/10 9/11
9/17 10/19 11/17
16/23 19/2 20/24
21/18 22/5 22/18
41/2 52/17 54/7 55/8
62/6 62/23 63/3 63/7
69/18 71/8 71/23
78/11 80/19 82/5
82/21 84/14 84/23
86/3 90/16 90/17 91/1
91/7 91/9 92/4 92/15
92/16 94/5 95/8 96/8
96/15 96/21 98/19
99/14 102/11 104/21
105/17 105/22 106/1
107/4 108/14 108/17
109/11 110/12 117/3
117/4 117/14 117/24
126/22 127/7 127/21
129/20 131/4 132/5
133/3 137/13 137/20
139/11 140/3 141/15
142/14 143/10 144/4
144/19 148/14 152/25)
153/9 157/9 157/24
158/20 160/23 162/2
165/12 166/1 166/13
167/12 167/12 169/11
170/17 173/14 174/11
177/21 180/4 181/3
181/8 186/13 188/10
188/12 189/13 191/9
191/19
orally [1] 188/13
order [11] 45/23 56/3
72/9 72/12 84/1 88/9
96/15 101/25 118/14
162/7 176/3
ordinarily [2] 47/5
94/17
ordinary [3] 136/5
136/10 166/24
ordination [1] 129/15
Orford [1] 145/24
organisation [4] 82/9
164/21 179/6 179/7
organisations [2]
11/9 82/4
original [19] 2/10
20/2 27/23 27/25 28/1
28/2 35/15 35/16
38/21 59/15 87/8
151/16 151/20 156/5
156/18 156/22 156/25}
158/2 161/20
originally [2] 97/16
151/1
ostensibly [1] 75/13
or [125] 4/12 4/15 6/3
22/19 23/24 24/4 29/5
31/2 36/13 37/8 37/10
63/17 63/17 65/2 69/6
118/14 119/24 120/19}
122/18 124/22 126/19}
other [60] 4/12 5/6
6/6 10/3 11/9 13/21
15/20 16/2 30/16
49/17 50/7 55/7 55/12)
58/23 60/15 64/15
65/4 65/21 67/23
68/22 82/18 85/10
88/4 90/8 94/6 96/4
98/25 101/22 105/16
106/6 107/2 109/12
110/8 114/20 117/4
117/21 118/8 118/23
119/9 119/10 122/16
123/5 127/19 132/3
138/2 143/23 146/4
162/25 163/9 163/24
173/9 184/3 185/10
186/18 188/11 189/13}
190/4 190/5 190/24
191/10
others [4] 70/14
119/3 121/6 142/5
otherwise [1] 162/14
ought [1] 188/19
our [29] 16/16 18/5
18/13 19/4 32/4 42/16}
47/17 51/4 53/16
53/17 61/13 96/10
104/4 106/8 112/23
112/25 134/10 139/17]
142/11 146/25 147/12
153/9 153/10 156/16
163/1 163/8 170/11
174/13 184/15
ourselves [1] 96/18
out [43] 3/13 3/22
17/21 18/5 18/12
18/17 26/24 52/2 55/7,
55/12 55/19 56/14
58/1 63/23 66/25 67/7,
67/8 67/14 82/15 91/4
91/12 91/25 95/14
98/22 101/4 107/5
114/23 115/17 121/24}
125/8 126/11 148/25
150/24 152/22 153/18}
154/2 156/20 157/24
158/2 174/12 177/11
188/1 190/17
outage [1] 78/11
outlined [1] 170/11
outlines [1] 128/5
outlining [1] 148/25
Outlook [1] 113/17
outside [1] 14/8
outsourcing [1]
36/16
outstanding [4]
46/12 96/13 127/16
135/2
outweighs [1] 80/18
over [45] 5/1 11/12
14/22 15/15 22/14
23/18 25/18 31/4
31/18 35/14 35/18
37/14 37/15 37/17
pack [2] 86/23 157/2
38/18 38/20 57/22
59/18 63/25 64/1 64/5I
85/8 87/14 90/13
107/7 112/7 113/17
116/15 117/15 118/15}
121/2 122/24 138/17
138/24 140/16 140/20)
141/9 143/15 147/15
158/12 163/22 167/18}
170/20 175/1 183/11
over/under [3]
140/16 140/20 141/9
overcome [2] 176/12
177/1
overpowered [1]
176/19
overriding [1] 41/24
oversight [1] 9/17
overturned [1] 98/15
overview [3] 9/8 58/4
81/13
overwhelm [1] 89/23
owed [1] 66/19
own [14] 52/11 65/23
68/14 76/16 82/12
110/21 119/16 119/20)
131/3 134/13 141/20
168/20 173/7 187/11
Pp
page [121] 1/21 1/21
1/23 12/1 12/3 15/15
19/18 21/2 22/14
22/22 23/18 30/3 30/3}
30/4 30/7 31/4 31/18
33/13 33/13 34/20
34/21 37/14 37/15
37/16 37/16 37/17
38/7 38/7 38/18 38/18}
38/20 40/19 40/20
42/2 42/3 42/10 42/11
44/12 56/19 56/20
56/22 57/22 58/9 61/6I
61/7 63/25 64/1 64/6
66/9 66/10 70/5 71/1
74/21 80/1 80/12
85/12 85/13 86/22
86/23 89/13 89/16
89/18 90/10 90/12
90/12 90/13 92/23
97/12 97/19 98/3 98/3}
98/4 100/3 103/4
103/5 108/9 117/15
117/16 121/7 123/2
126/4 127/18 127/19
131/13 131/15 131/17)
132/14 132/15 132/16)
133/15 134/7 136/23
136/24 138/17 138/18)
138/23 138/24 138/25)
140/9 142/2 142/3
142/7 144/20 144/21
145/20 146/16 147/16)
151/6 151/8 152/17
156/8 157/3 165/15
(68) office... - page
P
page... [8] 167/18
168/7 169/4 172/14
172/15 179/22 182/1
193/6
page 1 [7] 42/3
117/16 138/23 142/7
151/6 151/8 152/17
page 15 [2] 33/13
157/3
page 16 [1] 33/13
page 17 [2] 80/1
80/12
page 18 [1] 30/3
page 19 [2] 89/13
89/16
page 2 [7] 19/18
66/10 70/5 97/12 98/3
138/25 179/22
page 21 [2] 90/10
90/12
page 25 [1] 145/20
page 27 [2] 12/1
144/20
page 3 [8] 42/10
42/11 66/9 108/9
121/7 126/4 146/16
182/1
page 33 [1] 132/14
page 36 [1] 1/21
page 4 [1] 74/21
page 5 [7] 38/7 38/7
64/6 103/4 103/5
127/19 142/2
page 6 [1] 165/15
page 63 [3] 131/13
131/15 131/17
page 65 [2] 56/20
56/22
page 7 [4] 34/20
38/18 86/22 86/23
page 9 [1] 156/8
pages [4] 2/9 38/22
174/21 175/1
pages 33 [1] 174/21
paper [4] 39/24 45/22!
48/11 166/13
papers [3] 25/19
119/13 131/14
paragraph [46] 3/3
12/2 15/2 15/8 15/22
15/23 16/4 16/19
16/21 30/7 31/5 31/11
31/18 32/23 33/12
37/2 37/21 41/12 44/2
45/1 49/21 52/2 56/11
61/8 64/7 90/9 90/10
91/8 93/3 95/6 100/4
109/6 122/12 123/1
133/12 154/7 162/21
163/17 168/2 175/7
176/17 179/22 179/23}
181/10 182/1 182/1
paragraph 1 [1]
49/21
paragraph 10 [1]
31/5
Paragraph 11 [1]
31/11
paragraph 13 [1]
31/18
paragraph 17 [1]
32/23
paragraph 2 [1] 52/2
Paragraph 24 [1] 3/3
paragraph 3 [1]
162/21
paragraph 4 [1] 30/7
paragraph 44 [2]
90/10 91/8
paragraph 49 [1]
33/12
Paragraph 5 [1]
56/11
paragraph 54 [1]
95/6
paragraph 62 [1]
12/2
paragraph 7 [4]
179/22 179/23 181/10)
182/1
paragraphs [3] 22/22
48/20 92/10
parallels [1] 73/15
pardon [2] 110/15
192/5
part [22] 5/16 9/3
15/21 17/18 89/7
94/21 97/23 112/22
118/17 122/13 133/22)
139/17 142/25 143/2
155/19 158/15 174/19)
174/22 176/23 177/22!
181/25 185/6
partial [4] 51/20
187/9 187/24 188/2
Participants [1]
162/16
participated [1] 63/8
particular [28] 10/24
11/13 11/16 11/21
31/21 52/5 62/25 63/2
63/23 79/9 79/24
86/13 91/21 99/13
103/1 106/15 108/7
111/4 122/2 131/24
131/24 139/16 139/23}
143/11 143/17 161/5
164/16 185/6
particularly [6] 33/23
41/18 63/24 88/22
132/11 133/4
parties [9] 7/5 63/10
78/15 118/11 124/11
136/12 165/10 181/19)
190/16
partly [2] 53/19 129/7
partner [4] 43/20
90/6 92/24 149/18
partners [1] 13/21
parts [3] 9/24 21/3
132/3
party [5] 35/17 84/11
84/15 90/22 90/22
pass [3] 57/16 60/4
63/13
passage [1] 70/16
passed [4] 62/6
79/13 158/14 167/2
passing [7] 17/20
17/23 38/2 59/23 64/1
69/22 131/20
past [3] 140/23
147/20 147/24
pause [5] 24/22
75/17 78/14 107/12
116/7
paused [1] 108/16
pausing [5] 49/19
90/4 98/13 125/2
153/22
pay [5] 16/23 16/23
111/2 118/15 134/6
payments [3] 140/16
140/21 141/10
payout [1] 47/12
Pearce [19] 3/4 35/5
35/25 44/17 46/8 46/9
56/24 57/7 84/18 85/8
85/15 85/23 92/1
101/20 129/18 129/22
131/5 175/15 176/18
pending [3] 108/16
114/16 114/17
people [38] 7/8 9/23
25/13 36/24 38/9 43/2
43/6 43/13 62/20 63/6
63/20 70/7 70/9 92/16
99/18 110/7 113/7
121/10 121/23 132/3
136/15 140/12 140/23
143/6 158/13 166/16
166/18 175/2 175/16
178/24 179/8 182/2
182/10 182/14 185/10
191/11 191/15 191/21
per [4] 17/2 100/21
168/24 170/17
percentage [1]
127/12
perfect [3] 10/19
103/18 103/23
performed [1] 7/14
performing [4] 38/14
160/9 161/11 185/1
perhaps [7] 25/18
30/7 32/22 47/18
122/10 123/1 168/9
period [28] 4/8 11/24
25/9 25/16 25/23
32/19 42/9 43/12
52/18 63/4 69/8 76/1
81/25 87/23 103/10
112/15 113/2 113/9
143/22 143/25 144/15}
158/18 164/2 165/10
172/23 173/6 183/11
192/4
periods [1] 47/8
permanent [2] 7/15
112/11
permission [1]
134/20
permitted [1] 36/6
permitting [2] 35/19
36/17
persisted [1] 21/9
persistent [1] 153/4
person [7] 57/5
69/18 126/14 155/7
179/10 188/21 189/25}
personal [4] 5/12
53/7 82/12 116/17
personally [7] 20/8
47/6 76/22 111/18
141/21 161/9 173/18
personnel [2] 30/11
188/19
persons [3] 69/18
166/23 191/19
perspective [3]
23/21 76/21 167/20
persuade [2] 125/20
125/23
persuasive [2] 28/12
66/4
pertaining [1] 7/3
Phil [4] 105/24
photocopied [1]
38/22
phrase [3] 29/5 42/24I
44/21
physical [6] 84/14
91/7 91/9 92/4 92/15
95/11
physically [4] 39/7
42/17 95/17 95/24
pick [1] 108/13
pie [2] 45/23 101/25
piece [7] 11/16 52/5
147/3 148/7 149/10
150/20 175/23
pile [3] 56/18 144/17
144/19
pin [1] 191/18
inder's [1] 167/23
pivotal [1] 58/15
place [19] 23/14 33/1
33/4 39/24 39/25
45/25 81/17 112/23
116/12 117/9 123/15
125/25 130/6 130/11
146/10 147/6 155/18
156/19 190/17
places [1] 95/22
plain [2] 10/21 49/6
play [2] 58/12 162/24
pleadings [1] 24/6
please [94] 1/12 2/6
3/23 12/1 14/15 14/16
14/18 15/15 19/18
21/2 22/14 23/18
25/15 26/5 30/1 30/1
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pleased [1] 176/11
plus [3] 16/25 28/2
37/5
pm [7] 107/17 107/19
145/21 157/6 172/10
172/12 192/19
PO [1] 168/20
PO Ltd [1] 168/20
POCA [1] 162/6
point [18] 6/11 31/1
34/12 55/21 58/5
58/23 59/5 60/12
60/19 101/12 107/5
134/4 139/25 150/9
151/23 172/18 175/20)
177/18
pointed [1] 164/25
points [3] 3/22 58/1
58/18
POL [48] 3/10 11/20
12/10 13/14 16/14
17/1 19/5 29/20 41/2
54/8 55/19 56/9 81/9
91/3 99/18 109/21
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policies [1] 84/10
policy [12] 79/21
79/22 81/5 81/17
81/21 84/13 86/17
160/22 160/23 180/17)
181/3 181/8
portion [1] 95/23
portray [2] 184/19
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portrayed [1] 185/23
portrays [1] 187/18
posed [1] 168/17
position [16] 7/16
8/10 12/11 14/4 33/8
48/4 51/21 55/3 55/18)
68/6 89/22 125/14
127/13 128/4 136/18
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Posnett [2] 147/18
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possibility [4] 36/23
70/22 101/9 115/16
possible [22] 2/25
26/24 31/24 32/14
33/25 45/16 47/10
58/8 58/18 61/13 72/3
74/25 75/5 75/10
75/16 100/7 124/14
125/14 130/13 134/19)
144/11 152/5
possibly [15] 10/17
27/17 33/18 63/7 96/6
96/10 97/19 99/8
135/4 136/3 136/6
143/23 146/2 173/5
191/24
post [183] 4/1 4/6
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Post Office's [1]
184/23
post-2010 [1] 96/8
post-dates [1] 79/24
postal [6] 5/9 7/1 7/3
7/6 180/1 180/9
postmaster [6] 66/17
66/21 94/8 108/23
110/1 132/22
postmasters [12]
64/15 65/21 103/16
103/18 109/7 118/5
122/16 122/19 123/6
123/8 134/25 159/22
postmistress [3]
23/11 26/15 142/6
postpone [1] 53/20
potential [13] 35/20
36/17 37/24 44/9
50/16 50/21 51/11
64/3 76/7 76/12 76/18
T7IN7 155/22
potentially [2] 56/7
100/18
power [2] 22/5 78/11
powers [1] 125/21
practice [3] 16/9
18/18 19/15
practising [1] 24/18
pre [1] 162/6
pre-POCA [1] 162/6
precedent [7] 89/1
116/10 173/3 173/17
173/19 173/20 173/25
precise [2] 4/8
157/16
precisely [2] 52/2
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167/23
predominantly [1]
180/4
preliminary [3] 28/9
43/14 59/13
preparation [1] 17/18
prepare [1] 163/4
prepared [15] 68/5
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present [4] 125/19
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preservation [1] 3/1
preserve [2] 74/7
89/24
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press [2] 12/19 94/25)
pressed [1] 67/17
pressing [1] 3/14
pressure [1] 58/19
presumably [7] 20/6
36/3 54/25 122/20
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pretty [1] 83/10
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previous [4] 45/12
61/7 105/8 167/21
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54/25 71/17 79/5
135/18
primarily [2] 7/3
97/25
principal [8] 6/12
7/18 8/7 185/13
185/18 185/24 186/21
187/1
printout [2] 109/9
110/10
prior [8] 3/12 6/15
8/13 31/1 37/1 39/25
91/11 162/2
proactive [1] 133/13
probabilities [2]
16/15 69/12
probably [13] 9/1
19/12 22/3 22/17
69/20 70/25 102/18
111/11 115/19 115/21
149/25 151/3 151/19
probe [1] 190/2
problem [7] 23/12
27/6 72/14 78/7 78/9
106/17 115/10
problems [17] 12/6
21/11 21/12 21/14
22/8 30/19 61/9 61/13}
65/6 75/1 75/5 75/11
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procedure [2] 123/15)
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5/11 18/10 21/7 31/7
35/7 39/23 39/25
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87/20 87/21 91/5 99/1
100/13 100/23 101/23)
104/13 108/15 115/23}
118/19 120/25 125/16
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130/9 131/11 153/1
162/10 174/15
process [9] 80/16
91/19 112/4 112/12
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processed [1]
167/13
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progress [2] 131/23
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proof [1] 15/10
proper [3] 33/20
126/25 172/2
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94/10 123/11 167/20
property [3] 18/11
87/13 87/16
proportion [4] 54/20
1410/1 177/12 180/6
proportionality [1]
54/22
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88/5
proposal [5] 66/15
138/20 149/2 158/3
(70) POL00055212... - proposal
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135/7 139/5 139/15
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proposing [1] 66/14
prosecute [2] 96/14
153/20
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prosecution [23]
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106/11 108/12 110/21
114/25 142/5 148/20
170/16
prosecution's [1]
169/18
prosecutions [2]
99/15 161/4
prosecutor [2]
110/20 153/25
prosecutor's [1]
154/18
prospects [1] 88/22
prosperity [2] 123/22
123/24
Protocol [1] 84/19
proud [2] 11/6 11/8
prove [5] 16/14 17/1
29/8 39/7 102/1
provide [18] 44/19
83/15 104/18 106/20
110/18 112/14 116/13}
118/10 124/23 127/24
148/5 148/24 150/17
159/3 166/21 168/9
168/23 170/8
provided [15] 41/14
104/22 106/14 123/9
140/4 148/17 149/13
158/18 166/4 167/24
175/19 180/18 182/5
183/2 183/13
provides [1] 41/17
providing [7] 57/15
63/13 63/16 117/10
147/19 163/20 164/16)
provincial [1] 4/17
proving [2] 49/3
109/12
provision [2] 85/24
155/14
public [8] 12/8 12/15
26/24 29/24 34/1 74/5
77/7 77/10
publication [2] 33/25
34/5
publicise [1] 135/14
proposal... [1]
prosecuted [2] 102/4
160/20 161/17 161/22)
publicity [10] 12/19
29/14 31/23 32/14
134/23 160/3
publicly [1] 73/19
publish [1] 134/20
published [1] 3/17
pull [1] 114/2
pulling [1] 129/4
pure [1] 51/1
purely [6] 34/9 69/14
181/10
purpose [3] 13/18
15/19 117/25
purposes [1] 88/3
pursue [2] 55/8 56/4
pursued [2] 155/23
162/18
pursuing [1] 88/24
pursuit [1] 89/4
push [1] 162/25
put [18] 11/4 11/23
40/13 45/10 54/16
55/19 56/8 87/15
88/12 116/7 119/9
4145/7 145/17 177/4
17919
putting [2] 39/22
172/19
qualified [4] 4/3 4/5
4/6 24/17
quantum [2] 30/2
31/19
quashed [1] 100/15
question [12] 27/7
39/18 44/16 45/7 56/9
65/18 72/24 76/3 76/5
178/16 182/18 186/12)
questioned [9] 1/10
59/7 172/15 178/4
187/22 193/4 193/6
193/8 193/10
questioning [1]
157/8
questioning/investig
ating [1] 157/8
questionnaire [1]
122/15
questions [13] 21/23
105/17 107/4 162/16
168/17 168/21 171/16)
172/4 172/13 178/14
183/14 186/20 192/14)
quickly [3] 10/20
42/19 45/16
quite [26] 6/19 8/22
10/25 18/20 23/25
47/10 53/1 78/3 104/6
104/9 104/23 112/11
112/18 115/23 125/5
131/2 131/25 143/3
publicised [1] 135/25
40/15 51/3 68/13 69/2
125/12 129/18 164/10)
125/24 136/19 139/22,
151/25 152/9 152/12
152/19 154/21 155/1
187/4 188/16
quotable [2] 27/12
27/18
quote [1] 38/1
quoted [1] 27/13
R
114/1 115/8 120/18
136/17 138/3
raised [12] 58/13
58/18 58/23 63/20
65/24 81/22 102/12
102/16 116/1 117/4
154/1 156/2
raising [1] 60/13
ramifications [4]
39/9 39/12 40/4 40/8
random [1] 190/7
range [1] 5/8
rare [3] 76/8 104/6
104/9
rarely [2] 99/2 161/4
93/19 131/3 132/6
160/22
raw [1] 170/25
reach [1] 38/4
reached [2] 24/13
182/4
reaction [1] 172/6
34/11 38/17 48/19
57/2 93/24 101/8
102/18 111/18 122/5
152/19 178/9
readership [1]
176/11
reading [2] 139/10
146/15
real [6] 37/9 37/10
37/13 56/12 96/11
109/14
reality [3] 40/10
72/19 72/21
13/10 13/10 16/13
27/17 27/18 37/11
39/19 51/10 81/25
89/14 119/11 121/23
125/24 132/6 139/17
ream [1] 36/16
reason [7] 2/18 9/4
36/10 63/7 100/25
118/17 122/2
reasonable [1] 28/16
reasons [3] 6/4 17/4
145/9
reassured [2] 14/6
14/9
quoting [1] 52/23
raft [1] 57/13
raise [7] 71/14 102/8
rather [6] 50/12 83/9
read [13] 20/13 34/11
really [23] 12/20 13/1
148/20 151/18 155/12
157/13 168/16 191/18)
Rebekah [8] 7/25 8/4
8/19 147/17 152/2
182/24 186/3 186/4
rebut [1] 156/17
recall [67] 4/8 25/22
33/11 41/8 41/21 42/9)
52/18 55/23 61/25
63/4 63/8 75/23 76/1
79/3 85/11 85/23
86/25 88/17 98/21
104/16 104/23 108/3
111/25 118/14 119/15)
119/18 120/14 121/3
121/12 125/9 125/22
126/6 132/21 137/1
137/2 137/21 141/7
143/23 144/12 146/20}
147/5 148/2 148/13
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151/17 153/23 155/5
157/16 160/7 163/23
166/18 170/14 172/23}
173/18 173/24 174/3
174/10 176/4 178/25
recalling [1] 48/21
receipt [2] 42/5 148/5I
receive [5] 9/20
24/18 91/20 91/21
143/4
received [15] 2/9
2/15 9/22 16/10 20/7
20/9 24/7 65/2 65/14
102/9 117/6 132/5
138/8 167/22 176/18
receiving [9] 10/6
20/12 45/14 45/14
62/4 146/21 155/5
161/16 188/22
recent [2] 147/25
152/10
recently [4] 43/24
93/15 140/14 178/15
recipient [2] 126/4
146/19
recipients [1] 38/10
recognise [4] 44/7
141/2 143/24 145/3
recognised [1]
171/17
recognising [1]
39/10
recollection [13]
6/20 9/1 50/19 53/9
55/13 60/21 61/17
80/3 126/13 141/12
152/9 169/15 179/14
Recommend [1]
149/17
recommendation [3]
125/9 126/9 150/12
recommendations
[4] 126/19 127/19
152/6 174/4
recommending [2]
145/14 145/16
record [3] 94/5 94/6
143/10
recorded [3] 31/10
149/8 150/6
recording [2] 158/19
175/18
records [5] 28/2
31/15 39/3 75/2
167/21
recover [6] 3/8 64/13
88/6 88/13 89/8
138/21
recovering [1] 87/5
recovery [5] 42/4
80/18 88/21 96/12
162/11
recreated [2] 67/10
67/22
reduce [2] 112/4
112/19
reduced [1] 177/20
reducing [3] 112/16
113/6 127/11
reduction [2] 8/13
9/3
redundancies [1]
8/24
redundancy [7] 6/1
6/19 6/23 9/5 17/19
18/3 18/19
reeling [1] 163/11
refer [9] 51/15 53/16
82/20 89/25 91/11
135/9 157/20 174/14
174/18
reference [9] 85/13
111/19 146/14 147/21
148/18 148/24 155/10)
164/18 187/6
references [3] 23/9
128/11 141/13
referred [19] 4/16
712 18/12 41/19 45/7I
81/11 92/9 96/17
101/1 109/25 115/12
127/10 146/12 151/7
161/7 185/11 185/12
186/8 186/25
referring [2] 18/6
82/16
refers [6] 3/3 21/5
22/15 37/18 86/8
100/17
reflection [2] 27/3
27/5
refresh [2] 32/22
79/8
refuses [1] 109/2
refusing [1] 15/4
regard [1] 105/1
regarding [5] 32/25
79/14 93/7 140/13
184/24
regards [2] 19/8
167/7
(74) proposal... - regards
R
85/10 112/13
regret [1] 103/21
regular [1] 110/3
regularly [3] 62/20
121/20 191/22
regulation [1] 5/16
161/13
rejected [2] 3/14
26/15
rejecting [1] 111/13
related [4] 21/12
21/20 83/11 129/8
relating [17] 21/14
28/1 41/14 84/14
91/22 99/14 99/25
101/7 114/20 128/14
129/3 139/24 159/20
160/2 161/16 165/12
168/21
relation [18] 21/10
31/2 31/19 40/16
43/22 81/4 94/13
107/25 117/6 128/16
147/2 160/4 160/5
181/3 184/8 184/23
186/22 187/24
relations [2] 135/5
159/18
relationship [4]
Relationships [1]
118/13
relatively [2] 99/21
177/10
relatives [1] 6/7
relay [1] 78/22
relaying [1] 185/3
release [2] 117/18
117/24
90/18 91/11 92/5
113/14 116/9 123/17
124/11 125/15 127/3
144/24 170/8 192/4
reliability [5] 12/22
13/9 39/17 44/18
120/20
relied [2] 33/5 33/9
rely [3] 123/21 124/1
133/17
relying [1] 174/16
remained [1] 8/21
remains [1] 192/11
remember [22] 32/19
41/6 69/8 69/22 71/9
79/17 84/19 84/24
103/9 119/21 122/4
145/2 146/12 146/14
153/24 154/4 156/25
174/3 179/2 183/18
regional [3] 35/5
regulations [1] 15/21
regulatory [2] 118/12
29/20 34/8 35/1 43/20
relevant [18] 3/1 3/23
46/2 57/9 85/25 90/15)
183/22 190/2
remit [1] 148/25
remove [2] 16/2
161/21
removed [3] 27/7
42/17 122/22
remuneration [1]
16/24
rent [1] 5/12
repayment [2] 12/10
135/1
repeat [2] 65/18
129/24
repeated [1] 42/25
repeatedly [2] 30/17
181/4
repetition [1] 131/10
replaced [1] 78/10
replacing [1] 113/7
reply [2] 46/17 163/6
report [89] 2/21 8/2
8/4 8/5 13/15 13/22
13/23 16/8 16/12
17/12 19/14 19/15
20/13 20/16 20/24
26/22 27/2 27/21
28/23 31/13 31/14
31/23 32/5 32/13
49/5 59/16 59/20
61/22 62/1 64/19
65/14 65/14 65/15
74/20 75/7 75/10
77/15 116/3 116/4
117/3 123/19 124/24
125/8 126/16 126/21
157/21 158/4 158/10
158/11 163/2 175/15
184/10 184/11 185/7
186/16 188/3
reported [9] 22/25
23/15 86/11 97/6
137/12 146/4 176/19
180/19 182/6
reporting [6] 63/21
82/5 115/15 176/17
180/24 181/20
reports [11] 22/10
37/15 37/18 41/19
44/5 75/15 102/10
158/12 163/7 166/3
170/17
represent [3] 178/6
178/24 179/12
representation [1]
21/17
representative [1]
85/2
19/16 20/5 20/7 20/11
21/3 24/4 24/19 24/24
32/21 32/24 34/1 34/6
34/12 38/2 38/5 43/14
59/22 60/2 60/4 61/20
75/19 75/24 76/3 76/6
149/13 155/22 157/20)
175/18 176/18 180/16)
186/11 186/11 186/12)
representatives [1]
171/17
representing [1]
19/20
request [5] 3/4
170/19
requesting [2] 21/22
108/1
requests [3] 128/18
128/20 143/4
require [1] 59/23
required [4] 39/6
115/14 138/16 167/8
requirements [1]
148/25
resigned [1] 109/5
resoluters [1] 142/21
resolution [8] 19/5
76/20 87/2 131/1
190/11
resolve [1] 28/14
resolved [1] 51/13
resource [1] 47/4
respect [37] 9/6
10/14 11/16 17/24
20/18 20/19 25/22
50/3 64/18 82/10
91/14 94/1 96/25
113/19 114/4 129/17
164/15 164/23 166/4
168/10 171/11 185/2
188/3 188/17
respect of [2] 48/8
164/15
respectively [1] 97/5
respond [1] 112/1
responding [1]
191/15
response [15] 2/14
2/18 3/7 41/13 93/12
106/22 110/2 111/24
113/11 133/9 134/14
149/16 151/14 152/18}
165/21
responses [4]
165/23 168/16 168/18}
191/17
responsibility [2]
117/1 126/8
responsible [2] 37/7
85/5
rest [2] 183/22
183/23
result [12] 33/2 66/20
83/13 93/17 94/1
135/15 138/10 153/3
162/4 162/5 175/3
175/9
resulted [3] 2/25
reputation [1] 154/11
111/22 111/23 139/10
142/16 180/11 181/23
33/20 37/6 48/8 48/12)
102/22 102/23 108/15}
129/19 133/19 150/15}
158/25 159/15 160/17
140/15 141/9
resume [2] 47/21
47/22
Retail [1] 21/6
retain [1] 172/2
retained [1] 33/19
retirement [1] 26/8
retrieve [2] 106/4
113/22
retrieved [1] 113/16
return [2] 18/10
33/17
revert [1] 46/23
review [8] 2/13 24/5
49/8 61/14 147/23
148/2 157/11 186/13
reviewed [2] 21/19
44/11
Revised [1] 99/10
revolving [1] 172/24
RI [4] 147/16
58/23 70/12
right [42] 4/19 7/18
36/4 39/13 43/5 43/11
77/2 77/5 77/8 77/19
85/19 93/24 103/23
140/22 141/20 147/11
172/8 174/2 179/24
181/1 182/18 182/22
182/24 183/1 183/3
183/8 183/10 184/2
189/25 190/12 192/8
rights [2] 15/20
87/13
rising [1] 94/13
risk [2] 54/18 138/2
RM [1] 147/17
Road [1] 145/24
Rob [9] 8/15 96/23
97/3 97/4 151/10
151/11 151/15 152/18}
185/20
Rob's [1] 156/13
robot [1] 184/20
Robson [4] 38/11
42/4 121/9 121/18
robust [8] 13/18 14/1
25/11 42/15 43/10
49/1 49/23 124/10
robustness [4] 14/9
24/23 25/3 156/16
Rod [30] 13/15 13/20
62/18 66/12 118/11
121/5 121/9 121/17
122/1 131/19 133/9
133/10 133/19 134/9
138/25 139/6 139/11
139/22 147/16 158/15]
159/1 159/8 159/12
159/16 159/19 160/25}
161/6 184/9 185/4
retrospect [1] 135/16
Richard [4] 58/2 58/5
17/10 26/12 29/7 36/2}
48/6 68/14 70/1 76/13
104/11 134/13 140/12)
185/10
Rod Ismay [2] 184/9
185/10
role [28] 4/13 6/14
7/14 8/3 17/24 17/25
38/15 58/12 99/13
112/5 116/16 127/4
129/14 129/15 129/16)
129/19 130/18 131/7
133/19 135/19 136/4
160/4 160/9 160/22
160/22 160/24 161/14I
186/21
roles [2] 62/23 162/3
round [1] 51/13
Rowe [1] 83/4
Royal [18] 4/23 5/17
5/23 5/24 7/6 13/2
43/21 46/12 58/25
60/9 112/8 121/3
134/1 139/19 140/8
151/12 161/24 187/3
Royal Mail [1] 5/17
run [4] 82/9 140/23
166/15 173/13
running [1] 10/23
s
safest [1] 26/19
said [38] 3/19 4/9
10/5 11/10 15/13 21/8)
40/10 43/4 50/10
68/12 70/23 71/17
72/18 73/2 74/10
77/16 82/14 94/17
99/15 100/10 103/22
104/5 104/9 111/5
116/21 121/22 127/8
130/3 153/23 155/22
156/24 163/3 163/12
178/10 178/19 181/4
185/1 190/1
sake [1] 173/2
sale [2] 87/16 88/7
Sam [1] 178/5
same [19] 24/8 40/17
43/19 73/24 74/2
96/19 111/3 123/19
129/4 132/14 133/1
142/19 145/20 165/5
165/7 165/21 173/11
182/18 187/3
Sapte [1] 4/10
sarcastic [1] 103/20
satisfactory [3]
76/20 77/25 176/15
satisfied [2] 76/22
165/4
saturated [1] 22/19
save [1] 33/17
saw [8] 40/15 50/3
60/24 61/21 64/24
140/24 142/4 162/20
say [62] 3/24 7/18
11/6 12/3 12/14 25/22)
28/17 32/2 32/15
(72) regional - say
Ss
say... [53] 34/15
38/23 44/12 49/10
51/3 59/5 61/11 64/7
66/16 67/12 70/15
72/14 76/17 78/6
78/19 84/6 87/9 87/18}
89/19 90/12 90/13
91/8 92/3 95/6 96/21
103/12 103/12 103/24}
104/10 106/10 108/21
109/6 110/9 113/11
113/24 115/18 118/22)
126/5 136/14 151/17
165/8 168/18 174/9
178/22 180/7 182/7
184/16 184/25 187/12)
187/16 190/3 190/19
191/6
saying [13] 15/25
18/15 43/10 46/18
72/6 105/6 178/10
179/25 180/23 181/1
181/7 183/1 183/25
says [90] 14/25 15/1
15/9 15/16 15/24 16/5
16/19 16/20 19/18
21/15 21/24 22/22
23/9 23/19 24/20 26/7I
33/13 37/3 37/21 38/3
41/11 42/12 42/13
43/19 44/3 45/2 45/3
46/9 46/24 48/22 50/4
50/5 52/8 54/10 54/24
56/19 57/24 58/4
58/10 60/8 67/6 79/4
79/12 80/14 83/6
83/22 85/14 88/19
93/3 97/20 98/5 98/17,
100/2 100/4 107/2
108/10 122/11 123/2
128/6 128/19 133/10
134/9 137/6 137/7
138/1 138/25 140/11
142/9 142/16 145/4
145/21 146/7 146/23
147/22 151/10 152/19}
155/11 156/10 159/11
162/23 164/6 165/18
166/8 167/6 167/18
168/5 168/8 168/15
170/1 170/9
schedule [1] 53/17
screen [6] 22/1 22/1
22/11 108/3 119/20
179/21
script [1] 138/5
scroll [41] 14/16 16/4
21/2 22/21 34/23
38/18 41/11 44/2
44/25 48/19 53/23
53/24 54/9 57/22 61/7I
62/10 65/9 66/9 66/13
70/15 80/14 83/16
86/1 86/15 97/18
105/2 122/10 127/20
134/6 138/17 144/21
167/4 168/5 168/7
168/12 174/25 175/6
179/22
search [2] 10/22
113/18
searched [1] 167/21
second [13] 15/15
41/12 64/6 85/12
85/13 92/23 93/3
124/16 132/15 134/7
136/23 136/24 155/7
secondment [2]
113/4 113/5
Secretary's [1]
142/16
section [2] 21/6 42/4
secure [2] 154/12
154/23
security [14] 82/19
116/19 121/17 145/2
148/23 149/3 156/4
156/9 157/4 157/10
176/6 176/7 190/6
191/4
see [39] 1/3 9/14
11/17 30/4 34/24 42/3
42/10 49/8 57/19
70/15 73/15 83/17
83/24 90/4 90/7 94/13)
107/7 108/14 116/16
116/25 136/25 137/15)
138/18 143/9 147/14
151/9 155/6 166/15
167/24 167/25 172/5
180/20 181/25 182/3
182/11 185/12 186/18)
186/25 190/22
seeing [1] 61/25
seek [5] 68/20 88/6
89/8 188/9 188/12
seeking [10] 3/10
57/7 68/10 69/2 123/5
125/20 144/6 144/8
181/13 188/22
seem [10] 23/15
55/23 59/10 98/21
104/7 109/16 115/2
116/24 118/3 119/1
Seema [5] 108/17
108/18 114/20 114/22)
159/10
seems [22] 23/4 38/8
40/6 44/19 50/14 54/3
64/17 65/20 70/20
71/2 73/24 80/24
111/6 111/6 116/7
125/6 149/2 156/21
159/9 163/19 176/8
178/22
seen [22] 2/15 2/20
40/14 49/15 55/8
61/24 62/2 74/21 75/7
75/21 79/19 99/11
147/14 151/14 165/18)
111/18 120/22 122/1
131/18 139/4 146/14
160/16 170/1 181/19
187/8
seldom [1] 42/16
selection [5] 63/5
63/10 63/19 66/1
172/24
selectively [1] 188/1
sell [2] 11/9 93/11
send [6] 52/10 55/7
91/4 138/14 139/15
158/20
sending [3] 3/13
56/13 62/13
sends [1] 139/2
senior [17] 13/21
57/8 57/11 70/9 70/10)
70/13 79/13 81/22
105/5 119/25 121/15
126/14 141/16 141/18}
160/5 160/10 191/21
sense [3] 94/16
189/24 191/7
sensible [1] 145/17
sensitive [4] 85/14
85/16 86/2 86/4
sent [19] 46/19 55/12
61/15 65/1 91/25
99/14 100/1 128/24
133/3 139/7 140/10
140/10 140/25 143/8
157/12 158/20 174/12
190/16 191/17
sentence [4] 15/9
40/2 180/7 182/4
sentences [1] 180/14
sentencing [1] 118/1
separate [5] 73/21
95/14 95/15 95/22
95/25
separated [3] 95/11
95/17 95/24
separately [1] 74/1
separations [1]
95/11
September [9] 1/1
3/9 6/2 61/3 61/10
64/24 65/12 105/1
111/23
September 2006 [1]
64/24
sequence [1] 181/14
sequential [1] 52/20
sequentially [2]
183/9 183/11
serious [8] 12/22
13/16 39/9 39/12 40/4
45/19 102/3 115/23
seriously [1] 33/3
seriousness [1]
36/11
serve [2] 163/2 163/9
served [1] 163/7
services [27] 4/24
5/9 5/21 6/15 6/18
6/22 7/2 7/4 7/7 7/9
17/3 17/19 24/12 36/9}
36/19 70/12 82/2 85/1
95/12 95/13 110/19
112/3 112/6 112/20
113/2 141/19 164/19
set [12] 3/10 5/24
25/25 26/17 30/11
52/2 59/14 82/15
124/10 128/24 128/25}
152/22
sets [2] 75/12 96/2
setting [2] 18/21
36/15
settle [9] 15/25 16/7
45/11 45/15 45/17
48/8 50/11 55/8 68/9
settled [3] 28/22
28/24 88/9
settlement [8] 19/8
28/15 29/10 50/16
64/3 64/4 83/20 84/8
several [1] 92/9
shall [3] 47/21 85/15
101/8
share [4] 96/5 96/19
96/24 97/1
she [37] 7/12 7/15
15/12 15/25 17/5 17/6}
21/8 21/11 26/21
26/22 27/1 30/13
30/17 30/17 30/19
30/23 30/25 33/18
43/25 46/14 46/21
46/22 50/10 50/10
79/12 93/10 100/5
100/7 100/16 100/22
100/24 128/7 156/10
163/12 164/8 186/5
186/7
She's [1] 186/5
sheer [2] 39/20 40/11
Sherrott [2] 38/11
38/13
shined [1] 29/14
Shoosmiths [1]
159/25
short [6] 47/25 70/17
70/23 81/25 107/18
172/11
shortfall [3] 37/10
37/11 37/13
shortfalls [1] 173/10
shortly [9] 23/16
61/21 62/1 65/13
65/15 84/9 102/4
108/7 114/8
should [27] 1/14
16/23 39/25 42/19
42/20 53/20 58/6
60/13 86/11 98/19
108/2 108/14 114/7
114/16 125/7 125/24
134/24 138/12 162/13}
167/19 168/9 168/23
170/7 179/19 180/19
182/6 186/13
shouldn't [1] 114/13
show [4] 37/12 49/12
52/24 153/10
showed [1] 109/14
showing [2] 23/7
67/25
shown [4] 24/9 63/6
63/7 189/1
shut [9] 27/14 28/18
50/4 71/22 71/24 72/1
72/18 73/3 73/5
shut! [4] 27/9
sic [4] 172/3
side [6] 67/11 110/7
162/25 163/9 165/6
181/17
sight [3] 55/20 60/25
98/24
sign [11] 29/3 68/11
68/18 72/8 72/12
72/20 73/7 76/14
77/120 84/1 137/9
sign-up [1] 137/9
signature [1] 1/22
signed [6] 26/21
72/13 72/19 73/3 73/9
142/15
significance [2] 62/5
155/4
significant [24] 18/16
33/4 33/8 53/1 54/20
57/3 57/16 64/17
85/14 85/16 86/1 86/3
94/2 114/9 114/11
115/5 115/6 116/12
125/6 151/24 151/25
152/13 154/5 154/21
Significant/Sensitive
[1] 85/14
signs [1] 66/14
silence [4] 29/6
68/16 68/19 68/20
similar [23] 9/25 38/4
50/2 65/25 71/21
101/17 101/18 105/13}
117/23 118/25 123/6
128/1 131/17 132/6
133/1 134/3 134/7
141/13 151/2 160/17
165/6 168/10 169/13
simply [9] 26/2 29/6
43/4 43/11 59/11
62/23 156/22 160/19
179/2
since [7] 12/15 12/16
16/6 23/12 77/7 77/10}
153/6
Singh [7] 105/4 105/4I
106/18 107/25 112/1
159/8 160/11
single [3] 81/15
125/13 179/13
Singleton [1] 138/7
singular [1] 103/1
sir [12] 1/3 47/16
(73) say... - sir
Ss
sir... [10] 48/2 94/24
107/11 107/20 171/16)
172/13 192/5 192/10
192/15 192/16
site [1] 42/18
sites [1] 59/18
situation [9] 14/2
27/23 72/16 73/14
123/6 127/2 131/11
151/13 170/18
six [2] 112/15 113/3
size [9] 39/2 39/20
40/11 48/9 51/10 68/8)
113/6 133/7 177/12
slightly [8] 16/5 18/8
34/24 46/18 47/17
66/10 101/4 109/16
slim [1] 88/22
small [13] 2/3 5/8
50/20 75/2 85/7 94/21
112/9 112/12 124/17
162/15 177/10 177/10
180/6
Smallbridge [3]
41/15 41/21 42/13
smiles [1] 172/7
Smith [11] 2/21 3/10
26/7 121/9 121/15
126/13 131/19 185/9
191/20 192/5 192/5
Smiths [1] 192/3
smoothly [1] 30/10
snapshot [1] 44/8
snapshots [1] 45/1
so [150] 6/24 6/25
7/11 7/25 8/6 11/8
14/7 16/7 17/7 17/20
20/12 21/18 24/4
24/25 26/3 26/8 29/14
29/20 30/22 35/9
36/11 43/17 44/10
44/19 46/1 50/2 50/14:
50/21 54/3 54/23
55/10 55/23 56/18
59/19 61/10 61/24
62/20 63/9 63/12
63/21 64/17 65/15
66/6 66/9 66/12 67/4
69/6 69/19 70/6 70/20
73/5 73/23 75/4 78/3
81/10 81/17 82/8 85/4
87/7 89/11 90/12 91/8
91/19 92/3 92/19
92/25 94/11 95/22
96/23 97/23 98/3 98/4
99/11 99/21 99/23
99/24 100/10 103/23
104/2 104/5 106/11
106/18 110/5 110/11
110/12 111/3 112/9
113/4 113/6 114/1
114/9 114/12 114/25
116/6 116/6 118/16
119/1 120/3 124/4
126/19 126/24 127/1
127/9 127/12 136/11
138/18 140/10 142/3
143/9 147/10 147/12
147/19 148/20 149/2
155/1 161/13 162/8
163/5 164/5 166/19
169/9 172/3 172/8
174/5 175/14 176/8
177/21 178/22 178/23)
179/13 180/20 181/7
182/4 183/1 183/10
183/16 184/2 184/22
185/22 185/22 188/6
188/17 188/25 189/7
189/21 189/22 190/1
190/12 190/24 192/11
software [12] 22/4
23/24 100/8 101/7
101/19 137/17 137/19}
138/8 139/8 140/14
141/8 141/14
sold [1] 87/12
solicitor [19] 4/3 4/5
4/12 4/14 5/21 6/17
7/13 24/17 36/25
74/17 83/3 93/6 93/23
97/8 131/8 131/8
155/8 164/20 181/14
solicitors [17] 6/16
18/7 32/11 62/3 63/14
72/11 83/4 83/21
83/25 91/5 92/2 92/3
95/7 100/9 122/13
125/25 127/1
some [55] 2/3 2/8
3/20 4/12 7/5 19/7
21/3 24/18 26/16
32/22 36/14 37/14
37/18 41/14 45/13
60/13 61/12 64/1 75/9
78/18 82/13 83/10
85/18 93/6 108/20
112/13 112/23 113/4
116/25 118/3 121/25
128/5 129/15 130/20
136/12 140/6 145/7
145/24 149/20 155/24)
162/24 169/10 171/16)
176/3 184/3 184/20
185/2 187/2 188/10
188/17 188/20 189/13}
191/9 191/11 191/19
somebody [14] 5/22
8/10 35/9 44/1 70/24
71/22 73/18 93/5
103/8 123/17 131/4
135/12 173/1 177/8
somebody's [3] 53/2
91/6 177/7
someone [4] 49/7
69/6 87/2 178/22
something [27] 5/19
10/15 42/7 63/3 67/13
69/13 72/9 78/11
80/11 86/10 87/19
101/1 110/8 133/4
135/17 138/6 140/1
141/5 151/1 152/8
153/22 154/5 157/19
157/24 157/25 169/17
176/5
sometimes [4] 113/3
170/21 173/21 191/16
somewhat [3] 17/25
83/13 125/16
91/20 187/12
Sons [1] 92/24
soon [1] 58/18
soonest [1] 46/23
sorry [34] 7/23 11/24
25/16 27/15 27/24
32/20 37/15 53/23
61/6 69/24 70/4 90/10
96/9 101/4 112/18
112/19 114/18 115/21
119/13 121/1 132/13
132/15 138/24 151/5
151/8 152/15 157/17
164/3 168/6 168/7
171/23 171/23 173/6
179/17
sort [7] 50/24 94/5
94/6 96/2 113/4
174/25 184/20
sorts [2] 23/7 103/15
sought [9] 51/3 54/6
188/8 190/5 190/9
191/1 191/3 191/6
191/13
sound [3] 27/17
130/18 153/3
sounds [4] 28/16
115/4 130/19 145/13
source [1] 184/3
speak [14] 10/2 14/2
14/3 27/11 34/10
74/15 79/14 83/7
90/24 129/3 132/13
141/18 141/20 144/4
speaking [2] 25/13
26/9
spec [1] 166/1
special [1] 133/4
specialism [2] 9/13
14/22
specialist [1] 124/23
specific [10] 62/23
93/20 107/1 120/12
121/3 129/13 130/1
131/2 164/25 169/7
specifically [2] 92/19
100/9
speculation [1] 9/11
speculative [1] 49/18
speech [2] 50/2 50/3
spending [1] 56/2
spent [6] 5/1 54/23
94/19 106/7 106/25
113/15
sphere [1] 169/18
somewhere [3] 52/12)
spike [1] 177/4
SPOC [1] 167/9
spoke [4] 14/6 44/15
128/7 160/1
spoken [3] 83/25
150/24 164/8
spread [2] 95/14
175/1
Square [3] 106/13
106/16 106/16
St [1] 30/5
St John [1] 30/5
staff [5] 6/21 67/20
112/11 127/23 144/5
stage [20] 8/25 24/17
44/22 47/12 55/16
56/16 57/1 59/10
65/23 90/21 102/8
110/10 111/5 111/15
112/9 115/11 124/13
135/21 142/17 144/22}
staggered [1] 155/18
stake [4] 49/14 55/6
56/13 124/6
stand [1] 63/23
standard [1] 90/2
stands [1] 54/15
start [6] 30/7 34/18
34/20 120/2 121/6
144/20
started [5] 14/25
50/20 111/21 120/4
191/15
starting [1] 101/12
state [1] 83/14
stated [1] 122/14
statement [50] 1/15
1/21 1/25 2/10 3/3
3/16 3/20 4/2 4/9
10/10 11/7 11/25 12/2}
20/3 21/5 21/7 29/1
68/11 68/18 70/17
70/24 89/10 89/13
89/17 92/9 95/5 95/6
98/10 98/18 98/22
99/7 99/8 99/10 99/12,
103/22 103/25 109/21
120/10 120/12 154/22}
155/4 167/24 168/10
168/24 168/25 179/18}
180/23 181/8 182/2
192/12
statements [16] 28/6
66/2 67/2 98/25 99/4
99/19 103/15 127/24
135/10 155/15 163/10)
166/22 167/22 169/12
169/15 169/16
stating [2] 23/1 168/2I
stats [1] 145/7
status [1] 70/14
stayed [2] 114/16
115/3
steer [1] 182/13
Stein [5] 172/14
178/3 178/4 178/5
193/8
step [2] 123/3 151/25
Stephen [35] 27/10
34/22 35/13 41/19
43/18 43/18 44/20
49/19 51/18 52/22
53/13 56/25 57/17
60/19 75/21 78/5 79/3
79/11 83/5 83/17 84/6
88/15 99/3 99/5 99/17,
113/20 134/19 163/19}
165/15 166/9 166/21
169/25 170/3 191/13
191/18
Stephen Dilley [1]
169/25
steps [1] 147/2
stick [2] 42/10
143/17
sticking [1] 131/16
still [25] 13/17 16/17
26/17 43/17 46/6
46/21 56/7 57/11
87/11 93/6 104/2
113/20 115/19 127/16)
130/12 131/15 135/20}
137/9 155/4 157/5
159/6 166/15 167/14
167/16 177/17
sting [1] 127/10
stock [3] 23/6 30/16
138/9
stolen [1] 153/9
stood [1] 176/25
stop [2] 30/23 191/5
stopped [1] 142/20
storage [1] 113/22
story [1] 159/20
Stoy [4] 61/3 65/7
74/20 75/13
straddle [1] 174/21
straight [1] 82/16
strategy [25] 51/17
51/22 51/22 51/24
52/3 52/25 53/1 53/3
65/20 73/15 73/17
73/21 73/24 74/4
74/13 74/14 81/15
88/1 160/24 162/18
163/25 164/16 170/6
189/9 189/16
Street [1] 30/5
strengthen [1] 71/3
strengthening [1]
50/14
stress [3] 83/11
84/12 85/19
stress-related [1]
83/11
stress/bullying/haras
sment [1] 85/19
stretched [1] 8/22
stringent [1] 73/8
strings [1] 117/10
strong [4] 10/25 11/2
23/25 83/10
(74) sir... - strong
Ss
structure [9] 6/9 6/23
82/3 96/20 96/24 97/9
180/15 180/24 181/2
structures [1] 63/21
stunned [4] 175/8
175/11 175/17 176/12)
style [1] 22/7
sub [2] 23/22 180/5
subject [4] 103/11
147/4 149/11 159/9
subpostmaster [27]
50/7 50/20 63/1 81/14,
84/18 85/3 85/6 85/10)
87/3 91/10 91/22
91/24 92/5 94/3 94/6
94/20 101/22 109/1
114/15 115/15 121/19}
123/4 127/15 130/9
133/15 150/18 171/3
subpostmasters [19]
3/6 9/6 9/16 49/17
55/7 55/12 56/14 65/4
82/11 88/4 110/3
110/12 120/25 124/4
172/17 173/10 178/7
179/11 181/4
subpostmasters'’ [1]
47/5
subpostmistress [4]
15/4 16/16 93/16
103/14
Subsequent [1] 24/6
subsequently [3]
97/10 98/15 100/15
substantial [3] 47/8
177/15 177/23
substantive [1] 1/20
succeed [1] 33/21
successful [4] 19/4
39/11 132/19 175/3
successfully [1]
126/2
such [24] 11/2 19/9
20/8 28/12 28/13 51/6
51/7 55/6 66/12 68/18
73/8 94/7 101/10
112/1 118/11 122/1
125/25 127/13 134/18
141/11 153/13 155/4
169/3 170/25
Sue [4] 147/17 148/6
150/18 158/2
suffered [4] 137/13
137/20 139/16 140/14)
sufficient [7] 12/21
33/4 59/22 60/4 67/14,
68/4 126/23
suggest [5] 70/19
80/24 85/4 109/11
166/6
suggested [5] 69/20
69/23 87/24 151/1
153/12
suggesting [1] 139/6
suggestion [5] 11/8
33/1 125/6 150/23
169/9
suggestions [4]
68/22 124/7 124/8
135/14
suggests [4] 7/2
56/11 67/5 186/18
suitable [3] 135/4
140/19 149/17
sum [1] 66/18
summarise [4] 48/4
121/11 121/13 122/25)
summarised [1] 62/6
summarises [5]
15/23 23/19 37/14
43/19 48/17
summarising [1]
14/24
summary [11] 37/3
39/5 42/15 54/5 56/5
74/23 109/5 109/17
122/8 132/1 147/1
summer [2] 13/15
14/14
Summerhayes [1]
46/8
sums [1] 76/6
supplied [3] 13/12
30/12 106/4
supply [1] 112/25
support [11] 6/5
21/22 23/1 23/10
30/10 38/25 45/22
68/5 103/16 150/14
155/15
supporting [3] 41/17
69/9 150/15
sure [10] 46/21 65/2
67/13 67/15 67/18
68/2 140/12 163/6
180/22 182/12
Surely [1] 73/3
surprise [1] 24/3
surprised [2] 2/22
152/7
surprising [1] 40/25
Susan [1] 156/9
suspect [7] 98/18
149/25 151/3 151/18
161/18 170/21 174/11
suspended [1] 30/25
suspense [1] 44/6
sustained [1] 102/2
Swansea [1] 4/16
sworn [2] 1/9 193/2
sympathetic [1]
187/15
system [140] 3/7
3/11 9/21 10/5 10/14
10/19 11/5 11/22 12/6
12/19 12/23 13/9
13/18 14/1 15/5 15/19
17/9 21/10 21/11
21/13 21/14 21/20
22/7 22/9 22/16 23/20
24/16 24/23 25/3 25/6
25/7 25/8 25/10 27/4
28/3 28/7 30/9 30/12
30/14 30/22 31/7
31/16 32/25 33/3 34/3
34/13 39/4 39/12 40/7
41/15 41/25 42/15
44/6 49/1 49/16 49/23
50/5 50/23 58/8 59/2
59/25 60/11 60/14
61/9 65/7 65/25 66/23
67/1 67/5 68/23 69/9
71/7 71/16 72/6 72/15
73/5 73/12 73/19 74/6
74/8 76/4 76/15 77/22
78/9 82/14 89/2 93/7
93/18 100/6 102/11
102/12 102/17 102/24
105/9 105/18 107/4
107/8 109/13 109/23
116/6 116/15 117/22
118/24 120/20 122/17
122/20 122/21 123/10
124/1 124/25 126/24
128/15 132/23 132/25]
133/8 139/24 140/3
140/5 140/15 142/7
144/3 144/10 154/15
156/17 157/10 157/12
158/14 160/4 160/14
166/3 167/10 167/20
168/4 175/5 177/16
177/24 181/7 181/8
182/15 186/14
systems [2] 21/25
166/6
T
table [1] 51/13
tactic [4] 56/10 88/13
89/21 164/11
tactical [4] 53/19
54/3 55/14 56/5
tactics [2] 90/2
163/12
Tagg [2] 21/5 22/6
tail [1] 127/10
tailored [2] 169/19
172/4
take [39] 3/21 11/25
18/4 24/15 31/20
44/13 44/16 47/6 47/7
47/17 49/25 51/7
56/10 61/20 65/13
79/25 81/3 81/13
88/16 95/1 97/13
124/8 126/9 134/25
144/23 146/20 155/19)
157/1 162/14 165/11
169/22 171/19 171/21
178/12 179/18 184/7
184/8 188/17 189/10
taken [12] 3/20 26/8
33/3 35/14 55/14 56/6
72/10 82/14 91/14
104/24 123/3 163/16
takes [1] 17/6
taking [11] 23/14
26/18 27/1 47/4 50/9
116/12 118/19 147/6
156/13 156/19 186/21
Talbot [31] 1/7 1/9
1/13 1/14 3/16 26/9
28/16 43/23 44/14
46/13 48/3 70/2 79/14)
100/12 107/23 139/4
147/9 147/16 164/7
170/12 172/16 178/5
178/21 185/13 185/18}
187/1 187/6 187/12
187/19 187/23 193/2
Talbot's [1] 89/12
Talbot/Biddy [1]
139/4
talk [3] 10/4 23/5
124/16
talking [12] 5/7 27/1
46/16 46/25 50/6 65/3)
78/5 111/3 128/10
128/12 148/13 158/9
tapes [2] 117/18
117/24
task [2] 105/22 177/3
tasked [4] 76/19 87/5
94/4 127/11
Tatford [2] 105/13
142/9
taxed [1] 134/12
Taylor [1] 105/24
team [58] 5/16 5/23
6/9 6/11 7/1 7/2 8/1
8/6 8/17 8/21 9/8 9/11
9/14 10/1 14/19 14/20)
36/12 36/14 44/14
87/3 95/18 95/20
96/21 97/21 97/23
99/16 100/2 104/17
112/9 112/16 113/6
116/25 117/2 117/11
121/19 124/17 126/22)
130/13 131/1 134/1
141/23 142/12 142/18}
143/15 145/2 147/23
148/19 149/3 154/11
156/10 161/23 171/10
180/1 180/2 180/3
180/9 181/23 190/11
teams [5] 6/24 10/3
82/19 91/23 95/10
technical [4] 21/14
55/17 155/14 167/19
techniques [1]
124/19
technology [2] 23/21
24/20
telephone [8] 48/17
53/16 89/25 150/1
151/18 151/19 170/3
170/10
telephoning [1] 21/9
tell [21] 5/4 12/13
14/17 34/25 40/23
45/5 45/6 72/16
100/24 101/16 102/14)
105/21 119/14 137/18)
137/19 172/21 172/22)
173/3 178/17 185/22
190/7
telling [4] 43/2 43/6
52/10 175/2
template [1] 161/20
temporary [1] 113/9
ten [4] 175/2 175/16
176/10 176/11
term [1] 23/25
terminated [1] 15/18
termination [3] 39/5
109/5 124/14
terms [16] 6/19 9/20
10/12 20/25 27/19
50/12 57/15 61/20
68/1 72/3 82/5 95/24
112/11 120/11 138/5
148/24
test [9] 50/25 51/4
55/17 55/17 64/20
68/13 160/14 160/16
177/14
than [16] 5/6 16/2
49/14 50/12 54/17
60/3 93/20 119/9
119/10 126/21 146/4
146/6 148/10 150/9
160/22 163/24
thank [54] 1/5 1/6
4/11 1/25 2/3 3/16
3/25 4/18 6/8 12/2
16/5 34/19 34/21
37/15 37/17 48/2
54/10 61/7 64/2 64/6
83/1 86/23 87/7 89/17
90/11 93/14 95/3
97/11 98/2 98/4 103/4I
107/16 107/22 108/3
108/6 127/17 127/21
142/3 144/16 144/20
146/17 157/3 162/12
171/15 172/13 178/2
184/13 187/21 192/8
192/10 192/12 192/15)
192/16 192/18
Thanks [1] 133/11
that [964]
that I [8] 101/20
151/3 162/20 172/22
172/22 176/4 178/24
190/13
that's [42] 1/16 1/21
7/20 11/25 13/11
15/17 19/15 19/16
26/14 33/12 35/9
40/10 41/4 46/12
46/25 47/20 53/25
57/1 60/6 68/8 69/14
72/16 77/10 78/25
83/16 89/12 97/9 98/7
107/11 110/15 110/15)
111/3 113/5 113/10
(75) structure - that's
TOO
that's... [8] 146/12
174/2 176/7 177/25
184/12 188/24 190/12)
190/13
their [32] 18/17 19/12)
24/10 24/14 25/2 25/3,
25/15 38/2 38/5 41/6
59/18 62/22 63/21
64/16 64/25 65/22
66/3 71/23 87/14 93/8
97/1 110/18 110/21
113/1 113/22 116/19
141/20 143/8 144/5
156/5 168/18 181/6
theirs [1] 87/4
them [42] 10/22 15/4
21/4 32/17 43/23 52/8
58/20 92/13 93/9
102/14 108/15 111/1
113/18 113/22 117/19)
118/1 118/11 124/18
129/4 131/22 134/12
140/21 144/6 144/8
144/9 148/7 161/1
161/5 162/13 163/10
173/11 174/5 174/9
177/25 183/7 183/16
183/19 183/24 184/1
190/7 191/2 192/7
thematically [1] 3/21
theme [1] 131/16
themes [1] 89/14
themself [1] 135/13
themselves [2] 11/20
76/17
then [76] 3/23 4/15
6/16 8/1 13/24 16/6
18/15 19/3 20/10
20/13 21/15 22/14
23/18 24/7 24/10
25/23 27/7 28/24
29/19 44/25 45/2
49/16 58/9 71/1 71/13
77/9 77/18 77/19 84/5)
85/18 88/10 89/23
93/12 94/9 96/16
96/16 99/21 102/9
105/21 110/25 113/24}
121/5 122/25 123/7
127/9 128/18 129/10
133/12 138/17 146/7
147/16 148/22 149/4
149/8 152/22 158/17
161/24 162/15 166/8
168/1 168/12 169/7
170/9 172/9 177/13
177/13 178/14 178/15)
180/7 181/25 182/7
184/7 185/10 188/22
190/20 191/15
there [227]
there'd [1] 162/7
there's [18] 14/16
36/23 37/16 44/25
56/20 62/11 80/11
83/19 85/13 88/15
97/19 110/6 110/7
115/15 143/23 157/1
167/2 174/21
thereafter [4] 18/12
19/11 82/20 177/21
therefore [24] 16/22
19/6 20/15 54/19
55/18 56/9 64/21
73/25 76/10 80/9
80/22 96/13 98/24
109/14 110/23 118/16)
119/5 125/20 132/9
143/5 153/19 161/10
162/24 168/20
these [44] 10/21
15/13 21/12 21/19
23/15 38/20 51/24
52/1 57/2 62/20 73/21
74/13 74/17 78/21
85/8 90/1 94/20
100/13 106/19 113/8
114/5 118/4 120/7
120/25 121/22 121/24)
122/2 132/9 139/10
140/20 145/7 147/25
148/14 149/16 153/5
153/23 155/3 158/14
163/10 166/16 168/2
169/3 182/10 183/10
they [77] 5/13 8/5 9/7
11/8 11/18 18/17 34/5)
36/5 36/8 40/23 42/20
44/10 44/12 60/7
61/10 62/6 63/5 63/10
68/3 76/8 78/18 81/6
91/6 93/8 95/11 96/12
96/13 96/14 97/25
101/6 103/17 103/23
111/2 113/6 113/16
115/25 116/23 121/22)
122/15 122/17 122/21
125/24 127/22 129/25)
130/8 132/5 132/11
133/17 135/8 139/15
139/20 139/21 142/13)
143/10 148/10 148/19)
153/9 153/10 154/23
159/21 161/20 163/2
163/10 164/9 165/4
169/6 169/18 170/18
172/7 174/14 176/14
177/9 183/4 183/4
183/6 183/20 190/16
they'd [1] 154/25
they're [5] 29/4 42/5
93/6 131/2 169/13
thing [5] 4/1 40/17
82/18 145/14 163/13
things [7] 3/22 10/21
18/14 51/13 158/9
184/8 188/18
think [108] 5/1 6/1
6/10 6/20 9/25 11/21
12/20 13/1 16/14
27/18 34/7 35/1 38/20
43/11 47/18 51/10
51/12 52/13 55/16
60/4 60/12 64/15 65/5
65/21 69/12 70/12
71/3 71/13 71/18
71/24 76/13 77/2 77/3
77/4 77/11 79/3 81/14
87/3 87/23 88/5 89/3
90/7 92/16 94/24
94/25 95/2 96/6 97/17,
99/4 102/8 102/20
104/11 106/6 107/1
107/11 108/20 109/20
111/11 111/24 112/2
112/22 113/2 115/6
116/17 117/13 118/7
121/18 126/12 126/19!
127/9 127/13 130/3
131/21 135/12 135/23
136/8 137/9 139/25
141/2 142/15 143/19
144/7 147/12 150/19
154/21 155/22 158/25)
160/15 160/21 163/7
163/21 166/2 168/11
169/5 169/6 171/9
171/18 174/14 175/11
176/14 178/10 185/1
187/17 187/19 188/2
190/20 190/25 191/24
thinking [4] 46/3 73/4
73/6 81/7
thinks [1] 163/9
third [6] 15/8 44/2
124/20 127/7 149/10
154/7
this [412]
Thomas [1] 105/10
those [46] 2/6 3/18
3/22 4/12 8/20 9/17
21/7 27/19 33/23
48/19 52/7 57/11 69/5
70/9 81/2 81/6 86/4
86/18 86/19 90/17
91/1 95/10 102/22
103/25 104/24 107/1
107/9 114/3 117/10
122/24 124/8 136/14
144/1 146/4 150/2
165/9 172/3 174/12
175/16 176/25 183/2
183/13 184/2 188/12
191/16 191/23
though [20] 7/14
13/6 18/1 24/9 40/6
41/10 51/4 54/6 67/12
70/20 74/15 100/21
111/6 115/4 130/19
150/16 159/10 163/19}
164/11 189/4
thought [15] 34/14
43/21 50/11 56/9
75/17 78/14 99/4
100/24 106/23 111/11
111/12 113/12 138/6
152/21 163/20
thoughts [1] 133/18
thousands [1] 121/1
threaten [2] 173/9
173/11
threatened [2] 109/4
129/6
three [7] 22/21 39/6
75/2 135/10 144/19
148/3 148/10
threshold [1] 36/11
through [32] 3/21
13/14 24/15 32/21
42/20 46/14 46/16
46/19 53/6 57/18
67/21 74/16 84/12
87/16 88/7 109/6
111/8 124/8 126/5
137/15 144/18 146/20}
153/16 162/21 182/2
182/10 182/15 183/16}
183/19 183/24 186/19}
191/9
throughout [4] 58/16
94/11 141/15 141/16
throw [1] 26/20
throws [1] 15/20
Thursday [1] 1/1
thus [2] 156/17
168/16
time [117] 2/2 3/20
3/23 4/8 4/23 8/1
11/24 12/9 13/2 13/3
14/5 15/3 18/3 19/9
20/1 20/2 20/5 20/8
20/17 24/3 24/18
25/16 26/16 29/13
29/19 32/9 32/20
34/12 34/15 38/13
40/10 40/16 42/9 43/2)
43/12 47/3 47/8 47/20
49/2 52/14 52/18
55/15 56/1 57/4 61/16)
62/16 63/4 64/20 65/3)
65/20 68/12 69/9
69/10 71/14 71/19
75/8 75/18 76/2 76/19)
76/25 77/2 77/23
81/25 88/8 94/7 97/8
98/14 98/21 99/2
99/12 101/15 102/25
103/10 104/15 107/11
109/18 109/24 109/24,
112/1 112/3 113/2
113/9 113/14 114/10
116/3 116/16 120/4
121/25 122/1 122/4
128/1 130/12 133/25
136/6 139/12 141/11
141/14 144/13 144/15)
148/13 155/2 155/9
158/19 164/2 164/5
164/22 165/7 165/10
172/23 173/6 177/19
180/3 183/11 186/1
186/4 187/4 192/1
times [4] 30/10
110/19 163/22 187/7
tiny [2] 76/6 110/1
tired [4] 46/25 47/2
47/9 109/16
title [8] 7/8 7/9 41/6
97/19 122/4 185/16
185/17 186/24
titled [1] 145/11
titles [1] 187/5
today [14] 3/25 5/7
10/7 34/4 61/1 84/2
120/4 120/22 142/1
146/25 158/10 158/22)
163/23 164/24
together [6] 39/22
89/16 96/1 114/2
117/10 145/7
told [10] 10/16 25/12
43/13 49/19 102/5
115/25 144/9 161/3
176/2 179/2
Tom [6] 56/23 57/16
57/23 128/3 170/3
170/11
Tom Beezer [4]
57/16 128/3 170/3
170/11
Tom Beezer's [1]
57/23
Tomlin [3] 72/8 72/12
88/9
tomorrow [2] 78/12
192/17
Tony [4] 121/9
121/16 127/7 167/15
Tony U [1] 167/15
too [1] 152/7
took [14] 6/1 24/7
24/25 28/10 60/24
69/1 74/22 91/3 91/6
111/21 111/25 125/3
155/18 158/25
top [14] 33/13 42/2
53/24 70/3 84/5 90/12
138/18 152/17 168/5
168/7 169/4 169/9
169/10 184/13
topic [9] 78/24 78/25
82/22 85/21 94/23
108/7 119/23 162/15
165/11
topics [1] 162/12
total [2] 54/11 134/10
touch [2] 99/5 161/9
toward [1] 181/6
towards [3] 50/15
124/13 182/14
tower [1] 95/13
Tracy [1] 98/13
trading [1] 135/10
trail [1] 170/25
trained [1] 100/6
training [7] 4/12 4/15
5/10 9/21 9/22 21/23
124/17
(76) that's... - training
T
transaction [1]
168/22
transactions [3]
42/16 42/18 167/13
transcribed [1]
117/20
transcribers [1]
117/25
transcript [4] 114/6
117/21 118/23 119/8
transcripts [1] 27/4
transferred [1] 14/22
treat [1] 83/11
tremendous [1]
64/14
trends [4] 94/13
94/14 94/15 94/16
trial [20] 17/6 23/6
26/16 31/12 77/7 78/3
78/13 78/17 79/16
87/23 88/10 88/12
89/24 159/9 159/13
163/1 163/4 163/13
164/10 175/4
tried [4] 11/23 83/7
106/3 130/23
true [3] 1/25 21/16
32/4
truly [1] 94/19
trustee [1] 87/16
try [15] 19/3 28/14
45/10 53/2 74/5 77/19)
77/20 78/20 88/13
91/19 112/3 125/20
131/10 148/5 188/6
trying [21] 9/23 18/14)
73/1 76/13 85/23
93/11 99/3 99/3 99/17
112/22 125/23 127/14
128/13 131/7 140/19
163/8 184/16 184/19
184/25 187/12 187/15)
Tuesday [2] 95/20
189/5
turn [14] 1/20 8/5
30/3 30/6 43/25 63/20
89/10 103/4 142/7
145/19 181/25
Turner [1] 83/3
Twenty [1] 171/21
twice [2] 64/15 65/21
two [27] 47/6 48/20
73/21 74/17 75/12
75/15 75/15 75/15
81/24 83/19 94/19
95/14 95/15 95/25
96/2 102/9 113/15
124/25 127/19 132/7
145/23 148/2 148/10
156/1 162/12 164/6
192/3
two years [1] 75/15
type [4] 21/23 99/20
transparent [1] 80/16)
168/10 171/7
types [1] 170/24
typically [1] 140/1
ultimate [2] 94/1
106/22
ultimately [13] 3/14
6/6 24/11 32/7 61/21
64/5 69/17 71/20
75/19 127/12 155/3
155/23 191/17
unable [3] 57/11
176/13 188/19
unclear [2] 44/18
55/4
under [12] 5/9 18/22
25/7 71/18 110/17
112/12 112/24 130/4
140/16 140/20 141/9
185/7
undermining [2]
153/15 154/4
Underneath [1] 7/17
understand [19]
18/14 20/22 48/4
58/12 58/25 60/9
82/13 85/20 91/19
105/12 112/18 129/22)
146/1 170/23 180/21
187/25 189/2 189/23
190/1
understanding [3]
137/11 153/2 184/15
understood [2]
105/22 133/22
undertaking [2]
76/14 77/21
Undoubtedly [3]
102/3 188/24 191/20
unfavourable [2]
16/11 17/13
unfit [1] 15/19
unflattering [1] 16/11
unfortunate [1]
159/15
unfortunately [3] 6/4
103/9 150/8
unhelpful [1] 29/1
unique [4] 25/25
59/14 80/22 169/19
unit [2] 138/9 141/19
unless [5] 42/17
90/16 90/22 90/25
192/2
unlikely [5] 17/1
26/25 28/11 96/6
164/12
unrecoverable [2]
80/19 81/2
unreliable [1] 145/9
unreservedly [1]
71/4
unspecified [1] 54/16)
unsupported [1]
50/22
until [18] 12/20 19/9
20/8 61/18 84/21
90/17 91/1 94/7 95/8
96/6 104/10 141/11
146/22 151/23 160/7
166/2 177/19 192/20
untoward [1] 19/2
untrue [1] 71/5
93/25 161/7
unusually [1] 14/21
unwell [1] 83/9
up [51] 3/10 5/24
18/21 26/9 30/11
36/15 38/6 39/8 40/3
41/5 47/4 47/6 47/7
53/24 61/7 63/21
66/10 68/11 68/18
71/22 72/13 72/19
73/3 73/6 73/7 82/15
83/17 86/15 87/16
89/10 98/2 108/2
108/13 121/25 124/10}
127/1 137/9 140/19
145/17 151/14 151/23
165/2 168/7 176/25
177/8 177/19 179/10
189/18 189/18 190/21
190/22
update [5] 43/22 58/1
83/18 93/14 131/22
updated [2] 2/11
161/1
updates [1] 133/2
updating [3] 17/15
128/3 132/16
upgrade [2] 23/14
23/17
upgraded [1] 23/13
upon [14] 2/14 24/8
24/10 29/15 29/19
33/5 33/9 58/20 73/11
73/13 124/1 124/24
129/23 134/25
upward [1] 180/15
upwards [6] 8/5 57/7
82/5 180/24 181/8
181/12
us [40] 5/4 6/14
12/13 14/18 23/2
34/25 36/8 38/9 40/23)
61/15 62/12 89/1
90/20 92/1 95/10 97/2
98/23 105/21 106/25
109/22 112/24 114/3
114/8 115/14 117/21
117/24 118/23 120/6
145/17 146/6 153/6
155/25 157/23 159/18}
161/3 168/23 171/21
173/4 178/17 180/20
use [17] 21/12 47/10
64/11 64/14 68/21
69/5 71/23 118/5
119/9 134/19 135/23
140/20 166/2 169/5
unusual [4] 19/2 76/9
173/16 173/25 174/5
used [15] 5/13 10/13
29/5 58/16 62/19
98/10 98/25 103/21
121/13 131/2 160/21
188/2
useful [2] 41/17
120/11
using [6] 30/23 65/3
88/14 169/2 173/18
189/8
usual [1] 36/8
usually [5] 5/8 11/15
18/25 80/17 131/1
utilise [1] 110/22
utilised [2] 169/18
170/19
utterly [2] 176/20
177/11
Utting [3] 121/9
121/16 127/7
Vv
vacuum [1] 129/16
valid [2] 67/24 68/4
validity [1] 123/9
valuation [1] 87/12
value [3] 54/17 87/25
92/20
values [1] 86/8
various [12] 3/21
38/9 67/22 70/7 125/5
128/3 133/14 140/16
141/9 158/12 170/23
1711/4
VAT [1] 54/12
veracity [1] 154/10
verbatim [1] 176/17
verdict [1] 108/18
verification [1]
149/15
verified [1] 149/20
version [2] 46/19
79/23
very [72] 1/6 1/11
1/25 2/22 3/16 9/22
9/22 11/24 12/25
12/25 14/20 16/5
23/16 25/7 28/16
42/15 42/16 51/19
52/14 65/25 68/15
69/9 69/16 69/24
70/18 74/11 74/23
75/2 78/13 80/18 81/1
81/12 81/25 89/9
89/20 93/9 94/21
94/21 99/2 99/2
103/21 106/1 107/16
109/9 115/4 116/22
119/6 119/13 125/3
128/17 130/7 131/17
132/2 141/5 150/14
157/3 159/12 160/16
160/17 163/14 166/25}
169/13 173/20 178/6
169/16 173/21 187/23)
178/25 179/23 183/1
183/18 184/12 188/16)
192/8 192/16
via [4] 12/10 17/19
36/25 166/13
viability [1] 162/10
Victoria [1] 95/21
view [20] 9/17 22/5
24/22 24/25 26/19
28/9 28/10 29/24 32/9I
32/24 41/17 49/11
52/12 52/23 55/5 59/4
59/13 80/11 82/8
118/19
view/belief [1] 26/19
viewed [1] 43/15
views [1] 71/9
vigorously [1] 55/9
vindicated [2] 132/24)
175/5
virtual [2] 140/17
177/13
vis [2] 57/6 57/6
vis a vis [1] 57/6
visibility [1] 41/25
visit [2] 24/14 59/17
Vizards [1] 19/19
volition [2] 119/16
119/20
Ww
waiting [2] 119/4
167/16
want [22] 6/8 10/4
14/13 28/18 29/24
34/5 45/15 46/10
65/19 68/19 71/2
82/22 86/21 110/13
110/24 111/7 117/25
129/24 162/17 171/25)
190/13 190/21
wanted [13] 5/14
6/19 45/17 48/8 52/3
68/9 68/16 101/23
104/22 111/14 130/9
133/16 176/21
wants [4] 26/23
53/19 137/11 162/24
Ward [3] 97/17 97/17
165/23
Wardle [8] 7/24 8/4
8/18 38/12 62/17
70/11 164/18 182/18
warrants [1] 22/23
Warwick [3] 105/12
142/9 142/10
was [583]
was/is [1] 145/8
wasn't [40] 18/20
36/7 39/19 40/1 43/6
43/11 45/22 47/11
51/9 72/11 72/18 73/2I
75/19 75/23 82/2 82/7
84/13 86/20 94/17
96/16 101/25 111/13
117/12 119/15 126/18)
(77) transaction - wasn't
Ww
wasn't... [15] 135/16
143/2 145/14 151/15
151/20 152/6 155/23
173/8 173/16 174/5
175/13 175/23 176/21
4177/7 177/25
waste [1] 110/14
watched [1] 133/14
way [32] 17/5 19/7
25/4 26/19 27/11
28/13 36/14 45/13
46/2 63/15 67/2 72/2
75/9 82/9 82/14 83/18
90/5 96/10 98/20
109/12 129/15 131/6
149/20 153/8 155/24
157/8 158/5 176/9
180/21 184/24 187/3
188/7
ways [3] 116/25
135/24 157/11
we [320]
we'd [2] 110/5
142/20
we'll [6] 13/23 32/21
136/25 137/15 162/14}
167/24
we're [27] 1/6 5/6
9/14 14/15 36/20
43/17 46/6 47/15
55/11 56/22 62/10
64/4 78/2 87/7 92/25
103/11 115/19 120/3
134/4 136/22 146/17
152/10 156/14 159/5
159/6 161/13 163/17
we've [16] 19/17 21/3}
40/14 50/15 79/1
120/22 122/1 126/5
131/14 131/18 133/14
158/9 160/15 163/22
174/22 182/4
weakness [1] 52/24
weaknesses [1]
49/12
week [9] 42/21 44/16
47/6 57/25 83/12
94/20 159/13 159/23
189/6
Weekly [1] 111/16
weeks [1] 41/14
Weightman [1] 19/19
Weightmans [4]
17/21 18/2 18/13
29/11
welcome [1] 113/17
well [32] 3/24 4/24
13/20 19/16 25/18
26/5 26/23 29/19 54/6
55/2 57/13 59/5 60/8
60/12 70/22 91/10
109/24 133/25 137/4
143/19 152/2 171/24
173/1 173/20 174/15
181/25 183/4 187/19
188/5 188/15 190/20
192/2
wellbeing [5] 90/14
90/22 91/9 92/4 92/17
went [4] 28/10 50/18
125/23 162/20
were [230]
weren't [7] 8/8 19/6
26/3 27/21 94/15
125/4 161/3
West [1] 145/23
what [93] 5/4 20/18
20/22 27/3 27/5 28/19
28/20 33/21 36/9
40/10 41/23 47/20
49/19 51/5 52/23 54/5
56/2 57/18 62/22 67/7
71/12 72/19 78/18
78/22 82/8 84/11 89/8
90/20 91/3 92/14
98/19 104/9 105/21
105/22 106/4 109/11
110/15 111/10 111/12)
116/10 119/9 120/6
120/24 122/4 123/24
129/22 133/13 133/19}
133/24 137/6 137/16
141/20 144/4 144/12
146/1 148/17 149/9
150/9 150/15 150/17
151/22 151/25 152/12)
153/12 155/12 156/14)
156/21 157/13 158/20)
159/2 159/4 160/3
167/17 168/11 174/7
174/8 176/20 177/25
178/9 179/3 180/18
181/6 181/16 182/6
183/24 184/15 184/25)
185/1 185/6 187/15
189/12 190/4 190/22
what's [3] 132/1
149/5 172/5
whatever [2] 88/14
188/21
whatsoever [4] 19/10
53/9 80/4 158/8
when [32] 4/3 8/1
11/15 12/9 12/13
12/16 43/25 44/17
45/21 65/3 76/10
76/15 81/21 82/1
83/20 94/17 95/12
95/25 101/15 107/23
111/20 127/14 144/7
153/9 163/9 167/8
174/20 183/12 187/23)
188/7 189/8 191/5
where [58] 3/5 11/10
21/4 21/8 32/14 38/24
39/16 41/22 42/22
43/3 45/18 51/15 52/7)
52/22 53/3 53/9 56/8
78/8 79/4 80/17 85/24
88/19 91/21 92/12
95/6 96/11 101/18
104/7 104/20 105/8
111/22 114/3 117/22
118/24 120/4 124/15
127/2 131/22 134/5
136/2 138/19 145/8
153/10 154/13 154/24
156/18 158/13 162/6
167/22 170/18 178/17]
178/19 179/1 188/9
188/18
whereas [1] 138/11
whether [40] 4/3 9/7
29/4 37/9 37/10 41/17
46/10 47/9 51/20
55/25 60/7 65/2 76/3
80/9 80/25 81/2 85/9
85/22 85/23 91/6 92/4
94/10 105/16 107/2
107/3 108/14 109/12
117/17 118/14 127/21
137/19 137/20 145/6
158/1 160/1 162/9
167/11 167/12 178/16
186/13
which [77] 3/17 7/2
11/5 13/21 15/6 16/13
18/22 21/11 22/2
22/17 23/5 25/8 30/12
33/18 36/12 36/13
38/21 38/22 38/25
40/24 44/5 48/24
54/14 54/16 55/3
60/18 66/20 70/18
73/9 79/2 82/22 86/7
87/10 88/1 89/1 90/16
98/10 103/9 104/1
104/24 109/4 112/12
112/24 113/13 113/20
113/25 115/8 116/1
119/23 129/22 134/11
134/12 134/22 135/24
140/15 141/9 142/12
145/11 146/9 146/10
157/11 157/14 159/13
160/12 160/13 166/12
166/14 173/3 173/4
173/25 176/18 179/19}
179/22 180/11 183/10
184/9 185/19
whilst [3] 66/20
132/22 137/5
White [2] 37/20 38/4
whiteboard [1] 9/24
whitewash [1]
184/10
who [116] 6/17 6/18
7/6 7/23 8/17 8/21
11/2 11/13 11/21
13/19 14/18 17/21
24/17 25/12 26/9 28/5)
34/24 35/10 35/12
35/25 36/25 38/10
40/23 40/24 43/10
43/25 49/5 52/10
101/24 102/10 102/15}
52/16 57/15 57/17
63/12 63/15 63/16
69/22 73/23 74/11
78/16 79/14 86/25
92/24 97/5 97/7 97/17,
98/14 99/18 100/22
103/7 103/14 104/3
108/23 112/24 113/7
113/21 118/6 118/12
119/12 119/18 119/21
120/2 124/23 126/10
126/23 127/7 127/8
127/24 129/6 130/25
132/9 134/25 135/13
137/10 137/12 137/13}
137/18 137/20 138/25}
139/11 139/15 143/7
143/9 143/11 143/17
143/21 144/2 146/5
147/15 159/19 160/11
163/23 163/24 164/14
164/20 166/11 166/16}
166/19 168/14 170/8
172/19 173/10 176/25}
179/2 179/12 183/20
186/19 189/23 189/25}
191/21
whole [12] 5/8 6/21
49/16 50/4 63/19 66/1
70/9 81/14 127/15
140/8 157/10 164/21
wholly [4] 75/12
whom [4] 125/22
136/12 155/7 181/20
whose [3] 69/4 126/8
141/2
why [53] 8/24 17/15
27/20 28/17 28/18
28/18 29/8 32/1 32/11
34/4 35/1 44/17 45/23
46/21 47/2 51/7 59/10
62/13 62/23 63/4
67/12 67/12 68/8
68/10 68/18 75/19
75/23 82/13 82/17
100/19 104/11 111/3
111/25 114/9 121/12
122/2 130/1 131/24
132/3 132/5 132/11
135/23 139/6 150/14
151/15 151/20 161/5
161/5 162/3 175/11
175/16 186/7 186/14
wide [1] 128/8
widely [1] 137/21
wider [5] 56/4 88/3
89/4 115/10 135/20
wife [1] 83/8
Wilde [1] 4/10
will [40] 3/17 3/21
16/14 17/5 23/2 33/17]
39/8 40/4 46/22 49/13
49/16 49/17 50/5
54/13 55/7 58/16
57/19 59/23 61/4 63/6
63/20 66/2 67/10 69/6
64/11 64/14 78/12
79/6 84/8 117/17
123/22 132/20 135/8
138/14 146/5 152/24
153/1 153/14 153/17
153/20 154/3 154/17
162/15 163/11 168/6
172/21 173/3 186/25
Wilson [10] 8/16
96/23 97/3 97/4
151/10 151/11 151/15)
152/18 156/2 185/20
win [3] 37/12 54/19
119/3
wings [1] 119/4
Winn [3] 136/24
137/1 137/2
wins [1] 55/1
wish [6] 2/8 125/10
152/15 159/20 179/11
191/18
wished [1] 55/19
wishes [2] 184/17
184/23
wishing [1] 40/15
withdraw [2] 67/2
71/4
within [67] 5/21 7/9
10/1 10/2 13/14 13/24)
14/2 14/8 14/11 18/24)
31/10 35/10 36/24
42/21 43/13 51/23
57/5 57/8 57/14 69/18}
70/7 70/11 73/21
81/22 84/10 84/13
85/5 85/7 86/4 86/17
86/18 87/2 90/25
91/20 99/18 101/7
103/8 109/19 112/3
112/6 112/10 112/20
113/1 118/8 121/18
125/21 126/8 137/17
139/19 140/15 141/16)
144/19 144/23 161/23)
165/2 165/6 166/23
172/24 175/2 180/2
180/16 181/11 186/38
187/13 188/11 189/19}
191/21
without [14] 17/4
18/6 21/19 82/16
88/10 92/1 119/13
119/22 125/18 127/2
129/12 130/1 130/6
187/1
WITN04600211 [1]
120/1
WITN08500100 [4]
3/17 12/1 89/12
179/21
WITN09020115 [1]
19/16
witness [29] 1/15
1/21 3/19 4/2 10/10
11/25 21/7 28/6 41/9
63/9 66/1 89/10 89/12)
(78) wasn't... - witness
Ww
witness... [16] 89/16
95/5 99/4 99/7 99/8
99/10 99/12 99/19
106/14 120/12 127/24}
155/14 163/10 166/22)
169/16 192/12
witnessed [1] 22/7
witnesses [1] 67/9
Wolstenholme [19]
2/12 14/25 15/10
16/23 17/8 19/21
19/25 21/9 21/21 22/8)
27/25 29/3 30/13
30/21 31/6 33/17
60/22 120/5 120/7
Wolstenholme's [3]
22/3 31/3 33/1
won [1] 93/15
won't [2] 172/21
172/22
wondering [1]
140/22
Woodward [12]
34/23 35/1 35/2 35/3
35/8 35/17 44/13
79/11 92/1 100/1
100/22 181/23
word [7] 10/17 10/25
47/10 113/5 185/7
187/24 188/2
wording [5] 42/12
42/22 139/5 139/7
140/20
words [23] 10/9
27/12 27/13 29/4
42/24 66/15 67/4 69/5)
69/20 69/23 70/21
71/5 71/10 71/23 73/2
73/8 135/4 135/7
169/3 169/6 169/11
169/14 190/6
work [12] 5/12 6/3
9/9 18/20 112/16
113/1 147/3 148/8
149/10 150/21 180/3
180/6
worked [11] 4/9 35/3
41/1 41/1 81/24 96/21
96/23 97/25 108/23
180/21 183/20
worker [5] 126/3
130/16 130/19 135/13}
151/23
working [11] 5/5 5/23}
7/8 13/5 28/7 96/1
109/13 121/2 167/10
167/12 167/20
world [1] 12/25
worried [4] 25/4
25/23 26/3 27/21
worry [1] 190/18
worth [3] 41/16 43/12
135/10
would [163] 2/4 7/17
8/5 8/17 8/18 10/22
11/15 11/23 17/18
18/14 19/2 19/9 19/12
20/6 20/10 20/17
20/25 25/13 27/20
28/12 28/18 28/22
28/24 29/2 29/8 32/4
32/5 32/11 34/5 36/13
36/18 39/12 40/12
41/16 43/21 47/6 49/4
49/25 51/7 54/17
57/18 58/17 58/21
58/22 59/22 62/6
62/13 62/24 63/19
63/20 64/22 68/10
68/20 68/21 70/17
70/23 72/5 72/9 72/13)
72/20 73/10 73/10
73/12 75/7 79/5 81/1
81/9 82/3 85/25 86/7
86/16 87/4 87/18 90/1
91/13 91/19 91/21
92/3 92/10 92/20
94/19 95/7 96/13
96/17 98/18 99/11
100/19 101/6 105/14
105/25 106/11 106/19)
106/23 109/9 109/11
109/25 110/9 110/21
110/25 111/12 112/14)
113/13 113/22 115/4
115/14 116/18 117/25)
119/19 120/10 121/23)
125/14 125/25 126/8
126/23 130/12 132/3
132/5 133/21 135/25
137/10 138/5 139/14
139/25 140/1 141/4
143/4 143/11 143/17
144/8 148/4 148/16
150/16 152/8 154/4
154/15 158/17 159/3
161/21 161/25 162/3
162/5 164/1 165/5
165/5 168/3 170/20
171/21 172/18 174/12)
175/11 175/14 176/2
178/12 178/20 179/5
184/5 186/7 187/14
187/20 188/14 189/11
189/23 190/8
wouldn't [6] 36/12
90/25 101/25 146/3
148/16 148/21
wracked [1] 75/22
write [3] 80/15 80/17
417/17
write-off [2] 80/15
80/17
writes [1] 30/8
writing [11] 49/6
57/25 80/25 105/4
105/6 118/17 118/21
123/3 134/11 137/3
188/12
written [8] 30/4 64/25
100/16 119/19 150/9
168/18 176/9 188/20
wrong [10] 21/21
40/9 67/17 77/11
98/23 109/3 109/23
110/6 110/8 192/2
wrongly [1] 15/18
wrote [1] 24/11
Wyles [8] 7/25 8/4
8/19 62/16 70/11
139/4 140/11 182/22
Y
Yeah [1] 97/22
year [5] 87/12 93/1
99/24 110/19 170/17
years [16] 5/1 11/12
13/5 14/21 62/20
75/15 94/11 98/14
107/7 116/15 121/2
143/15 147/24 148/3
148/11 158/12
yes [71] 1/8 4/11 4/25
6/2 6/3 10/2 10/11
14/12 17/11 20/17
20/21 24/2 25/21
36/19 39/14 39/15
44/22 47/23 50/18
54/2 54/3 61/2 61/23
65/11 77/14 80/8 85/4
86/6 87/22 91/18 92/8
97/25 99/10 99/11
99/22 104/11 105/20
107/13 107/15 108/4
108/5 108/20 112/21
115/7 117/14 129/18
131/9 132/8 135/22
136/10 142/24 161/15}
163/18 172/9 174/3
175/24 176/6 176/19
178/1 179/20 184/5
184/6 184/17 185/14
185/18 185/21 186/4
189/21 190/18 192/8
192/18
yesterday [1] 98/9
yesterday's [1]
106/14
yet [4] 109/23 110/7
115/22 128/14
you [698]
you'd [1] 191/2
you'll [4] 74/21 79/3
98/19 151/8
you're [32] 26/11
53/24 56/25 63/25
65/1 77/15 80/1 97/1
102/5 104/11 110/23
118/21 132/16 141/22]
142/22 144/22 157/5
157/21 160/21 161/16
171/18 180/23 181/1
181/16 183/25 184/16}
184/16 184/19 184/22
184/25 186/21 187/15]
you've [38] 3/19 4/9
6/10 8/20 10/5 10/6
14/7 25/19 60/25
72/18 73/2 77/15
77/16 81/11 88/2 89/9
99/15 111/5 116/21
121/17 130/15 151/7
158/17 161/3 164/24
176/9 178/8 178/14
181/19 183/13 186/19]
187/6 187/8 187/8
187/9 188/18 188/18
190/1
Young [1] 149/17
your [128] 1/11 1/17
1/22 2/1 4/2 4/9 4/23
6/9 8/17 10/1 10/4
10/9 11/25 13/24
17/16 19/6 24/22 27/8}
27/13 27/14 28/18
32/2 32/9 32/11 32/18
32/22 34/3 36/18
38/17 39/15 40/6
41/16 42/8 45/12 46/1
46/2 48/5 48/13 50/4
51/16 51/16 52/11
52/23 53/18 55/13
59/23 60/5 65/23
69/19 70/21 73/1 73/6
74/13 76/15 79/8
80/11 81/7 82/8 89/9
93/12 94/11 95/5 95/6
99/13 99/15 102/21
102/22 102/23 106/24}
109/10 109/18 111/24,
113/12 114/19 116/13}
119/16 130/1 130/15
131/3 135/19 139/22
140/2 140/4 140/24
141/7 141/23 142/25
143/25 150/11 150/23}
152/23 158/22 160/3
161/13 162/2 171/9
172/6 173/7 173/16
174/8 174/23 175/7
176/10 176/10 177/3
178/8 178/23 179/1
179/4 179/13 179/18
180/23 181/1 181/7
182/1 182/15 183/6
183/10 183/22 183/23}
184/14 186/1 186/15
187/7 187/10 188/10
189/13 190/4
yours [2] 69/6 177/7
yourself [16] 52/21
56/24 78/5 86/24
94/13 94/16 108/10
116/11 117/1 121/8
163/24 165/16 184/14)
184/19 185/12 185/16
zoom [1] 101/4
(79) witness... - zoom