2nd WS

1. 2.43 - In relation to the phrase “sometimes both”, what was the general understanding at DH when it came to what proportion of haemophiliacs infected with HIV were also infected with Hepatitis C?

3rd WS

1. 2.19 - Did he take Zuckermans documents or copies?

2. 2.29 (4) This appears to be a key piece of information given the 1994 destruction date on a number of the volumes

3. 2.29 (5) - Can he assist with what is meant by she destroyed them “because the BSE disclosure proceed had caused her great difficulty”?

4. 2.31 - What was the course of action that needed to be discussed?

5. 2.35 - The word “low key” appears twice here, why?

6. 2.36(9) - Why “in-house”? Why not characteristics of a public inquiry? (This may be a Q For Fenwick)

7. 2.40 - Is it his understanding that Metters “retained” papers because he expected DH to be sued in relation to HCV?

   1. And so what was retained would have been done with that in mind as far as what we can see here?

8. 2.70 - How likely is it that the “junior official” was Dr Rejman?

9. 3.4 - Does he accept that him saying “no one thought” is speculation?

10. 4.27(2) & (3) & 4.28 - There seems to be no attempt to make these points in relation to HIV?

    1. Is that because DH accepted, but didn’t explicitly state, that it thought self-sufficiency would have prevented many, if not most, HIV infections?

11. 4.37 - Does he accept that, the entire conversation is framed in terms of large pool Factor concentrates?

    1. Does he accept that there were other ways self-sufficiency could, theoretically or otherwise, be achieved? (eg banning large pool factor and using only cryo and small pool)

       1. Was this point ever considered during the course of the entire study? Eg that self-sufficiency doesn’t have to mean in large-pool concentrates?

    2. Further, if these other ways of achieving self-sufficiency were explored, the conclusion that hep c was unavoidable for everyone may well have been different?

12. 4.40 - In relation to “all the information is in the public domain”, did this concern him? If for no other reason, for what he knew about some of the  ACVSB files being destroyed?

    1. On reflection, does he accept that line was not accurate?

       1. If he doesn’t can we make him aware of the apology issued by DH to former ministers about this line (flagged in my oral evidence) and ask again.

13. 4.41 - Did he have any sense, at this time, of what would have been grounds for a public inquiry? What would it have taken at that time?

    1. Were there any formal  guidelines in this regard?

       1. Should there have been?

14. 4.60 - Would he agree with the position of all these points now?

15. 4.67 - Was several weeks a fair estimate?

16. 4.75 - Is it correct to understand Burgin offered DH the chance to change the draft report?

Non-WS

1. Why wasn’t Dr Rejman interviewed as part of the audit on ACVSB files?