First of all, the group in questions one, we already know the answers to the majority of those questions. They were covered in the evidence of the editors and of Sly Bailey, our chief executive, on 16 January. No one at the Mirror was fired, no one was disciplined, and just to summarise very shortly, what Mrs Bailey said was that in 2006, following the publication of the ICO report "What price privacy?", Trinity Mirror had adopted what she described as a forward-looking approach, not declaring an amnesty and making very, very, very clear, she said, what was acceptable and what was completely and absolutely unacceptable. If, back then in January, there had been relevant additional questions to ask, they should have been submitted then.
In relation to the last of the four subsidiary questions in question one, namely are the journalists still working for the newspaper and even being appropriated to senior positions, the Inquiry's consistent approach, rightly in our submission, has been not to identify individual journalists.
In relation to question 2, the procedure of this Inquiry is, we submit, not a Trojan horse to fish for disclosure which cannot be obtained by other means. I think that's a terrible mixed metaphor, but I hope my meaning is clear. You will doubtless be aware that the ICO has established, I believe since the commencement of this Inquiry, a fast-track service whereby individuals can find out, by means of a subject access request under the DPA, if the Whittamore notebooks contain any information about them. That is route that is open, and there was certainly nothing in Mr Gilmour's evidence to suggest that information was still being retained, let alone used, nine years after it had been seized. Indeed, very much the contrary, in the light of what Mr Thomas and Mr Graham have said.
My final, final point is this. Following the hearing on 2 December last year, the data sticks with the Whittamore information on them were released to the core participants, including Mr Sherborne and his client. They were released precisely so that, having analysed them, they could make submissions on the contents. It appears that that is an option that they have declined to take. They have chosen not to do so, and now, very, very late in the day, nearly six months later, they adopt this procedure, which will involve going back over Module 1 and involve a massive exercise both for the participants, if they are ordered to undertake it, but also for the Inquiry subsequently to analyse it. In my submission, it is a simply hopeless application.