Factor 8

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Dr Andrzej Rejman

Factor 8

DR ANDRZEJ REJMAN

  • 4.9 - Was it his role to make judgements on the likeness of negligence? Did he do this?

    • If no, whose role would this have been?

  • 25.4 - Is it safe to say that there was a shared view within DH that unlicensed products were commonly used within the world of haemophilia treatment and had been for a long time? (Note this also ties in with the doc I submitted for Pickles Q’s: https://www.dropbox.com/s/jasigj5v12o8j0y/If%20this%20gets%20out%202%201990.pdf?dl=0

  • 27.4 - Can he explain how this reconciles 27.1?

  • 31.4 - Whose decision was it to determine what was “appropriate”?

    • Presumably, if something wasn’t shared with a Minister, that it later turned out should have been, would it be that person's fault?

  • 34.2 - Does he recall meetings with William Waldegrave regarding the HIV litigation and if so what was discussed?

    • Does he recall meetings with Tom Sackville regarding the campaign for compensation for those infected with Hepatitis C and if so what was discussed?

  • 44.7 - Is he aware of any attempts that were made to identify other patients in the centre, and/or other centres, that may have received that batch, or be storing it at home?

    • In any event, should this have happened?

  • 47.2 - Is there any evidential basis for this claim or is he simply speculating?

    • If he recalls something specific can he explain?

    • What years or points in time is he talking about?

  • 47.4/47.5 - How can patients ask for something which they are unaware of?

    • Did DH expect haemophilia clinicians to be experts in virology and epidemiology?

  • 83.2 - Who would those officials have been?

  • 86.7 - Be that as it may, what is his comment?

  • 87.4 - Does he accept that document destruction cannot be stopped unless it has been started?

    • Does he know what is meant on Line 2 by “sorted out”

    • What he outlines is one way of explaining what is written regarding the destruction comments. Is another reading, that would be consistent with what is written, that documents were actively being destroyed and that it was being pointed out that this must stop at said point in time? And this could explain one of the reasons why there are a variety of documents known to have existed but which cannot be found by the IBI or others?

  • In relation to DHSC0004359_059 at 6(i) - Can he expand on why this is of “crucial significance”?

    • Is it right to take from this, that in his view at least, it was not possible to look at the entire cohort and conclude there was no fault or negligence because there could have been, depending on a variety of things including the ones he sets out here?

  • https://www.dropbox.com/s/8g2bj4syfz96oqj/DSC00716.JPG?dl=0

    • Can he explain how he can say that all relevant documents have been disclosed, when he says in the next breath that they haven’t even looked through all the papers in their discovery?

  • In relation to DHSC0029810, 2nd Page:

    • Is it right that his view here was that informed consent was essential?

    • How did he know that informed consent had been obtained from the patients to state this in such a matter of fact way?

    • Would his opinion given at para 3 be different, if, it had been known to him that informed consent was not obtained in many cases?

  • In relation to DHSC0042937_032 https://www.dropbox.com/s/cyqz64ugg7xtmi0/_DSC6071.JPG?dl=0

    • In relation to Para 4 - Can he explain the following:

      • Did he agree with what is said at Para 3?

      • Why wasn’t Spence Galbraith the obvious choice? (I ask this having not seen Canavan’s minute or why an alternate was needed)

      • Why wouldn’t these people be independent? 

      • What is his definition of “truly independent” and did he believe that this definition was applicable to all the other expert witnesses that he had been recruiting?

  • https://www.dropbox.com/s/vdzge0281fwgy7n/_DSC7427.JPG?dl=0

    • Does he recall what the anxieties were in Para 1?

  • Going back to my point 5 above, can he explain if he saw Prof Bloom as “truly independent”?

  • Remaining on this theme, it appears the concerns regarding Ludlam were not regarding independence, but that his appearance may cause embarrassment, is that correct?

  • https://www.dropbox.com/s/mqjo73fpreb6vtx/_DSC6889.JPG?dl=0

    • In connection with point 5 above, it appears possible that Geoffrey Rose was dropped because of the criticism contained in his Statement, is that correct?

  • https://www.dropbox.com/s/9tti319qt1dtosb/_DSC7181.JPG?dl=0

    • Can he confirm that it was his view that the chances of Factor VIII being HIV positive in 1984 was higher than during the period 1979 - 1982?

  • https://www.dropbox.com/s/taotfu7ai6gjilp/_DSC5773.JPG?dl=0

    • In this letter, Rejman suggests that some information from an expert report be “radically pruned”. How common was it for him to suggest the pruning of expert reports?

  • https://drive.google.com/file/d/1xdOTNm5gCyVdXzDXUBN8pYD3_PwB-3iC/view?usp=sharing

    • Does he know if said documents were ever found/sent? (Note to IBI: I have searched Relativity for dated docs and made notes on the PDF accordingly, only 2 were found there).

    • Is there anything he can add about this, regarding the timing of the 14th December court order date and the announcement of a settlement?

    • Is there any connection between the missing documents and what is said in DHSC0043223

  • https://drive.google.com/file/d/18wywEbqVmzv8YWNIEwGIgQkaZGKirBk3/view?usp=sharing

    • Why did he suggest that "DH does not make available to the RHA/DHAs any information which might be used against the DH"?

      • Was that suggested policy followed through?

    • Was there any specific documentation that he had in mind?

  • Would it be fair to say that many of the expert witnesses approached by DH had a conflict of interest, being directly involved in the material events (eg Bloom, Perry etc), and were therefore unable to provide DH with an independent  view?

  • In WITN4486016, first para. Who/How did Mr Burrage ask? Is he aware of any response to said request?

  • BART0000735 - In relation to HIV patients not being given Interferon - how common practice was this to his knowledge?

    • Why?

  • Would it have been a good idea to include haemophiliacs in the Hepatitis C Lookbacks?

  • DHSC0002467_049 para 11. Is it right to understand DH was unwilling to test haemophiliacs for Hep C as of this time in 1995?

    • What was/is his reaction to receiving this information?

    • (NB: This document is missing the final page which is available in HIM 1 VOL 10)

  • DHSC0002549_045

    • Does he recall what Ms Towner’s minute of 18th July was about/ asking for and for what purpose?

    • Upon learning of this, did he have any particular observations about the low incidence of HIV in Finland - or does he now?

  • Does he recognise any of the signatures on the GEB Files destruction dockets?

  • https://drive.google.com/file/d/1GmZ_nBZujzVgOUuiv-FSD84O5D02eYXz/view?usp=sharing

    • Does he have any insight as to why "the look-back exercise is not being pursued with enough vigour"?

    • Was there any change in “vigour” following this?

  • If Rejman were to have required a blood transfusion in 1990, based on what was known to him about the HCV test available at the time, would he have preferred that blood to have been tested with that test for HCV or not at all?

  • Would it have been important for a person signing the HIV haemophilia litigation undertaking to know that they were most probably infected with HCV?

  • NHBT0000061_175 (Final Paragraph) - Their comments suggest as at Aug 90 there view was the HCV test was “satisfactory” - is that right?

    • Can he expand upon the comments about potential litigation?

      • NB: The final page of this copy on relativity is chopped, there is a complete copy in file OEA 9 9 3. For ease it reads “we think the paper needs to mention the avoidance of litigation as a possible benefit of screening. People might seek damages if they developed cirrhosis, acute or chronic hepatitis as a result of a transfusion when there are satisfactory screening tests available. We know from the experience of haemophiliacs with HIV how real the risk is and the potential costs can be of the order of £100-250,000 a case.“

  • https://drive.google.com/file/d/1VGnyQ7o7hDaRp7yNlLzXV89oeTlTKUMV/view?usp=sharing

    • This approach would make Dr Rizza a gate-keeper of soughts to knowledge of other HCD’s about the availability and info of Ortho’s HCV test?

    • Why would it be undesirable?

  • DHSC0002502_023 (3rd Para) Did he understand this exercise to be a “nuisance”?

    • How commonly held was that view?

  • Did he ever give/prescribe FVIII to haemophilia patients? (late 70’s)

    • Does he understand that some of those patients developed HCV as a result of treatment with FVIII?

    • NB: He did and says in a document but I am unable to locate it. Might speak to conflict of interest/lack of independence in making certain judgements later down the line.

  • Should DH have ensured it had suspended destruction of documents as soon as it knew that it may be subject to legal proceedings? Whether in respect of HIV or HCV.

  • https://drive.google.com/file/d/1gsL5oE4njbWOm29AJ0cM_j5KKJc-Pazm/view?usp=sharing

    • Para 5 - re AIDS exclusions reducing HCV+ donors. Does he agree that this would have also worked the other way round, in that had those exclusions been put in place earlier (or even tougher ones), in say the 1970s, to screen out Hepatitis donors, the amount of HIV+ donations getting through could have been reduced?

  • Additional During Hearings - 10/05/22

  • What he says at 10:25:38 - “they may decide oh well, this is something we can sue him or we can tie him into litigation” - Would this also have been his thinking in 1990, 1994,1995 etc?

  • With what he outlines at 12:06:35 - Did he notice any particular patterns or themes in the types of people who had been infected with HIV in terms of product type etc?

  • He says at 12:08:35 (And earlier in his evidence re the list of documents), so two occasions at least, where he took documents/files home. Did he ever take any of the GEB files home/is it possible he did?

  • 12:13:43 - Why wouldn’t DH use its own officials as expert witnesses?

  • He says Burrage got GEB files from DRO, but the 2000 Audit specifically says that didn’t happen - Can he clarify? Perhaps it’s helpful to take him to the audit.