I think that maybe is the fundamental --

I understand that, sir. It's just in terms of the wider culture or practice that's going on, it is inevitable that if evidence is put forward, either by Mr Sherborne's clients or by anonymous witnesses coming forward and contributing themselves, if that evidence is put forward, that ...

I understand.

-- but without knowing the identity.

I can see that, sir. That's my point really. It is quite difficult then to make submissions on whether anonymity may be justified in the abstract without knowing the identity; if, say, the witness is making allegations about newspaper X, in certain circumstances, it may be that newspaper X ...

Sir, I think Mr Garnham may have pre-empted one of the things I was going to raise. It is simply to understand the process by which a witness statement that your Lordship receives and considers of interest, but the witness wants to retain anonymity. Would the witness statement, when it ...

Sir, the only other point we have, we have indicated that we would wish to make an oral opening statement. That's unlikely to be much more than 20 minutes.

Just in terms of start date, I don't think we have anything more to add if the 14th is settled on, and anything which is further to be said with regard to the document management system, and how that's going to operate. You've seen in our letter ...

Sir, I think that is everything.

Sir, I would just reiterate the point about advance notice. If issues can be highlighted, even in their broad sense to witnesses --

I quite understand.

No.

I am grateful. If it is going to be that flexible in terms of this supplemental questioning process, which may not arise very much at all.

To a degree on that front, we would say that there should be an element of transparency in the process, in the extent that there is the power or the ability for another core participant to ask counsel to the Inquiry to ask questions of a particular witness, not their ...

But to that extent, and witnesses may be giving evidence, which is in some respects secondhand, that people in their organisation know about but which they are providing the evidence to the Inquiry for, and in those circumstances we would say, in terms of the appearance of the evidence which ...

I wouldn't want to speculate, sir.

Sir, can I just pick up on this advance notice to witness point that Mr Dingemans has been making submissions in relation to? It is a submission which we would support. Obviously, there is a need for flexibility in how the Inquiry goes about its work. One can see the ...

Yes. That may be a submission for another day when we know more about the --

Absolutely. Our concern was that the notion of suspicion, or the Inquiry were raising concerns based on suspicions should be used in relatively tightly confined circumstances, as the Baha Mousa ruling.

I am grateful. It may be that the civil standard is appropriate. It is just, at this stage, until the level of the detail of the Inquiry --

I am grateful, sir. I think the Guardian had three points in our letter on Friday. Several of those have fallen by the wayside. The standard of proof point, I think our concern, at this stage, was this, that it was potentially premature.

My Lord, I am David Glen, I appear on behalf of Guardian News and Media Limited. My Lord, I will be relatively brief. I adopt, at least in their generality, much of the submissions made by Mr Dingemans a moment ago.

Guardian News and Media Limited is the publishing company ...