Did patients mention in the late 1980’s or early 1990’s about taking legal action and if so what did you tell them?

• Para 45 e - Why did you take this approach?

  • When did you begin taking this approach?

• Para 52 - Can he expand on “free of charge”? Does this include commercial concentrates as the sentence appears to suggest?

• Para 53 - The mention of “invoices” is not compatible with the above.

• Para 53 - Does he recall the use of unheated concentrates in 1985 and if so, over what timescale?

• Para 67 - Why do you consider single UK donor units to be an advantage?

• Para 76 - What evidence was made available to you to assert that products “would have been shown to be safe”

  • In what context do you believe products “would have been shown to be safe?” Eg is this in relation to viral risk or something else?

  • If products had not been shown to be safe in respect of viral transmission, do you believe that information should have been conveyed to you and others? / was it?

• In relation to para 8c of this document (litigation) - minutes of meeting that he attended - https://drive.google.com/file/d/1fNcXuqm9RzKPh7P8XeeDvtDx6SvJ6Jr1/view?usp=sharing

  • Does he have any comment on “damage being done to the doctor/patient relationship”?

  • Was he aware of any other doctors acting as expert witnesses for the plaintiffs?

  • Does he know which manufacturer had been joined to the action?

  • Does he know which parts of the main statement of claim the defence were seeking to have struck out and why?

• In relation to para 12d (chronic hepatitis) in the same document as above

  • Did he send samples to Dr Mortimer for HCV testing at this time?

• In relation to this document, can he confirm what was in fact the case as there is conflicting information? - https://drive.google.com/file/d/1Fmc6FzDxBykks3EaZUUndJs1TrNeuV_v/view?usp=sharing