From TT:

BW Thats not approp Q
CM I think it is
J Yr defence was drafted by solics
Yes
J Why does para 7 say this re inaccurate reflection
AD The Cs claim were fully and some partially upheld, so claim of full upholding was wrong

J The vast majority were upheld?
AD Yes
CM p162: para 9. Detriment 11: recom that Ix report is biased and proceedurally flawed
Yes
CM Defences on p141/2 and info on p174/5 u characterise only proceedural flaws and miss out bias and unreliability of report. Why latch onto one

CM procedural and not bias?
Dont know. I said they were unsound to use
CM You never said this
I cant see where said this
CM p196, u say it cant be relied on but only cos of procedural flaws. U dont use language unsound or bias
Yes
CM U do this w DSH

From TT:

CM Yr letter to DSH o p1894/5, u say procedurally flawed. So cld suggest C got off on a technicality
I cant speak to how wld be interpreted. The same language is used for all of the letters, incl Dr Flynn.
CM Do u acceptt the dilution of Durrant findings creates risk of further smears

CM by DSH?
I dont know
CM Detriment 9: p1184/5 emails. Likewise p1187/8. Can u put these on reading list? Both Brown and Davis point to chilling effect to fulfil profess obligations
Yes, I can see their concerns
CM Sept 21, just before Cs interogation by DA. Were Browns concerns?

CM Both are asking for the Ix to stop
AD I dont think they are asking for it to stop
CM [reading] yr being told as an org that this continuation is impeding drs from reporting which concerns patient safety
Yes
CM p1189: Ix concluded evid gathering and wont sanction getting more
Yes

From TT:

CM Whole process was contaminated by the process used
I accept that
CM Why when concerns of SG and clinicians that CPO cant sanction more work w them cld u challenge finding s of fact
I met all the colleagues. Clear some in SG had concenrs.

AD Many diff views expressed. All interviews done and then I'd take action at that point.
CM p1759: Durrants findings. [reads re diff being objective and fulfil freedom to speak policy]
Yes
CM No-one independent looked at whether shld persist

AD Was told to speak to eq chairs but I then also realised they were also freedom to speak (talked to Galliano). I gave Gx to her re how to move forward and she commissioned Durrant Ix.
J When aware of concerns u spoke to her again
Yes. She said to speak to eq commission chairs

CM After Cs Gx?
AD JG was my chair throughout. I'd had feedback throughout. This has happened - how shld I appraoch this?
CM Do u accept that 2 profess away from work for months
Yes
CM After C reduced her hrs before leaving and Flynn left
Yes

From TT:

CM Did u overide concerns
I dont feel that I did. was v challenging and that was approach I took
CM U spent more time w DSH than yr own SG team in 21-22? Davis and Brown. Cld add Flynn.
AD Yes
CM Sum time spent to assuage the chilling effect was an away day a yr after the DA report he didnt attend

Yes
CM [ill health?] The C says in her WS that her dignity was violated and had a hostile environment. Central to this was DSHs objection to GMC and NHSE referrals. But u chose to commission reports
Yes. You chose DA
AD I met him yes
CM The impact, detr 10 and 7.

CM On 23 Oct Brown to MP: [reads re Ix and C being off sick and wanting timescales for report] Its impacting on our SG functions. When DA 1st saw DA report was in 2026 in dislosure
Yes
CM So u or the org has evid from her LM that the SG function and her health was impacted
Yes

But still prolongued
Yes
CM Nothing was done w report. It wld be wrong to continue w report as no independent adjudicator of DAs report
BW Thats after Durrants report
CM Report likely to be contested in Dec 21
AD I knew wld be some issue

From TT:

CM p1188: can the draft be shared before finalised for comment. Yr team were entitled to that surely?
AD Idk
CM In yr WS paras 77/8: u say u havent formed a view on outcome when Gx comes in
Yes
CM No action taken whilst Gx in
Yes
CM But Gx was about MP and process behind it
Yes

Correction: about AD
CM It's about you and u sent to yr personal email.
AD I gave to my chair and LM to say had received.
CM U hadnt got a view on the report
Yes. It asked many Qs. I wanted to speak to Gill. It asked many Qs. Then Gx arrived and I recused myself

From TT:

CM p16 of supp: email AD in Jan 22 to Jill re final report and needing to make a decision. The GMC and NHSE involved and am mtg today to give progress. I have to make decisions re 2 drs. U say u hadnt done this yet before Gx, but after protected act presented the final

CM report is presented to GMC and NHSE
BW Thats misleading. The email is here about the top email
J Its an imp clarification
BW p1648 - thats the new one
CM I accept that
J Decision was after the protected act
CM Yes. Report shared in mtg u were at tog with Mark P on 12 Jan
Yes

From TT:

CM Look at email - why is this at bottom of page and not the top? Until last Monday?
AD I cant talk to that
CM U know of the Gx, serious concerns others have of process as well as the C
Yes
CM Read this to yrself.

CM U still urge expedition
A lot has happened here. I asked Gill for timeline and wanted Chair to know had the Cx, IX reort, MPs recommendations, trying to d/w chair that had 2 distressed gps and speed wld be helpful
CM Do u accept the C knew nothing about sharing report until

proceedings. Did u tell her
No I didnt
CM [reads re concerns of further referral to GMC] Yr pursuing the C
No
CM In a mtg w NHSE and GMC yr conveying concern re the C [missed]
AD DA interview list and ppl wanted to know where we were. NHSE regulate the ICB so asked where in process

AD Said e'thing paused whilst waited for Gx which Jill taking forward
CM This isnt in yr WS. Nothing on this
AD I dont know
CM There's a detriment claim of failure to SG Cs reputation. U say in yr WS. This is all detr 10-14.