Day 17

(1) Bank St Petersburg PJSC (2) Alexander Savelyev v (1) Vitaly Arkhangelsky (2) Julia Arkhangelskaya (3) Oslo Marine Group Ports
LLC

Day 17 — Redacted

February 26, 2016

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February 26, 2016 Day 17 — Redacted

1 Friday, 26 February 2016 1 is that apart from this, I did give additional evidence
2 (9.45 am) 2 and there is a lot that I am sure I can add. We only
3 MR JUSTICE HILDYARD: Yes, well good morning. 3 have four pages in this witness statement. This is
4 I think the first thing we have to do is swear in 4 definitely all true, but this is not all the evidence
5 Mrs Arkhangelskaya. 5 that I have given in these proceedings because, apart
6 I received an e-mail overnight from Mr Stroilov, and 6 from that, I think we — I had an affidavit that I swore
7 I dare say you did too, but my understanding is that 7 in — I think in 2012, then I was not feeling well.
8 those are matters to be deferred until Monday. 8 I think I gave yet another affidavit. So there have
9 MR LORD: Yes, and, my Lord, the material that I put to 9 been quite a few documents in these proceedings.
10 Dr Arkhangelsky was all drawn from the Magnum documents, 10 The very first affidavit I think was sworn in 2012,
11 I put some documents to him from Magnum, but 11 speaking from memory. This is the 2015 document, so
12 I understand he has issues he wants to raise in that 12 this is a general witness statement. This is
13 regard. 13 a collation of all the information, as it were.
14 MR JUSTICE HILDYARD: That may not be a sufficient answer 14 MR JUSTICE HILDYARD: Yes. I understand that, but I am
15 but, in any event, it is a matter to be deferred until 15 taking this document to be what you wish to be your
16 Monday. 16 evidence at this hearing.
17 MR LORD: Exactly. 17 A. Yes. Yes.
18 MR JUSTICE HILDYARD: Yes. Good. Well, please could 18 MR JUSTICE HILDYARD: Very good. Well, Mr Lord will have
19 Mrs Arkhangelskaya be sworn in. 19 some questions for you.
20 Would you stand, please. 20 Cross-examination by MR LORD
21 MRS JULIA ALEKSANDROVNA ARKHANGELSKY (Affirmed) 21 MR LORD: Mrs Arkhangelskaya, could you please look at
22 (All questions and answers interpreted except where 22 paragraphs 5 and 6 of your witness statement, which
23 otherwise indicated) 23 start at {C1/2/9} in the Russian version, and {C1/2/2}
24 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, do sit down. You 24 in the English translation, please.
25 have some water in front of you, and the translators 25 Could you please read paragraphs 5 and 6 to
1 3

1 will do their business.

2 Please can you be taken to file {C1/2/1}, {C1/2/9}.

3 That is a Russian translation of a document which begins

4 at {C1/2/1}.

5 A. Is this 2/1 or 2/9, because mine starts with 2/9. What

6 I have in front of me is {C1/2/9}.

7 MR JUSTICE HILDYARD: Yes, and you should be able to see

8 that on the screen as well, on the left-hand side.

9 Go to page 14, please, {C1/2/14}; is that your

10 signature on that document?

11 A. Yes, it is. Yes, I did sign this document.

12 MR JUSTICE HILDYARD: Is that document your witness

13 statement in these proceedings?

14 A. Bear with me one second, I will just go through this

15 document, if I may. Yes, that is true.

16 MR JUSTICE HILDYARD: Have you carefully read that statement

17 again before coming here today?

18 A. Well, maybe not extremely careful, but I am very well

19 familiar with the contents of this document.

20 MR JUSTICE HILDYARD: And are the contents of it true?

21 A. I think so, yes, of course.

22 MR JUSTICE HILDYARD: Are there any revisions you wish to

23 make to it, or additions which you want to tell me about

24 before you are cross-examined?

25 A. Well, there is only one thing that I would like to add;

1 yourself, please. (Pause)

2 A. Yes, I have read those paragraphs.

3 Q. And, according to paragraph 5, you are a graduate in

4 accountancy and audit; is that right?

5 A. Yes, that is correct.

6 Q. And how many years did you study for, in order to get

7 that degree?

8 A. At college it took me two years’ general economic

9 studies, plus a further three years of more specialised,

10 in-depth study, for a total of five years.

11 Q. And what was the more specialised study that you

12 undertook?

13 A. Economics, accounting, a little bit of everything.

14 Finance, insurance. As we say in Russia: now that you

15 have your degree, forget about everything that you have

16 learned; now you start the actual, real work.

17 Q. And as part of that five years’ study, were you taught

18 accounting standards?

19 A. Are you referring to what we call the theory of

20 accountancy, because in Russia we have theory and then

21 practice. So accounting standards is something that

22 I am not sure I quite understand what you are referring

23 to.

24 Is that theory or practice? Is that the rules and

25 regulations applying to accountancy?

2 4
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1 Q. First, did you study any accountancy theory? 1 one who was properly qualified to do that, and she had
2 A. Yes. I did. 2 studied this on purpose; she actually took a specialised
3 Q. And you graduated in that subject, did you? 3 course in this.
4 A. Yes, you can put it that way. 4 I did not do that. I understand what you are
5 Q. And did you also, as part of your study, study 5 referring to, sir, this is called IFRS. I do recall
6 accounting rules, in other words the more practical side 6 that those rules were quite different from Russian
7 of accounting? 7 accounting standards. That I do recall.
8 A. Well, there were quite a few textbooks that we had to 8 Q. And did you ever gain any professional qualifications in
9 read. I did — I did study the theory of accounting, 9 either accountancy or audit?
10 yes. 10 A. Yes. I had an auditor’s diploma, which was given to me
11 Q. But did you also study — and I suggest it must be 11 after I had gained, I think, three years of hands-on
12 likely you would have studied — some of the practice of 12 experience, and speaking from memory, I think it was in
13 accounting; in other words the sort of rules, 13 2001, but I am not sure. But, mind you, that was
14 the accounting rules that are used by accountants and 14 Russian audit. It was not international standards
15 auditors? 15 audit. So I had to sit some exams, and I had to have
16 A. Well, this is practice and this is something that I — 16 some hands-on experience, because exams are something
17 to use an English expression — was learning by doing. 17 that you do automatically, but the important thing is
18 The college, or university, was more a theoretical 18 hands-on experience.
19 foundation, and then I picked up all the practical 19 So you sit an exam — between you and me, this is
20 things while working. 20 not a difficult thing to do — but then what counts is
21 Q. So is it your evidence that when you were studying for 21 hands-on experience. The exam lasts about 90 minutes,
22 a degree in accountancy and audit at St Petersburg State 22 there are several questions that you have to answer,
23 University of Economics and Finance, the course did not 23 then that degree has to be confirmed once a year.
24 include tuition in practical accounting standards? 24 So when I went on maternity leave, my degree — how
25 I think you know what I mean, Mrs Arkhangelskaya. I’m 25 should I put it? Because I had not confirmed it, it
5 7

1 talking about the sort of accounting standards and rules

2 that are applied; in other words the way accountants are

3 meant to draw up accounts.

4 A. Well, of course we did have tests, we did have practical

5 tests, but it was more theoretical. It was not real,

6 hands-on accounting.

7 Now, if you’re interested in my experience and

8 expertise, then I would be more than happy to tell you

9 more about the work that I actually did after graduating

10 from university, but university was more theoretical

11 than practical.

12 Q. And have you at any stage studied any accounting rules,

13 such as Russian accounting rules, for example?

14 A. Yes. Something along those lines. Mind you, I stopped

15 working many years ago, but I do recall studying

16 something along those lines.

17 Q. And what about more international accounting rules, like

18 the IFRS standards?

19 A. I understand what you are referring to. We did not

20 study this at college, but my company, Marketing,

21 Consulting and Design, the company where I worked, we

22 did offer those services. I think it was in 2003, when

23 I stopped working there and went on maternity leave,

24 that company was just beginning to offer that service.

25 We only had one lady in our department who was the only

1 sort of expired automatically.

2 But for a year or two I was a holder of that

3 diploma. Mind you, the company where I worked, if it

4 was to be able to carry on audit, it had to have

5 a number of qualified people; not assistants, but actual

6 auditors, with hands-on experience and people who are

7 qualified. That was the requirement for the company to

8 be able to carry on that business.

9 Q. And which professional body gave you that accreditation?

10 A. Are you referring to my auditor’s diploma? To be

11 honest, I do not recall who did that. Our HR department

12 asked us to undergo certain studies. It was all paid by

13 the company, but to be honest, sitting here today, I do

14 not recall the name of that body that was in charge of

15 actually issuing diplomas or degrees in St Petersburg at

16 that time.

17 Q. Presumably, Mrs Arkhangelskaya, it would be fair to say

18 that you have gained a good degree of experience in

19 the field of accounting?

20 A. Well, I wouldn’t put it that way. Let’s say that after

21 graduation, I think I spent three, four, maybe five —

22 somewhere between four and five years. I wouldn’t

23 describe myself as a highly qualified specialist, or

24 expert. That was definitely not the case, because you

25 only begin gaining practical, hands-on experience after

6 8
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1 graduation.

2 But, of course, I understand this better than

3 someone who is a film director or a scientist.

4 I definitely understand more about accounting than some

5 other people around.

6 Q. And have you had experience of drawing up company

7 accounts?

8 A. No. No. I never did that myself, unfortunately. It

9 just so happened that I — upon graduation I immediately

10 joined an auditing company. I was a junior assistant,

11 then an assistant, and the assistants and junior

12 assistants always report to a senior auditor. They

13 report to him and they assist him in collating

14 information. Lots of management accounts, primary

15 records, that’s the kind of thing that I was more in

16 charge of. But I did not carry on any accounting

17 business myself.

18 Mind you, this was also an auditing company; it was

19 not an accountancy firm. It was an audit firm, so we

20 did not do much accounting. There was consultancy,

21 audit, advisory, but I don’t think we actually did any

22 proper accounting.

23 Q. So when you were doing audit work, wouldn’t that involve

24 checking and reviewing accounts?

25 A. Well, if you are referring to the balance sheet and the

1 statement, which is on {C1/2/10}, or {C1/2/2} in

2 the English, you have given evidence that after

3 university you went to work for a company called MKD; do

4 you see that?

5 A. Yes.

6 Q. And MKD, according to you, provides audit and consulting

7 services; can you see that?

8 A. Yes. I think this is the case.

9 Q. Is it right that MKD audited OMG?

10 A. I think it did, but at that time I was no longer

11 employed by that company for all practical purposes.

12 I do recall my husband meeting the director of MKD at

13 some point in time, and I know they did some work for

14 them, but that’s about all I can say about this,

15 unfortunately.

16 Q. I wonder if we could see {D32/520/61}, please.

17 Can you see this page, Mrs Arkhangelskaya?

18 A. Yes, I can. I have not read it yet. If you want me to

19 read it, I will read it, but I can see it.

20 Q. Could we go to page 61, please. {D32/520/61}.

21 A. Yes.

22 Q. It should be up on screen in a minute.

23 Can you see, Mrs Arkhangelskaya, that seems to be

24 an auditor’s certificate from MKD, but please correct me

25 if I am wrong about that.

9

1 profit and loss account, it’s obviously something that

2 I did see, but so far as taxes and accounts are

3 concerned, this is something that the chief auditor

4 does. All the others were in charge of bits and pieces

5 of accounting; I was in charge of payroll, social

6 security, working capital, intangibles … what else?

7 You know, the things that beginners are usually in

8 charge of. You know, things that related to tax

9 accounting and things like that were something that was

10 usually done by the senior auditors.

11 So when a group runs an audit, a group is put

12 together, headed by a chief auditor, two junior

13 qualified auditors, and two assistants and junior

14 assistants who are in charge of smaller bits and pieces

15 of accounting documentation, the things that I’ve just

16 referred to.

17 But obviously when we started running an audit in

18 a company, we obviously had to look into the business of

19 the company. We had to read their accounts, just for us

20 to understand what I am looking at. If we are looking

21 at, for instance, materials, and if materials account

22 for 0.01 per cent, then it is less important, but if

23 assets — if that accounts for a larger portion of that,

24 I would definitely have to pay more attention to that.

25 Q. And if you look, please, at paragraph 6 of your witness

11

1 A. I am afraid I cannot say anything about this. I see

2 exactly the same document that you can see. It says

3 «Auditor’s opinion», the way I see it. But I cannot add

4 anything apart from that.

5 Q. And what does it say in the bottom left-hand of

6 the page?

7 A. We have the date and then it says «Director-General of

8 MKD, Yuri Voropaev». What else …

9 Q. I think we have the English up on the screen now, thank

10 you for that, {D32/520/3}, and it looks, doesn’t it, as

11 if MKD have given this audit statement on

12 25 August 2008?

13 A. I presume so, yes. That must be the case.

14 Q. And did MKD audit OMG accounts before the year 2007, to

15 the best of your knowledge?

16 A. I do not really know when any audit was done, if any.

17 It says here 2007, but that’s about all I can say.

18 What I can say, beyond reasonable doubt, is that

19 there was no relationship between MKD and my husband or

20 his companies at the time when I was employed by the

21 company, because I know that my husband only met

22 Mr Voropaev several years after that.

23 Q. If we go, please, back to paragraph 6 of your witness

24 statement, {C1/2/10}, and {C1/2/2} in the English,

25 please, Mrs Arkhangelskaya, you say in that paragraph,

10 12
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1 the last sentence:

2 «I continued formally to be employed by MKD until

3 2012, although from 2003 onwards I was either on

4 (principally unpaid) maternity leave or childcare

5 leave.»

6 Is that right?

7 A. Yes, absolutely.

8 Q. But you were still formally an employee of MKD up to

9 2012?

10 A. From a purely pro forma point of view only.

11 Q. When you worked at MKD, were you ever involved in any of

12 the audit of any OMG accounts or businesses?

13 A. I finished work, as it says in my statement, in 2003,

14 in January, and after that I haven’t actually spent

15 a single day at MKD. My employment book, my labour book

16 was there, but no more than that, because in Russia,

17 there is a concept of maternity leave. There is one

18 year of paid maternity leave, and your work position is

19 kept for you, kept open for another three years.

20 Since I have three children, I simply left my labour

21 record book, my employment book, I left it there. But

22 after January 2003 I haven’t worked a single day at MKD.

23 I’ve never visited them. I came to the accounts office

24 a couple of times, or three times, to sign for child

25 benefits, and that’s it.

1 Group companies and was not involved in their management

2 in any way.»

3 Can you see that, Mrs Arkhangelskaya?

4 A. Yes, I can see the paragraph. I am listening to

5 the interpretation. I don’t know what exactly is

6 discussed here, and what is your question, sir?

7 Q. Would you agree with a statement that you were only ever

8 a shareholder in Group Oslo Marine companies, and that

9 you were never involved in their management in any way?

10 A. Could you please clarify: would that be a general

11 question, or is that regarding the specific paragraph

12 number 27, which I don’t understand very well?

13 Q. Would it be right to say that there were times when you

14 were involved in the management of OMG group companies?

15 A. I’m sorry, sir. If I understood your question

16 correctly, ever — have I done ever anything for OMG

17 companies? Could you please reformulate your question,

18 because I still don’t seem to understand it.

19 Q. Sorry, it’s my …?

20 A. Because what you are saying here in paragraph 27, it

21 talks about something about ownership, about 90 per cent

22 and 10 per cent, and you are asking about management.

23 Prior to that there was an audit related question. I’m

24 very sorry, perhaps I am stressed out. I honestly do

25 not understand.

13 15
1 Q. Yes, but that wasn’t quite the question, 1 Q. All right, I will ask it again. Could you tell his
2 Mrs Arkhangelskaya. Before you went on maternity leave, 2 Lordship whether you were ever involved in
3 were you ever involved, when you were at MKD, in any 3 the management of any OMG group company?
4 auditing of any OMG company, or any company in which 4 A. So the word «management» is important; is that correct?
5 Dr Arkhangelsky had an interest? 5 No, I definitely was not ever involved in management.
6 A. No. Moreover, not myself, not even the company did that 6 Q. When you say the word «management» is important; do you
7 in my absence in 2003. Prior to 2003, it was nothing of 7 understand what the word «management» means?
8 sorts, definitely. 8 A. Sir, you are referring me to the paragraph 27, saying
9 Q. Could I ask you, please, to be shown {C1/1/8}, please, 9 that I was an owner. Maybe, maybe I was an owner, but
10 and paragraph 27 of Dr Arkhangelsky’s witness statement. 10 owning and managing are different things, aren’t they?
11 This may need to be translated into Russian for the 11 Therefore, I am just making sure I understand the
12 witness because this document is in English. 12 question.
13 Mrs Arkhangelskaya, could you see paragraph 27, 13 Is the question about whether I held the
14 please. If I read it out to you, then it can perhaps be 14 10 per cent, or is it about me managing something?
15 translated into Russian: 15 I was never managing the company, I never held any
16 «Scan was founded in September 2001. It was wholly 16 management positions in the company, and this is
17 owned by Group Oslo Marine LLC (‘GOM’), which was 17 something I said in my witness statement: my role was
18 ultimately owned 90 per cent by me and 10 per cent by my 18 always very minimal. It was rather a role of a wife
19 wife.» 19 that holds some share capital, no more, no less.
20 If it could be translated into Russian for the 20 Q. I wonder, could you be shown, please, your second
21 interpreter. 21 affidavit in these proceedings; it’s at {G1/21/2}.
22 THE INTERPRETER: It’s done, sir. This is the interpreter 22 Mrs Arkhangelskaya, this is a translation of your
23 speaking. 23 affidavit, and you say this in paragraph 6 —
24 MR LORD: Thank you: 24 MR JUSTICE HILDYARD: Do we have the original?
25 «However, my wife was only ever a shareholder in 25 MR LORD: No, I don’t think we do, my Lord, unfortunately.
14 16
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1 I don’t think it is on Magnum. It should be. I don’t

2 know if we can try and get that.

3 MR JUSTICE HILDYARD: Well, there we are. You had best …

4 MR LORD: I will try and do the best I can.

5 Sorry, Mrs Arkhangelskaya. In paragraph 5 you say:

6 «Although my husband and I ultimately own the

7 Vyborg Port (50 per cent each through Oslo Marine Group

8 Ports LLC), we have received no income from it since the

9 commencement of this litigation.»

10 Then in paragraph 6 you say:

11 «Although I do not think this amounts to ‘income’

12 within the meaning of the Order, I think I should

13 disclose that I am employed by the Vyborg Port as

14 a financial controller. I receive salary of

15 approximately €91,000 (£71,000) per annum.»

16 Is that right — and this affidavit,

17 Mrs Arkhangelskaya, was filed on 20 July 2012.

18 Is it right that by that date, you had been employed

19 by Vyborg Port as a financial controller?

20 A. Yes. If you imagine what a labour record book is in

21 Russia, it’s a book shows — it basically is kept at the

22 place of your employment and, as I said, up to 2012 my

23 labour record book was at MKD. It was simply sitting

24 there. That means my labour record was accruing, my

25 time was accruing, and then when I got employed at that

1 paragraph 14 of your second affidavit filed in these

2 proceedings?

3 A. Sir, my involvement; are you asking about Vyborg Port,

4 or Petrograd?

5 Q. You say in the affidavit:

6 «… I had only a very limited involvement in

7 the business activities of Oslo Marine Group (with the

8 exception of my work for Vyborg Port and for

9 Petrograd).»

10 So, Mrs Arkhangelskaya, I take from that that you

11 had done more than only limited — you had been more

12 than only — sorry — you had had more than only

13 a limited involvement in the business activities of

14 Vyborg Port and Petrograd. So I am asking you to tell

15 his Lordship the nature of that involvement, please.

16 A. Vyborg Port, my main responsibility for the most part

17 was actually receiving salary.

18 For Petrograd, I was more involved with Petrograd

19 and, if you like, I can tell some more.

20 Q. Can we first deal with what involvement you had in

21 the business activities of Vyborg Port, please?

22 A. In 2012, if we are discussing that time period,

23 I already lived in Nice for three years. Since my

24 husband at that point in time still remains an owner —

25 I to some degree as well, but he was for the most

17 19
1 company, at Vyborg, that is true, but my functions were 1 part — as far I understand he was also involved in
2 minimal because I was an owner and my husband was 2 the management at that point in time, and I would like
3 an owner. I was receiving a salary there, that is true. 3 to state one more time: when the husband is an owner, it
4 Q. And what were the responsibilities you performed in 4 is quite all right that the wife also draws a salary.
5 the role of financial controller for Vyborg Port? 5 Just to say one more time: I was not involved in
6 A. Minimal responsibilities. For the most part, that was 6 anything special there, because at that point in time,
7 drawing salary, because in Russia there is a concept: if 7 my work was over and I lived in Nice.
8 your husband is an owner, if he works at the enterprise, 8 Q. And have you been more involved in the business
9 the wife is employed at the same place because the wife 9 activities of Vyborg Port since the time of this
10 needs a tax declaration, the wife needs to be paying 10 affidavit in July 2012?
11 pensions, the wife’s labour record book should look 11 A. No. Not at all. Quite the contrary.
12 good. So my responsibilities were, to put it this way, 12 Q. I wonder, could you be shown —
13 minimal. 13 MR JUSTICE HILDYARD: Mr Lord, does this go to a particular
14 Q. And could you look at paragraph 14, please, of that 14 pleaded issue?
15 affidavit on {G1/21/3}. I am going to ask you — I am 15 MR LORD: Sorry, my Lord?
16 going to read out a sentence towards the end of that 16 MR JUSTICE HILDYARD: Are you on credibility or are you
17 paragraph, where you say this: 17 pleaded issues?
18 «Many of the questions relate to matters outside my 18 MR LORD: My Lord, I’m potentially on —
19 knowledge, as I had only a very limited involvement in 19 MR JUSTICE HILDYARD: We have taken some time on this.
20 the business activities of Oslo Marine Group (with the 20 MR LORD: I’m potentially on both issues. I’m entitled to
21 exception of my work for Vyborg Port and for 21 explore this witness’s familiarity with the OMG business
22 Petrograd).». 22 before I ask her questions about the OMG business.
23 I wonder, Mrs Arkhangelskaya, could you tell his 23 MR JUSTICE HILDYARD: Well, yes, but have you not nearly
24 Lordship what the involvement was that you had in 24 done that?
25 Vyborg Port that you appear to be referring to in 25 MR LORD: Yes.
18 20
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1 MR JUSTICE HILDYARD: Yes. Good.

2 MR LORD: Could you be shown, please, {H1/6/7}, which is the

3 first page of your third affidavit in these proceedings,

4 and the Russian version is available. {H1/6/3} I would

5 like you, please, to go to paragraph 14 at {H1/6/9} and

6 the English is {H1/6/5}.

7 Could you read paragraph 14, please,

8 Mrs Arkhangelskaya, to yourself?

9 A. I have read it, sir.

10 Q. And can you confirm that the contents are true, as far

11 as you are concerned today?

12 A. My role? Rather, this is discussing my discussions with

13 my husband. I communicated with the employees of

14 Vyborg Port, but that was very little of that, believe

15 me.

16 Q. And this affidavit was sworn in October 2012; would it

17 be right to say that you have carried on carrying out

18 those sorts of work for Vyborg Port since October 2012?

19 A. I would not be able to say whether it was 2012 or 2013.

20 I think — now I might be mistaken. Up to 2013 my

21 husband was involved in the daily operations of

22 Vyborg Port, so he did discuss some issues with me, but

23 that was at the level of, you see, in general discussion

24 level, up to 2013; but after 2013, as far as

25 I understand, he was not involved in the port

1 » … that he [that’s Dr Arkhangelsky] has invested

2 into a creation of an important economical resource in

3 port and maritime sector of the ports of St Petersburg

4 and Vyborg and that he became the General Director and

5 the main shareholder of OMG holding created in 2001 to

6 ensure the unified management of fifty companies that he

7 managed together with his wife Mrs Tarasova spouse

8 Arkhangelskaya, and his mother-in-law…»

9 Is it right, Mrs Arkhangelskaya, that you did carry

10 out a management — at least some management role in

11 relation to OMG?

12 A. Sorry, I’m not quite sure why that court decision —

13 French court decision was shown to me, and whether

14 that’s relevant. As I already told your colleague who

15 cross-examined me, I do not recall exactly whether in

16 2012 or 2013, and now I’ve been saying the same thing

17 for half an hour: my role was minimal. I have

18 a husband, and a husband and wife are minding their own

19 thing. My thing, my business, was my kids. So you are

20 trying to ascertain as to what degree my role was

21 minimal: it was very minimal.

22 Q. And, Mrs Arkhangelskaya, is it right that your mother

23 has played a role in the management of OMG group

24 companies? There’s no — sorry, Mrs Arkhangelskaya,

25 there is no problem; I’m not criticising that. I am not

21

1 activities. After 2012, the answer rather would be no.

2 Q. So when did you cease to carry out those sort of

3 activities in relation to Vyborg Port?

4 A. Sir, do you mean the way it says in paragraph 14? Some

5 discussions, some discussion of daily operations? Do

6 I understand you correctly, sir?

7 Q. Yes, I was just checking, I was just trying to establish

8 whether you have carried on doing those sort of things

9 in relation to Vyborg Port since the date you gave this

10 statement in October 2012; that’s all.

11 A. I think I would not be able to pinpoint the exact month,

12 but after 2013, the answer would be rather no than yes.

13 Q. Could you be shown, please, {N21/50/83}, which is

14 a translation from the French of a decision of the

15 French Asylum Court in March 2012. I just want you to

16 go, please, or I will take you to, {N21/50/88}.

17 This is a translation of the judgment of this

18 tribunal, and about a quarter of the way down the page,

19 starting — well, it’s the first big paragraph starting:

20 «Considering that the documents contained in

21 the file and the statements made in the public hearing

22 before the Court allow to consider as proven the fact

23 that …»

24 And so it goes on. About seven lines down, this

25 judgment records this:

23

1 making any criticism. I just want to establish —

2 A. I understand, of course, yes.

3 Q. I am just trying to establish the roles that various

4 people have played in OMG companies before I ask you

5 questions about them.

6 A. Thank you, sir. No problem.

7 Could you please repeat your last question?

8 Q. Has your mother, Mrs Tarasova, played a role in managing

9 any OMG companies at any time?

10 A. The only thing, could I just clarify, is it indeed me,

11 Mrs Tarasova, or is it my mother mentioned here in the

12 court statement, because Tarasova was my maiden name.

13 Q. Well, it seems, Mrs Arkhangelskaya, to refer to both.

14 It seems to refer to you and then it seems to refer to

15 Dr Arkhangelsky’s mother-in-law; in other words, your

16 mother.

17 A. Well, Mrs Tarasova, this is me in French. It doesn’t

18 say «mother-in-law», because I am Tarasova, but my

19 second name, my double-barreled name, my husband’s name,

20 is Arkhangelskaya, so it’s very strange the way it was

21 mentioned in the French proceedings.

22 Does it say mother and does it then say Madame

23 Arkhangelskaya? So it’s not clear to me.

24 Well, my mother, should you be interested, sir, she

25 actually was never involved in anything regarding

22 24
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1 Oslo Marine Group. As far as I recall, she was

2 a nominal director in one of the companies; that was

3 a bank requirement, as far as I can recall, to use

4 a different name.

5 Q. I wonder, could you be shown the French version of this

6 judgment at {N21/50/95}.

7 A. That would be great, it is easier for me to read French.

8 We need to find the correct paragraph though.

9 In this case it doesn’t matter, it’s just are you

10 interested in what is the involvement of my mum and what

11 does it say in the French.

12 Could you please tell me in English, sir, what was

13 the first starting word of the paragraph? Where shall

14 I start reading from?

15 Q. «Considérant …»

16 A. Okay, you are saying that even my mum is mentioned here

17 for some reason. «Madame Tarasova, the spouse of

18 Arkhangelsky», yes, that’s me, yes, I can see that,

19 maybe.

20 Q. And then what does it say?

21 A. Yes, my belle-mère, well, that is actually

22 mother-in-law, it’s not even a mum. So my

23 mother-in-law. There must be a small mistake, because

24 my mum is my mum, and belle-mère must be not my mum.

25 I’m sorry.

1 situation very much because anything linked to my

2 husband, everything is very strange. I did not have

3 a quiet life, so my mum was the only person I had, and

4 I really want to protect her, and she was asked by my

5 husband and she couldn’t deny.

6 So she became a nominal director because of her

7 different surname. Maybe he asked me to do the same,

8 but we have the same surname, you see, and my mum had

9 a different surname.

10 But, of course, she was never involved in management

11 anywhere. As of today, she has been retired for

12 13 years, she was assisting me with her grandchildren.

13 Trust me, she doesn’t know anything.

14 Once or twice she even went to be interrogated at

15 the tax office for some reasons, but she was accompanied

16 by a lawyer. I definitely recall that. She also gave

17 a statement saying that she was not involved in

18 anything. But if there are any questions, I’ve

19 forgotten who was answering the questions, whether that

20 was the accountant or the company, now I cannot recall.

21 But I definitely can confirm she was not involved in

22 anything.

23 Q. For that last answer, is it right that your mother lives

24 with or near you in France now?

25 A. Unfortunately, I would not be able to answer that

25 27

1 Q. But it is referring, Mrs Arkhangelskaya, to your husband

2 in this paragraph, and it is referring to his wife,

3 which is you, and then his mother-in-law, which is your

4 mother, isn’t it?

5 A. Maybe. Maybe. Ah, «sa belle-mère», that’s it. Yes,

6 that’s right, so his mother-in-law, indeed, my mum.

7 Q. So could you tell his Lordship whether your mum has

8 played any role in managing any of the OMG companies at

9 any time? It’s not meant to be a criticism,

10 Mrs Arkhangelskaya, I’m just trying to get at the truth.

11 A. I understand the question, sir. I understand what you

12 are saying. Put it this way: for all practical purposes

13 she never played any role, nought per cent. But,

14 legally, as far as I recall, indeed some company was

15 registered in her name; my husband asked her to do that.

16 As far as I can recall, that was a bank requirement to

17 have different surnames, so not to have affiliated

18 entities, or affiliated persons. Now I can’t even

19 recall what bank that was. Maybe it was BSP, because

20 the main projects my husband had there was that bank.

21 But I can definitely confirm that my mum was not

22 involved in any way in the group. Practically, for all

23 practical purposes, she had no involvement, but from the

24 legal viewpoint, she was a director of some company.

25 That is true. I don’t deny it. I didn’t like the

1 question. I would be able to answer to his Lordship

2 straightaway, but not to you, because I’ve got plenty of

3 problems in my life and you can create problems. Not

4 you personally, but the Bank of St Petersburg, because

5 it is a public hearing and this affidavit that we just

6 looked at, I simply had to ask — give an example: after

7 I mentioned my salary at Vyborg Port, two weeks after

8 the affidavit, the tax office arrived at the

9 Vyborg Port, just to check on my salary, nothing else.

10 So now, the question about my mother, I know what

11 it’s coming to.

12 Q. No, what I want to establish is whether you have regular

13 contact with your mother. I don’t mind where she is,

14 just you are in regular contact with her?

15 Actually, in light of your last answer, don’t answer

16 that question. Ignore that question. I will withdraw

17 that question.

18 A. I am very sorry, sir. Simply, yes, if you are

19 interested in that, I have the contact with her.

20 Q. Ignore the question. Ignore the question, I was going

21 to ask you a question about that, but in view of what

22 you have said about the involvement of your mother in

23 any of the companies, I don’t need to ask the question.

24 Sorry, my Lord, I apologise for that.

25 MR JUSTICE HILDYARD: I understand.

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1 MR LORD: It was premised on a — I need to adjust. 1 seemed to be, disclosed, and try to pull together in one
2 Mrs Arkhangelskaya, could I ask, please — are you 2 place ultimately all the documents in issue, so those we
3 all right, Mrs Arkhangelskaya? If you need a break at 3 discussed the other day. But for present purposes,
4 any stage … (Pause) 4 because it needs to be done carefully, I have focused on
5 MR JUSTICE HILDYARD: If you need a break, 5 the documents that I wanted to ask Mrs Arkhangelskaya
6 Mrs Arkhangelskaya — 6 about.
7 A. I’m fine. 7 So this will just be about the spousal consents, if
8 MR LORD: Mrs Arkhangelskaya, I would like to ask you, 8 that’s all right, but I am having the same exercise done
9 please, now, about the spousal consents that may or may 9 and we will address the points and the evidence
10 not have been given by you to various personal 10 your Lordship asked us to address in a more extensive
11 guarantees that your husband may or may not have given; 11 way for the other, relevant documents, if that’s all
12 does that make sense? 12 right.
13 A. Yes. 13 MR JUSTICE HILDYARD: Yes. I’m going to explain this as
14 Q. I wonder, please, Mrs Arkhangelskaya, if you would be 14 best I can to the witness, and you must correct me if
15 kind enough to look in your witness statement. It 15 I am wrong.
16 starts at paragraph 12 on {C1/2/10}, and the English is 16 Mrs Arkhangelskaya, your husband, when he was
17 at {C1/2/2}. 17 cross-examined, was taken to various documents, and on
18 A. I’m very sorry, sir, could you please repeat the page? 18 those documents, in the copies that he was shown, there
19 Q. Yes, certainly, I am sorry about that. It is {C1/2/10} 19 were missing certain entries which your husband expected
20 and it starts at paragraph 12 and goes through to 20 to be on them. An issue arose as to whether he was
21 paragraph 15; can you see that? 21 being shown the original documents, or a copy of
22 A. Yes. 22 the original documents, or such a poor copy as did not
23 Q. Thank you very much. Can you just remind yourself, 23 show what your husband expected to see.
24 Mrs Arkhangelskaya, what you say in those paragraphs 12 24 It transpired that some of the documents that your
25 to 15, please. I wonder if you could just read them to 25 husband was shown were, indeed, either so poorly copied,
29 31

1 yourself and then I will ask you a few questions.

2 (Pause)

3 A. Yes, I have read those paragraphs.

4 MR LORD: My Lord, I am going to ask about, obviously, the

5 spousal consents. I have caused to have a certain

6 amount of enquiry done into the point about the various

7 copies of relevant documents, and I have a schedule,

8 which I would like to hand to your Lordship and to

9 the witness, which I hope is an accurate synopsis of

10 the different versions of the document that appear, as

11 we understand it.

12 I don’t think I need to take the witness through the

13 complicated schedule, but I just want your Lordship to

14 see that and to make sure that any further documents or

15 versions could be raised with her, if your Lordship

16 feels it is appropriate in the light of the points that

17 we, I think, discussed, whenever it was. Your Lordship

18 will recollect the point about the different versions of

19 these documents.

20 MR JUSTICE HILDYARD: I am trying to fish in my memory.

21 MR LORD: It was the stamp issue, my Lord, do you remember?

22 MR JUSTICE HILDYARD: I am sorry, of course, yes, with the

23 rectangular boxes.

24 MR LORD: It is. So what I am trying to do is have done

25 a check of the versions of a document that are, it

1 or were copies of some other version, that although it

2 did not appear on those copies that there were the

3 entries, in fact, in the real versions of those

4 documents, or what are presented to be the real version

5 of those documents, the things your husband thought

6 would be there were there.

7 Now, that is not the case in every document, as

8 I understand it, and the explanation for this has not

9 yet been given, but Mr Lord does not want to ask you

10 about that. That is only the context so you know what

11 we were discussing, because you may not have seen the

12 transcript of your husband’s evidence.

13 All Mr Lord wants to do now is to go through with

14 you the documents which appear to record spousal consent

15 in respect of the documents on which your husband was

16 being examined.

17 Have I made that all thoroughly unclear for you?

18 A. I think I understand, my Lord. I think I understand

19 your explanation. Thank you very much.

20 Mind you, it all depends on the documents that are

21 going to be turned up. If it all refers to OMG, then

22 I may not know much about that, but let’s take a look.

23 MR LORD: Thank you, Mrs Arkhangelskaya. I am only going to

24 put to you the documents that are, we say, signed by or

25 on your behalf, if that’s all right. (Handed).

30 32
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1 Just picking it up, the context is paragraph 12 of

2 your witness statement, where you say: {C1/2/2}

3 {C1/2/10}

4 «To the best of my recollection I did not sign the

5 documents listed in Appendix II to the Defence and

6 Counterclaim listed under numbers A7 to A12 and A29.

7 I did not agree to any personal guarantees being given

8 by or personal loan being taken out by Vitaly, and

9 I would therefore never have signed such documents

10 knowingly. I consider it unlikely that I could have

11 signed any such documents by mistake.»

12 All right? That’s what you say in paragraph 12.

13 Just to be fair to you, so you can see what you are

14 there referring to, if you could be shown, please,

15 the relevant appendix from the defence and counterclaim

16 that you are referring to, it starts at {A1/2/73}.

17 MR JUSTICE HILDYARD: It may be that that doesn’t mean very

18 much without a Russian translation.

19 MR LORD: No. It’s Mrs Arkhangelskaya’s pleading, of

20 course, my Lord, but I will try to help, of course.

21 MR JUSTICE HILDYARD: I know. Yes.

22 MR LORD: Mrs Arkhangelskaya, can you see the bottom half of

23 that page? It should be on screen. Has it come on

24 screen? Sorry, Mrs Arkhangelskaya; can you see that?

25 A. The bottom part in English?

1 question, please?

2 Q. Yes. I was really just getting you to identify that you

3 understood, or explain that you understood, what this

4 document appears to be, first; can you confirm that?

5 That it looks like it is a spousal consent given by you

6 to a personal guarantee given by your husband in favour

7 of Bank of St Petersburg in relation to a loan by the

8 Bank to Onega in June 2006?

9 A. Well, I am afraid I cannot recollect this 2005, I think,

10 or is it 2004, or whatever, document. It’s not very

11 clear in Russian. It’s very difficult to recollect,

12 I am afraid. Well, it looks like it is a document, but

13 it refers to RUB 110 million. Well, I definitely did

14 not have that much cash at that time for me to give any

15 consent.

16 Q. No, Mrs Arkhangelskaya, it’s a loan in that amount.

17 It’s a loan in that amount from the

18 Bank of St Petersburg to Onega, to the company. It’s

19 not coming from you.

20 A. Oh, that I understand, but are you saying that I am

21 vouching for what is being done, and if push comes to

22 shove, I have to fork out RUB 110 million; is that what

23 you are saying?

24 Q. No, I’m suggesting that what this document is is

25 a consent by you, an agreement as the wife of

33

1 Q. Yes.

2 A. And it’s pages 73 and 74, I have that on the screen.

3 {A1/2/74}

4 Q. Thank you very much. And can you see the heading

5 halfway down, it says «Wife’s consent»?

6 It may not matter, Mrs Arkhangelskaya, because I can

7 take you to the relevant document; I just wanted to show

8 you where the relevant contracts appear, or, rather,

9 consents are referred to in your defence.

10 If I could just — then I think you can put that

11 A1 away. I am going to ask you now about the spousal

12 consent for the personal guarantee of Dr Arkhangelsky

13 for the first Onega loan. I wonder if we could have

14 {O1/12/1} on screen, please. If we could have on screen

15 {D13/305/1}.

16 Can you see the document in Russian,

17 Mrs Arkhangelskaya?

18 A. Yes, I can.

19 Q. And that looks as if it is a consent by you to

20 a personal guarantee given by Dr Arkhangelsky in favour

21 of Bank of St Petersburg, in relation to a loan made by

22 the Bank to Onega in June 2006. That’s what it looks

23 like, doesn’t it?

24 A. So what’s your question? Did I sign this document, or

25 does it look like I did? Could you reformulate your

35

1 Dr Arkhangelsky, that he can give a guarantee in

2 relation to this loan to Onega. You are just agreeing.

3 In this document you are saying, as his wife: yes,

4 I consent to that, aren’t you? To him, Dr Arkhangelsky,

5 entering into a guarantee?

6 A. But does my consent amount to a sub guarantee, as it

7 were? I don’t think this is the case. It’s really

8 quite opaque to me. I’m not sure I understand what this

9 all amounts to.

10 I mean, 110 million is way too much for me.

11 Q. Mrs Arkhangelskaya, does that look like your signature

12 on {O1/12/1}?

13 A. The one I have on the screen now in front of me?

14 Q. Yes.

15 A. Well, you see, it looks like my signature, but, you

16 know, it’s two different things: either it looks like my

17 signature, or it is my signature. Now, just because it

18 looks like it is my signature does not necessarily mean

19 it is my signature. Two different things.

20 Q. If I could show you, please, the expert handwriting

21 report of Mr Radley, Mrs Arkhangelskaya, who I think —

22 which report has been served, I think, on your behalf

23 and that of the other defendant in these proceedings.

24 If you could just, please, be shown {E1/6/1}.

25 MR JUSTICE HILDYARD: Mr Lord, should you ask her whether

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1 she signed it in all recollection?

2 MR LORD: Yes, I was going to after I had asked her about

3 this, but I wonder …

4 MR JUSTICE HILDYARD: Yes, if you want. All I’m worried

5 about is if she is not an expert, as it were?

6 MR LORD: No, but I think, in fairness, I can point out what

7 people have said about this signature before I ask her

8 the final question.

9 MR JUSTICE HILDYARD: All right, if you think that’s fair,

10 I will let you proceed.

11 A. Could I just say a few words by way of clarification?

12 I mean, feel free to show me even 100 documents and ask

13 me whether it is my signature or not. I may be hard put

14 to answer, my Lord, simply because I do not recall that

15 document. It is very easy to forge my signature. We

16 are talking huge amounts of money which are involved in

17 these proceedings, therefore, if I do not know the

18 document, how on earth can I be expected to say whether

19 it’s my signature or not if I do not recall the

20 document?

21 If I say this is not my signature, someone will

22 later on come back to me and say that I have been

23 deceiving the court or I have been misleading the court;

24 or vice versa, I say that this is my signature and then

25 I am again accused of deceiving. Therefore I would

1 given at 2006, looks like your signature as at that

2 date.

3 A. Well, if I am expected to answer that question, my

4 answer is it does look like my signature but I am not

5 familiar with this document. That’s the best I can say.

6 You see, it does look like my signature, but I can

7 not say with any certainty at all that I had actually

8 affixed my signature to this particular document,

9 because just because it looks like my signature does not

10 necessarily mean, or does not mean at all, that

11 I affixed my signature to this particular document,

12 particularly because this is a Bank of St Petersburg

13 document generated by BSP, so anything may have

14 happened.

15 MR LORD: Can I suggest, Mrs Arkhangelskaya, that you did

16 sign this document?

17 A. Maybe. I don’t know. I am not familiar with this

18 document — with this 2006 document.

19 Q. I think, out of fairness, I should show you the report

20 of Mr Radley on this. I think I should, in fairness, so

21 you see what’s been said by Mr Radley. I think that

22 would be fair.

23 If you have {E1/6/5}; for his Lordship’s note, it is

24 A12. A12 is the document I am currently asking you

25 about, Mrs Arkhangelskaya, «Consent to Contract of

37 39

1 really be hard put to confirm either way, simply because

2 I do not recall this document. This document is not

3 familiar to me.

4 MR LORD: But you agree that that signature does look like

5 your signature?

6 A. I cannot answer that question, because whatever I say is

7 likely to be used against me. You see, sir, the way you

8 ask questions — you paint me into a corner, Mr Lord,

9 when you ask me whether I agree that this signature

10 looks like my signature. My answer is I do not

11 recollect the document, I am not familiar with this

12 document; therefore, consequently, there is nothing

13 I can say about my signature here, my alleged signature

14 here.

15 Q. Mrs Arkhangelskaya, I think you can say, to the best of

16 your ability, whether what we see on the screen does

17 look like a copy of your signature, or the signature you

18 were using at that time in June 2006. I think you can

19 be asked that, I think.

20 A. No, I am not answering that question.

21 MR JUSTICE HILDYARD: You must answer the question.

22 A. My apologies. I am happy to answer the question by

23 saying «I do not know».

24 MR JUSTICE HILDYARD: What you are being asked is whether

25 you think that what’s on that page, the date of which is

1 Guarantee No 133/06″, 30 June 2006, and you can see

2 «O/12» {O1/12/1}. That is the document Mr Radley is

3 talking about and that he has examined, and it is that

4 document which is on screen in front of you at the

5 moment.

6 If we could have {E1/6/10}, paragraph (vii),

7 Mr Radley says this:

8 «There is very strong evidence to support the

9 proposition that Julia Arkhangelsky wrote the signature

10 on A12 and it is considered highly unlikely that this

11 signature is a copy of her signature style.»

12 So Mr Radley has looked at some comparators and he

13 has looked at this document, {O1/12/1}, and he has given

14 the opinion that there is very strong evidence to

15 support the proposition that you wrote the signature.

16 Now, there’s nothing you want to point to today, is

17 there, now, to disagree with that opinion?

18 A. Well, if he is a professional documents examiner, well,

19 this may be the case. I really have nothing to say.

20 Let me reiterate that I am not familiar with this

21 document. I do not know this document. These are two

22 different things.

23 Q. And if you could be shown, please, {O2/149/1}, which is

24 a copy of an e-mail from Mr Stroilov, attaching a table

25 setting out comments that you and your husband were then

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1 making in relation to a list of documents that were

2 potentially in dispute in these proceedings. Can you

3 see that, Mrs Arkhangelskaya?

4 A. Yes, I can see something in English.

5 Q. And it looks as if you — well, do you remember ever

6 going through a list of documents to consider whether

7 you may or may not have signed them?

8 A. Yes, I do recall some documents. I do not recall what

9 those documents were. All the signatures there were

10 different. It was not just a question of whether it was

11 my signature or not my signature; they were so different

12 they had clearly been generated by different people.

13 So just to answer your question, something was shown

14 to me, yes. I simply don’t recall when that was. I do

15 not remember the year.

16 Q. And when I come to the table, you will see that the

17 table has been completed either with the letter «E» or

18 the letter «N» or the «?». The letter «E» was meant to

19 signify that a document signed by the relevant defendant

20 is admitted to exist, but that was without prejudice to

21 the issue of veracity of any given copy, and the

22 veracity of any signatures, dates, text or markings

23 appearing on such copy. An «N» meant that no such

24 document existed, and a «?» was said to be self-evident.

25 If you could go, please, to {O2/149/5}, you can see

1 there, but if you don’t really remember or understand

2 what these entries are, then I will move on. I was just

3 giving you a chance, really, to comment on that.

4 A. I am not familiar with this spreadsheet, I am afraid.

5 I’m sure my husband was dealing with this, and to be

6 honest, it’s all being transacted in English and

7 I really know very little indeed about the details of

8 this. So we are looking at the year 2013, and I am

9 afraid there is nothing at all that I can share with you

10 with respect to this document, sorry.

11 MR JUSTICE HILDYARD: Do you recall at all being asked your

12 views on the various — well, in respect of this

13 document, do you remember this document ever being

14 produced to you?

15 A. My Lord, are you referring to the spreadsheet?

16 MR JUSTICE HILDYARD: Yes.

17 A. Well, to be honest, I may be wrong, and I may be totally

18 wrong. I do know that Vitaly does ask some questions of

19 me regularly, on a regular basis. Obviously we discuss

20 that in Russian, the document is in English. I may not

21 have seen this spreadsheet. Having said that, he may

22 have asked me something with respect to this

23 spreadsheet, but this particular document, in the form

24 in which it is now shown to me, I really do not

25 recollect this.

41

1 that under document number 25, there is a reference to

2 a loan agreement dated 30 June 2006, and that appears to

3 be a reference to the first Onega loan because of

4 the date and the number; do you agree,

5 Mrs Arkhangelskaya?

6 A. I am not sure I understand what you are referring to.

7 What is it exactly that you are asking me to say that

8 I agree or disagree with?

9 Q. If you look at entry number 28, you can see that that

10 document is described as, «Declaration of consent by

11 YA Arkhangelsky to VD Arkhangelsky’s guarantee of

12 obligations borrower dated», and there is no date

13 completed. Then the signature appearing on the document

14 is said to be yours, and then there is a question mark.

15 So we had understood —

16 A. No, in 25, we have the letter E. Once again, I am not

17 sure I understand what this document actually signifies.

18 I will make an effort and try to understand, but as

19 things stand now, I don’t.

20 Q. Well, 25 is the loan agreement between

21 Bank of St Petersburg and Onega, that’s the loan. Then

22 26 is a guarantee. 27 is another guarantee, and then

23 28 seems to be a reference to a spousal consent in

24 relation to those guarantees. But don’t worry.

25 I wanted to pick up the fact there was a question mark

43

1 I do see my signature at the bottom. Well, as you

2 know, within the framework of these English court

3 proceedings, my husband does everything for us, on our

4 behalf. I do have to take part in this, even though

5 I do not like taking part in this, but because we are

6 the defendants here, I have to take part in this.

7 I understand that I do have to answer your questions,

8 but I am afraid it is very difficult for me to answer

9 those questions. Not because I don’t want to answer

10 your questions, my Lord, because I do want to be of

11 maximum possible assistance to the court, but it is just

12 very difficult for me to answer.

13 Q. Could you be shown {O2/149/6}, please. This appears to

14 be a signature by you, Mrs Arkhangelskaya?

15 A. Yes.

16 Q. In which you are signifying that you have signed, or,

17 rather, this table is a table that is being produced not

18 just by your husband, but also by you; do you remember

19 signing this table?

20 A. That’s a good question. Once again, throughout these

21 hearings I have signed a lot of documents and I do

22 apologise, I may not recall all the documents that

23 I have had to sign. They are all in English.

24 Obviously, my husband does his best to explain all this

25 to me in Russian, but he simply, physically, does not

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1 have sufficient time to do that.

2 So, let’s then translate everything into Russian,

3 word for word. It is my signature, yes.

4 Again, my apologies.

5 Q. I’m terribly sorry, Mrs Arkhangelskaya, this is a table

6 that has been produced by the defendants, it’s been

7 signed by you and your husband, and it is perfectly

8 proper for me to ask questions about it, even though it

9 is in English, because it was served in that language

10 and it was perfectly proper to ask you those questions,

11 and if you hadn’t understood the table, can I ask why

12 you were signing that page, if you didn’t understand

13 what was above it?

14 A. Well, once again, within the framework of these

15 proceedings, everything I sign is always something that

16 my husband explains to me, why I have to explain that in

17 English. Sometimes I simply have to trust him.

18 Sometimes I am required to sign a document at 3.00 in

19 the morning, and I really put my trust and confidence in

20 him, because, I mean, I cannot expect him at 3.00 in

21 the morning to explain everything that’s going on.

22 It looks like I did sign this document but, to be

23 honest, I do not recall this spreadsheet. Once again,

24 I apologise for not remembering all the documents in all

25 the bundles within these proceedings.

1 Mrs Arkhangelskaya, could I ask you, please, to look

2 at another document. If we have on screen {O1/7/1},

3 please.

4 MR JUSTICE HILDYARD: Mr Lord, you take this in the order

5 that you wish. I think I was unfair to you in

6 disturbing the previous sequence, so you —

7 MR LORD: That’s all right, my Lord. I think I can take it

8 reasonably — I think the witness has answered what —

9 she has answered what she has answered. I don’t know if

10 there would be any other purpose served in going through

11 an awful lot of the whys and wherefores, but I will, if

12 your Lordship …

13 MR JUSTICE HILDYARD: You take your course on this.

14 MR LORD: Thank you, my Lord. I want to make sure the

15 witness — I’m trying to make sure that, as far as

16 I can, I can orientate the witness fairly before I ask

17 the question.

18 MR JUSTICE HILDYARD: Can I just ask this — I’m sorry to

19 interrupt you — but on the last document that we saw,

20 which you agreed that you did sign, as did your husband,

21 do you recall a process where your husband showed you

22 various documents and explained to you their effect in

23 Russian and asked you whether you think you signed them?

24 Do you remember that process? Because I know that you

25 have had a lot to do?

45 47

1 Q. That’s all right. I think, to be absolutely accurate,

2 I think the table was prepared by the claimants, but it

3 was then, I think, sent to the defendants, sent to you

4 and Dr Arkhangelsky to put in the comments, and that’s

5 why we see the «E», «N» and «?», and then it was served,

6 I think — I think — by Mr Stroilov, on your behalf,

7 with those signatures.

8 So you know, I think the actual table was prepared

9 by the claimants, and then the list of «?», «N» or «E»

10 in manuscript was filled in, I think by the defendants,

11 and signed, as we see on that page, and sent back by

12 Mr Stroilov, so you know the full background.

13 A. Okay. Now I understand. Now I understand your

14 question. Now I understand what you expect me to say or

15 do.

16 Okay, I can confirm that I have not seen this

17 spreadsheet. This is my signature. This document was

18 shown to me. Now, whether this — once again, I just

19 want to confirm that I did not generate this document,

20 and you have just confirmed this. Some documents were

21 shown to me by Vitaly. Now, whether this is my

22 signature or not, I really hesitate to confirm. But now

23 at least I understand the background; thank you for

24 that.

25 Q. That’s all right.

1 A. Of course, my Lord. Constantly there are some

2 documents, we analysed them with him, and for that time

3 period of 2012/2013, we had several boxes of documents

4 in English at home. He was doing something on his own.

5 He was explaining some things to me. I remember I wrote

6 a few affidavits in Russian and he was translating them

7 into English. Yes, there was some work to be done.

8 MR JUSTICE HILDYARD: But can I take it you wouldn’t have

9 put your signature on that document unless you felt that

10 you had understood what it was to signify, even if you

11 did not have in front of you the particular spreadsheet?

12 A. Of course, my Lord. You understand correctly.

13 MR JUSTICE HILDYARD: Yes.

14 MR LORD: Can I show you, please, {O1/7/1}, which is another

15 of the spousal consents, and this one,

16 Mrs Arkhangelskaya, is to the first Vyborg loan; can you

17 see what’s on screen at {O1/7/1}?

18 A. Yes, I’ve read it.

19 Q. And can I ask whether that is a document that you think

20 you signed?

21 A. I am not familiar with the document in the same way as

22 I was not familiar with the previous one. As far as

23 I can see, it was drawn by BSP, and here it says that

24 I have to give a guarantee of 310 million of my own

25 money that I didn’t have. I would not be able to

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1 comment on the signature. I am not familiar with the

2 document.

3 Q. If you could have {D38/654/1} up, please, we will see

4 the English translation. Mrs Arkhangelskaya, again, it

5 is a document that signifies your consent to your

6 husband giving a guarantee himself in relation to a loan

7 to Vyborg Shipping Company given by

8 Bank of St Petersburg. So, it’s really you saying that

9 you consent to a guarantee being given by your husband.

10 So you are not giving the guarantee: you are agreeing

11 that your husband — you are consenting to your husband

12 giving the guarantee in this document. Do you

13 understand what the document signifies?

14 A. I understand you, sir, but I am not — I haven’t seen

15 this document before. I am not familiar with it.

16 I don’t know about it.

17 Q. But you accept, therefore, that it’s possible that you

18 did sign this document? Or, put another way, you can’t

19 say —

20 A. For 310 million? You must be kidding, sir. That is

21 a guarantee using my money. I did not have such funds

22 at that point in time. How could you guarantee

23 something with the funds you haven’t got?

24 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, I hope Mr Lord

25 doesn’t mind me saying this. We are given to understand

1 inelegantly, is that in many of your questions I think

2 you have felt that you could not have signed the

3 document because you would never have agreed to

4 liability in such an enormous amount, and I wanted just

5 to explain to you that, even if you did sign those

6 agreements, you would not be exposing yourself

7 personally to liability, though of course it would

8 constitute your agreement to your husband exposing

9 himself to that liability.

10 I’m sorry, Mr Lord.

11 MR LORD: That’s right, my Lord.

12 MR JUSTICE HILDYARD: Many of the questions may have been

13 answered on a premise which was misunderstood.

14 Do you understand now? Not really?

15 A. Approximately, but not very well. I’m sorry. The

16 amount is too big. But I don’t know about the

17 documents, so I wouldn’t be able to comment.

18 MR LORD: I’m going to ask about the documents, I think, in

19 those circumstances. I have tried, fairly, to put the

20 context, and I am now just going to put the documents,

21 if I may?

22 MR JUSTICE HILDYARD: Yes.

23 MR LORD: I think I asked you, Mrs Arkhangelskaya, but I had

24 better, again, ask you; or, really, I am putting to you

25 that the document at {O1/7/1}, you either signed it, or

49 51
1 that under Russian law — 1 somebody — if you didn’t sign it, the person who signed
2 MR LORD: My Lord, can I stop you there, because I’m not 2 it did so with your authorisation.
3 sure we do accept that it is a Russian legal 3 A. The document that I can see on the screen here, is that
4 requirement, so I don’t want to — 4 the — I don’t know who signed that document. I am not
5 MR JUSTICE HILDYARD: Right. Under banking practice. 5 familiar with that document. That’s the most important
6 MR LORD: Certainly, my Lord. 6 point.
7 MR JUSTICE HILDYARD: Under banking practice it is the 7 Q. I wonder, could you please be shown {O1/8/1}. And can
8 practice of Bank of St Petersburg, at any rate, and 8 we have {D40/691/1} on screen.
9 possibly other banks in Russia, at least one other bank 9 Mrs Arkhangelskaya, have you not ever looked at this
10 in Russia, to ask the spouse of someone who is giving 10 document, or have you ever seen {O1/8/1} before? Do you
11 a personal guarantee to confirm his or her consent to 11 recollect ever seeing this document?
12 their spouse giving that guarantee. The effect of that 12 A. 342 million. I’m not familiar with this document.
13 document is not to expose the spouse who is giving their 13 Q. So is it your evidence that you don’t think you have
14 consent to any liability; simply to confirm that they 14 ever seen this document before at any stage?
15 are agreed that their spouse should be under that 15 A. Sir, how do you mean? At what stage? Maybe I’ve seen
16 liability. 16 that document when I was drawing up some affidavits, but
17 Now, if you see what I mean, by someone signing 17 the fact is that it wasn’t drawn up by me. That is for
18 this, it would not — by a spouse signing this, it would 18 sure.
19 not commit that spouse to any liability, but it might 19 Q. But, Mrs Arkhangelskaya, I was asking you that; I was
20 commit that spouse not to raise questions as to their 20 asking whether at some stage, at least, you have had
21 husband’s or wife’s liability. That’s all it is. It’s 21 cause to look at that document and think about it? Or
22 not a personal exposure. 22 not?
23 Is that fair, Mr Lord? 23 A. I saw some of my guarantees along those lines, allegedly
24 MR LORD: Yes. 24 my guarantees; whether that was my signature or not,
25 MR JUSTICE HILDYARD: The reason I tried to explain that, 25 I forgot who put them to me, whether my husband or
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1 Mr Stroilov, but I say everywhere that I’ve never seen

2 these documents before, and I confirm today that I have

3 not seen this document.

4 By saying that, I say I haven’t drawn that up. By

5 seeing it — maybe I misunderstood you, sir. By seeing

6 it, I mean I haven’t drawn that up, I haven’t put that

7 together.

8 At the very least, these documents — I’m sorry,

9 my Lord. Yes, I think — I think I am about to be

10 misled again.

11 There was a cross-examination three years ago that

12 was done from London via videolink in Nice. I was shown

13 a large volume of documents by your colleagues, and the

14 documents were along the same lines, and the question

15 was whether I was the person drawing up that document,

16 whether the signature is mine, or otherwise; is that

17 what you mean, sir? Is the question —

18 Q. No. No. Mrs Arkhangelskaya, you have given evidence.

19 Your case, your pleaded case, positively asserts that

20 this document is a forgery. Your witness statement

21 supports that position and, therefore, I had taken

22 it that at some stage, at least, you had carefully

23 considered the documents that fit into that category; in

24 other words documents which you have said in this

25 litigation, you and your husband have said, that

1 the English. Mrs Arkhangelskaya, I am only really

2 asking you questions about evidence that I understand

3 that you have confirmed to be true today. So I am not

4 trying to — I really am not trying to be difficult

5 here. I am just assuming that before you confirm

6 paragraph 12 to be true today, you would have checked

7 pretty carefully the documents that you are describing

8 in that paragraph; was I wrong to be questioning you on

9 that basis? Was that a false basis of mine?

10 A. Sir, I don’t think I was doing something wrong. Rather,

11 my understanding was wrong. The question about whether

12 that document has anything to do with you, whether you

13 have drawn that up, or the question of whether you have

14 seen it ever, these are two different questions.

15 Q. Mrs Arkhangelskaya, can his Lordship take it that for

16 the purpose of your giving the evidence in paragraph 12

17 of your witness statement, you have considered the

18 documents that you are there describing so as to satisfy

19 yourself whether you think you did or didn’t sign them?

20 A. I’m sorry, sir, I didn’t understand the question again.

21 Could you please repeat it, maybe perhaps reword it?

22 I’m sorry, sir. Have you considered; could you please

23 elaborate on what you mean by the word «considered»?

24 Q. Have you looked at these documents that you are

25 referring to in paragraph 12? Have you looked at them?

53

1 Bank of St Petersburg forged or fabricated. And I am

2 simply taking you through a list of those documents.

3 So it’s nothing unfair about the process. It’s not

4 trying to trick you. If your evidence is you have not

5 ever had cause to look at this document and think about

6 it and think whether you did really sign it, if that’s

7 the truth, then please tell his Lordship.

8 A. To put it this way, I don’t know the document because —

9 in the sense of me not drawing that up, but I could have

10 seen it at the London cross-examination three years ago,

11 because your colleague put a great, vast number of

12 documents to me. I could have seen the documents in

13 the proceedings, if I was asked whether I was putting

14 that together; that could have been asked by a lawyer,

15 my husband, by the court.

16 So I did not produce the document. I don’t know it

17 in terms of me drawing that up, but indeed I could have

18 seen the document several times during

19 cross-examination, during the hearing, during giving

20 evidence. So that’s the issue.

21 So is your question, sir, about whether I have seen

22 that piece of paper, or whether it has anything to do

23 with me, with my hands, with my thinking process?

24 Q. Would you be shown your witness statement, please, at

25 {C1/2/10}, paragraph 12, and it is {C1/2/2} in

55

1 Have you sat down and looked at them?

2 A. Have I seen the documents? Because it says here that

3 I have not signed the documents. Unfortunately I cannot

4 recall the numbers off the top of my head so easily.

5 The personal guarantees, yes, this is about not signing

6 personal guarantees. This is correct. But whether

7 I have seen them, well, these are not my guarantees, but

8 I have seen the pieces of paper. So if you are asking

9 me whether I confirm that these are my personal

10 guarantees, the answer is no, this is not correct.

11 Q. Mrs Arkhangelskaya, in paragraph 12 you identify certain

12 documents by reference to an A number: A7 to A12 and

13 A29. And they come off a list of documents which have

14 been given those numbers for the purposes of this

15 forgery dispute. That’s why I had assumed that in this

16 witness statement, you would have looked at A7, A8, A9,

17 A10, A11, A12 and A29; is that right or not?

18 A. All I have put in my witness statement is correct.

19 Unfortunately, I do not recall the numbers at this

20 stage. Perhaps I have seen the documents stated here,

21 these numbers, I mean, but if it says so in the witness

22 statement, that must be correct.

23 Q. Mrs Arkhangelskaya, in the light of the evidence you

24 have given this morning, have you actually — have you

25 yourself independently thought about this question of

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1 the signing of the spousal consents? Or have you just

2 done what your husband has asked you to do in that

3 respect?

4 A. I do not understand the question, sir. Could you please

5 reword it slightly differently.

6 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, you are here to

7 help me decide this case. I understand that this is

8 a difficult process. As far as I can tell, Mr Lord is

9 being perfectly fair in his questions. Indeed, in one

10 instance I interrupted and his process was fairer than

11 what I thought. I want you to focus very carefully and

12 focus all your mind on the questions he asks, and answer

13 to the best of your ability.

14 I have become concerned that you are seeking to see

15 difficulties in the questions rather than seeking to

16 understand them, and that is troubling me. I want you

17 to try and help, all right?

18 A. I am doing my best, my Lord. I’m sorry, I did not

19 understand the last question about my husband.

20 MR JUSTICE HILDYARD: Well, focus — please state it again,

21 Mr Lord, and let us see whether we can get an answer.

22 MR LORD: Mrs Arkhangelskaya, have you yourself

23 independently thought about whether you did or didn’t

24 sign the documents that you identify in paragraph 12 of

25 your witness statement?

1 been the case that somebody else — if somebody else

2 signed it, they would have done so with your

3 authorisation?

4 A. Whether I’ve authorised anyone to sign a document in my

5 place for RUB 300 million, it’s absolutely out of the

6 question.

7 Q. And might you have authorised your husband to sign this

8 document on your behalf? Might you have let him sign

9 documents like this on your behalf?

10 A. No. Why? Let the husband sign his own documents.

11 Certainly what’s the point of signing documents on my

12 behalf?

13 Q. You were aware, weren’t you, you were aware that

14 Bank of St Petersburg was lending a lot of money to OMG

15 companies?

16 A. I knew that my husband is operating in a classical

17 business way: he bought an asset, the asset has to be

18 developed, therefore we need some loans. This is

19 something I knew, yes.

20 Q. Could I see on screen, please {O1/9/1}.

21 MR JUSTICE HILDYARD: My Lord, can I just — we have been

22 going for some time and I had rather hoped that we

23 would — I mean no criticism of you in this — I just

24 feel that I must have a break now, even if — I don’t

25 mean thereby to cut you off from this. I just mean that

57

1 A. Of course. I have not signed the documents for

2 RUB 300 million — not euros, sorry. I simply could not

3 have signed such a thing.

4 Q. If you could have on the screen again {O1/8/1}, please,

5 which I think I just took you to. This is the document

6 that has been numbered A8 in the list of documents, and

7 therefore, Mrs Arkhangelskaya, it is one of

8 the documents, as I understand it, that you are

9 referring to in paragraph 12 of your witness statement.

10 Do you agree that that is one of the documents you

11 are referring to in your witness statement? You can see

12 the reference, {O1/8/1}, and it has A8 at the top?

13 A. Yes.

14 Q. And can I —

15 A. As it says here, I have not signed such a document.

16 I have seen it, but I have seen it in the proceedings,

17 in the process of giving evidence. But I haven’t signed

18 it.

19 Q. So you don’t think you signed this document; is that

20 right?

21 A. That’s right. That document is not familiar to me as

22 something drawn up by me, but most likely I have seen it

23 at the last cross-examination. Your colleague was

24 putting lots of similar documents to me.

25 Q. And were you — if you didn’t sign it, wouldn’t it have

59

1 I think that the transcript writers probably need

2 a break.

3 MR LORD: We are making quite good process anyway, my Lord.

4 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, we are going to

5 have a little break now, and I think that will be in

6 everyone’s interests. But Mr Lord will come back to

7 these matters in about ten minutes’ time; all right?

8 A. Thank you, my Lord.

9 (11.37 am)

10 (A short break)

11 (11.50 am)

12 MR LORD: Mrs Arkhangelskaya, I think I have put the

13 document A8 to you. I think I have. Can we have A9,

14 please, {O1/9/1}.

15 MR JUSTICE HILDYARD: Shall we have the English up as well?

16 MR LORD: Sorry, my Lord, it is my fault. {D42/737/1},

17 please.

18 Mrs Arkhangelskaya, again this is one of

19 the documents that you describe in paragraph 12 of your

20 witness statement. Would it be fair that you can’t

21 really say today whether you did or didn’t sign it?

22 A. Well, this document does look like the previous one. It

23 says Bank of St Petersburg, it quotes a huge amount of

24 money in roubles. 30 April 2008. It does look like the

25 previous document, and the gist is the same, in

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1 the sense that it’s the same bank and a large amount of

2 money. But I am not aware of this, in the sense that

3 I have seen documents like this one, but I do not recall

4 generating this document.

5 Q. But you can’t say now, can you, whether or not you did

6 or didn’t sign this document back in 2008, can you?

7 A. Well, because this involves a large amount of money and

8 it is generated by BSP and it is my personal guarantee,

9 I think, so I do not know whether I signed this or not.

10 I must have seen this some time in the past, but I do

11 not recall signing this.

12 Q. And I suggest, Mrs Arkhangelskaya, that either you

13 signed it, or somebody signed it with your permission?

14 A. Well, this is your opinion and I cannot confirm this.

15 Either myself or someone else — tertium non datur, as

16 they used to say; is there any third option available?

17 Q. I wonder, could you be shown, please {O1/10/1}, and

18 {D55/957/1}.

19 A. It’s quite similar to the previous one, I think.

20 Q. Again, the same point, Mrs Arkhangelskaya; can you say

21 today whether you did or didn’t sign the document we see

22 at {O1/10/1}?

23 A. This document looks like the previous document, but I do

24 not know this document, in the sense that I do not know

25 whether I read this document, familiarised myself with

1 is that this is my personal guarantee, or it’s my

2 husband’s guarantee. For me, it quotes my name because

3 it doesn’t say, «I, Vitaly Arkhangelsky»; it says

4 «I, Julia Arkhangelskaya». So it’s my guarantee.

5 From the economic point of view, it involves a huge

6 amount of money, RUB 145 million, so this amounts to my

7 personal guarantee, as it were, does it not?

8 Q. No, it doesn’t, Mrs Arkhangelskaya. Should I take it

9 from your last few answers that your principal concern

10 now is that you don’t become liable for any financial

11 liabilities that may attach to your husband,

12 Dr Arkhangelsky; would that be fair? Is that your main

13 concern, or one of your main concerns today?

14 A. No, this is no longer my concern because all my assets

15 have already been taken away by the Bank. So I am just

16 looking at a document and you are asking me questions

17 about the document I am looking at.

18 Q. And is it your evidence that you don’t understand that

19 the documents I have been showing you are spousal

20 consents, as opposed to personal guarantees; is that

21 your evidence? That you don’t understand the

22 difference?

23 A. Well, in principle for me, so far as I am concerned, it

24 is the same thing.

25 Q. And when you were doing your accountancy and audit

61 63

1 this document and/or signed it.

2 Q. And I suggest to you, Mrs Arkhangelskaya, that you did

3 either sign it or that if anyone else signed it, they

4 did so with your permission?

5 A. No. This is not true.

6 Q. Could you be shown A11, please. It is {O1/11/1} and

7 {D49/855/1}, I think.

8 Mrs Arkhangelskaya, can you say today whether you

9 did or didn’t sign the document at {O1/11/1}, the A11

10 document?

11 A. All I can say is that this is a personal guarantee for

12 145 million. It also comes from Bank of St Petersburg.

13 I did not sign any personal guarantees. So the same

14 answer.

15 Q. And I suggest, Mrs Arkhangelskaya, that you did either

16 sign this, or if someone else signed it, they did so

17 with your permission?

18 A. No, this is not true.

19 Q. Mrs Arkhangelskaya, you keep saying this is a guarantee

20 by you. His Lordship has explained, these are not

21 guarantees you are giving; these are consents that you

22 are giving, as a spouse, to guarantees being given by

23 Dr Arkhangelsky. You keep mischaracterising these

24 documents, so I don’t want it to be said that —

25 A. My apologies. I may be wrong. For me, the gist of this

1 studies and training, would you have understood the

2 difference between a guarantee and a consent to

3 a guarantee, do you think?

4 A. Well, I may not have spent sufficient time to understand

5 the difference between those two terms. Mind you, this

6 is not accounting, this is banking, so it’s not really

7 my field of study.

8 Q. I wonder, could you be shown A11, please, which is

9 {O1/11/1}. Actually, I have done that.

10 I need to take you, I think, in your witness

11 statement again, to {C1/2/10}, paragraphs 13 to 15.

12 {C1/2/2}.

13 A. I have it in front of me, yes. Thank you.

14 Q. Thank you. You can see what you have said in

15 paragraphs 13 to 15. You have given some evidence that

16 you don’t think that the document A10 or document A11

17 can have been signed by you because you weren’t in

18 Russia on the dates in question, and therefore you can’t

19 have signed them in the presence of the Bank personnel,

20 as those documents suggest was the case; do you see

21 that?

22 A. Yes, I have read this.

23 Q. Isn’t it right that Bank of St Petersburg on occasion

24 allowed OMG companies and your husband to sign documents

25 away from the Bank, and then return them to the Bank,

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1 signed?

2 A. I think this question is better asked to my husband.

3 What I say in 14 and 15 is, basically, a subparagraph to

4 paragraph 12: I did not sign those documents. I went

5 through my notes, and, mind you, on top of that, I was

6 not in Russia, so that’s additional proof that I could

7 not have possibly signed those documents because, number

8 one, I do not recall those documents, and I also was not

9 in Russia.

10 So 14 and 15 are, as it were, subparagraphs to

11 paragraph 12, if you see what I mean.

12 Q. But there could be two explanations, couldn’t there, or

13 there could be two other relevant situations: one would

14 be that you sign these documents when you got back to

15 Russia, even though the documents bear an earlier date.

16 That’s an explanation, isn’t it, sort of signing later

17 for an earlier-dated document; do you see what I mean?

18 I am not criticising you for that,

19 Mrs Arkhangelskaya, but it would be an explanation,

20 wouldn’t it: you sign when you get back, even though the

21 document is dated with an earlier date, because that’s

22 when the guarantee and the contracts were all going to

23 be dated?

24 A. This is not the case. Now, what is important here is

25 that I am not familiar with these documents. I just

1 it your evidence that, to the best of your knowledge,

2 your husband has never given a personal guarantee to

3 a bank, any bank?

4 A. Well, I think you should ask him. I don’t think he did.

5 Q. Well, Mrs Arkhangelskaya, your involvement would be —

6 A. Mind you, we are looking at huge amounts of money. We

7 have never had sufficient assets to cover that.

8 Q. That’s a slightly different point, Mrs Arkhangelskaya.

9 You see, I am asking you about spousal consents to

10 personal guarantees given by your husband, aren’t I?

11 A. I understand that. We are looking at the documents that

12 you are turning up now. They are related to me, not to

13 my husband. That I understand. That much I understand.

14 Q. And I am asking you whether, to your knowledge, your

15 husband ever gave a personal guarantee to a bank, any

16 bank; not just Bank of St Petersburg, but did he ever,

17 to your knowledge, give a personal guarantee to a bank

18 to cover a loan by that bank?

19 A. I have no knowledge of that, let me put it that way.

20 I have no information to that effect.

21 Q. Does that mean that you think that he, to the best of

22 your knowledge today, never gave a personal guarantee,

23 or you can’t remember, or you just don’t really know the

24 answer?

25 A. I do not know the answer because I do know that some

65 67

1 don’t know these documents. I’m not even looking at the

2 date, be it 2007, 2008, 2005. Sitting here today, this

3 is many years ago, so I’m not familiar with the

4 documents.

5 Now, what I wrote about Bulgaria here is no longer

6 that important; it’s just an icing on the cake, as it

7 were. It’s some additional proof that there is no way

8 I could have signed this. I did not really have to

9 refer to this. It’s just additional proof that there is

10 no way I could have signed this.

11 Q. And another explanation would be that somebody else

12 signed it with your permission, for example your

13 husband; that would be an explanation, wouldn’t it?

14 A. No.

15 Q. Did you ever allow him to sign documents on your behalf,

16 or are you saying that you always insisted that you

17 personally signed any document yourself?

18 A. I always tried to sign whatever documents I need to sign

19 myself.

20 Q. I’m sure that’s right, but was there never an occasion

21 when he signed something on your behalf because you

22 weren’t around, or you were too busy with the family,

23 for example?

24 A. No, of course not, because that would be a forgery.

25 Q. And is it your evidence that you have never given — is

1 loans had been extended in large amounts, because he

2 needed a lot of money to build his business and his

3 projects, but I’m not aware of any specific amounts,

4 I do not know how that was done in practice, so I cannot

5 give you any answer with respect to any specific names

6 of any specific banks. I do recall there were two

7 banks, but I do not recall the details.

8 He never really kept me apprised of the details, or

9 the minutiae or the mechanics of what was being done.

10 Q. And would it be fair to say that you usually did,

11 really, what he asked you; that you trusted him and you

12 just went along with what he asked you to do generally?

13 A. What is your question referring to? Could you please be

14 more specific? There’s the husband, there is the wife,

15 there’s the division of responsibilities. His

16 responsibilities involved his business; my

17 responsibilities were different.

18 Well, when you say «trust», what exactly do you

19 mean? Do you recall the saying «trust by verify»? You

20 cannot trust anyone absolutely or completely; you have

21 to verify, you have to be careful.

22 Q. If your husband wanted to enter into some particular

23 business venture or enter into some particular business

24 agreement, would you generally go along with that?

25 Would you generally agree to that course, or would you

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1 sometimes stop and say: no, we can’t do that, Vitaly; do

2 you remember?

3 A. Well, of course, sometimes I may be against something.

4 Now, if your question is whether or not I had a right of

5 say or I had a vote, well maybe I did, but a very small

6 one.

7 Q. Could you be shown A29, please, which is {O1/29/1}, and

8 that’s at {D98/1265/1}, if we could have the English on

9 screen, please. This looks to be a consent by you,

10 Mrs Arkhangelskaya, to a loan being taken out by your

11 husband from Bank of St Petersburg for RUB 130 million

12 on 28 November 2008; can you see that?

13 A. This document looks like the previous one:

14 «I, Arkhangelskaya …»

15 A large amount of money, RUB 130 million,

16 Bank of St Petersburg, so it does look like the previous

17 ones.

18 Q. And again, does that look like your signature?

19 A. As in the previous documents, my answer will be the

20 same: I am not familiar with the document itself, and

21 I do not want to speculate whether this signature looks

22 like my signature or it does not look like my signature

23 particularly, because you have expert evidence,

24 a document examiner, who has written a report.

25 This looks like all the previous documents, so my

1 Q. I’m going to ask you now, Mrs Arkhangelskaya, about some

2 other matters, if I may.

3 I wonder if we could have {I15/15/103} on the

4 screen, please, which is a letter from Withers dated

5 23 July 2015 to the solicitors for

6 Bank of St Petersburg, and it is in relation to

7 Vyborg Port and Port Equipment.

8 If you could go, please, to {I15/15/105}, Withers

9 set out some information in this letter which purports

10 to have come from either you or your husband.

11 A. Yes, yes I’m listening. It’s all in English, so I do

12 not understand.

13 Q. Have you considered this letter at any stage by way of

14 preparation for today?

15 A. Well, it’s my husband who reads documents in English, so

16 sometimes he explains something that needs to be

17 explained. There are certain things that he does on his

18 own, certain things we do together, but his main role is

19 to take part in these proceedings because he is

20 an English speaker, and also because he has been doing

21 this 24/7 for the last many years. I mainly deal with

22 and attend to our children.

23 If you can ask me a specific question, I am more

24 than happy to answer. I do not know what this letter is

25 about. I mean, Withers may have asked me certain

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1 answer will be like the answer that I had previously

2 given.

3 Q. Mrs Arkhangelskaya, that’s not really an answer. Doing

4 the best you can today, looking at that page {O1/29/1},

5 does that look to you to be your signature? Or the

6 signature that you were using back in November 2008, or

7 round about that time?

8 A. It’s very difficult for me to answer that question.

9 Maybe yes, maybe no.

10 Rather no than yes, but one thing I am certain of is

11 that I am not familiar with the document. How can

12 I possibly sign a document that I am not familiar with?

13 You see, feel free to show me 100 signatures, and then

14 ask me whether they look like mine. I’m very keen to

15 assist the court, but I just cannot answer the question

16 as to what this signature looks like, or whose signature

17 it looks like.

18 Q. Again, Mrs Arkhangelskaya, I suggest that either you

19 signed this document at {O1/29/1}, or, if someone else

20 signed it, they did so with your permission.

21 A. No, I did not sign this and there is no way I could have

22 allowed or permitted anyone to sign a document involving

23 RUB 130 million.

24 I mean, mind you, what kind of permission are you

25 referring to, sir?

1 questions. If you can just be more specific, what is it

2 exactly that you are asking me about?

3 Q. Are you still the financial controller for Vyborg Port

4 LLC?

5 A. No.

6 Q. We have seen a document where you said that you were at

7 one stage; when did you cease to have that role for

8 Vyborg Port?

9 A. As I mentioned about 90 minutes ago, these

10 responsibilities mainly involved my being on the

11 payroll, and getting my pay cheque. So I think

12 I answered your question. Back in 2013 everything

13 stopped, but they still continue paying me the salary,

14 which is a mystery to me. If you want, I can answer

15 that question as to why I am still on their payroll and

16 why I get my salary paid. I have some — I can

17 speculate as to the reasons behind this.

18 Q. So your evidence is that you think you can explain why

19 you still had payments from this company, although you

20 have ceased to have an official role in the company; is

21 that right?

22 A. Well, I have an employment contract which is still

23 valid. It has not been terminated. My labour record

24 book is still in the accounting department of the port.

25 So it means that, from a legal point of view, I am still

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1 on their records, on their payroll. I am regarded to be

2 their employee, but I do not play any actual role.

3 Q. And who do you think has been sending you those

4 payments? Who has been authorising those payments to

5 come, do you think?

6 A. It’s the Vyborg Port, and it must be the director of

7 Vyborg Port. We no longer have any contact with the

8 port, but the salary started being paid, I think in

9 2013. There were definitely some payments at that time.

10 They do not come on a regular basis. Also, the amounts

11 are way smaller than they used to be. Neither Vitaly

12 nor myself can exercise any influence with respect to

13 the amount of the money that is being paid.

14 He did exchange correspondence with the director of

15 the port. He asked the director to increase my salary.

16 The answer was in the negative. The answer was no.

17 That was not going to be done.

18 Q. When was that, Mrs Arkhangelskaya? When did your

19 husband ask for your salary to be increased?

20 A. After 2014, in the end of 2014, in early 2015, he

21 definitely had some correspondence in this regard

22 because we needed a document for the tax authorities in

23 France, and only the accounts department could draw up

24 such a document about what salary has been allocated to

25 me, so it should be that time period, or thereabouts.

1 €3,200 per month, and I had to pay tax on that as well.

2 As of today, that is payment for us keeping silent, for

3 my husband and myself, because the port director, she

4 always knew that our financial situation is difficult in

5 France, we are in dire straits. We have many court

6 proceedings around the world. Vitaly always reminded

7 her of that, that we needed funds, and now these funds

8 have been minimised down to 3,000. I think it’s simply

9 paying us off for keeping silent, for not carrying on

10 the proceedings, whether we are owners of the port or

11 not, but this is my personal opinion. It’s very strange

12 that we are, indeed, being paid this 3,000. I think it

13 is our payment for keeping silent, not for sticking our

14 noses into anything, not to find out, not to — but

15 I think after today’s hearing, I think that 3,000 would

16 be petered out, it would stop. They would simply close

17 my account in Russia, as it happened after the

18 cross-examination.

19 Q. And who are you referring to? Who are you saying made

20 these payments to you? You have somebody in mind: who

21 is the person you are talking about?

22 A. This is Ms Olga Lukina, the port director, as far as

23 I know. Whether she is the director currently or not.

24 Vitaly had the contact, and as far as I recall that was

25 Mrs Olga Lukina. Of course, the actual payments are

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1 Q. And who has been managing Vyborg Port over the last two

2 years, let’s say, three years?

3 A. Unfortunately I do not know. I recall the director’s

4 surname, and I don’t know who currently manages

5 Vyborg Port. Most likely it doesn’t belong to us.

6 I don’t know who owns this asset at the time. I don’t

7 have a representative in Russia and therefore cannot

8 answer this question.

9 Q. And what about the company called Port Equipment LLC?

10 It’s right, isn’t it, Mrs Arkhangelskaya, I think — in

11 this letter from Withers, they say that you confirm, you

12 and your husband confirm, that you from time to time

13 receive funds from Port Equipment as well as Vyborg Port

14 LLC; is that right?

15 A. Yes, that’s right, but Vyborg Port and Port Equipment,

16 it’s more or less the same. I don’t know how it’s

17 organised legally, how the structure is put together,

18 but that’s more or less the same.

19 Q. And, again, can you explain why you have been getting

20 those payments from Port Equipment?

21 A. Prior to 2013/2014 I understand why that was the case,

22 because after all my husband was an owner, even though

23 these payments could not be called sufficient

24 remuneration for an owner.

25 Currently that is — that amount in 2015 is about

1 done by the accounts department, not by Mrs Lukina

2 personally.

3 Q. So is it right that you are still in contact with

4 Ms Lukina?

5 A. Only via electronic means of communication. He can

6 write her a letter. She might reply or might not. So

7 that’s the type of contact. She doesn’t answer queries.

8 We sent a query in 2015 with regard to my documents —

9 a document pertaining to my salary for the tax

10 authorities. There was a request whether my salary

11 could possibly be increased. So that is a type of

12 contact.

13 She did not respond to any other queries, as far as

14 I know. Maybe Vitaly didn’t ask her. Maybe it’s best

15 to be asking him, because otherwise he might lose this

16 3,000.

17 Q. I am just referring back to the letter from Withers at

18 {I15/15/105}, and I will read out the two paragraphs

19 I am looking at:

20 «Mr and Mrs Arkhangelsky confirm that they have from

21 time to time received funds from Vyborg Port LLC and/or

22 Port Equipment LLC. In practice, however, since at

23 least 2012 Mr and Mrs Arkhangelsky have not been

24 actively involved in the running of the two companies,

25 and the lead was taken instead by the local management,

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1 including Mr Vasiliev and Ms Lukina.

2 «Mr and Mrs Arkhangelsky can only speculate as to

3 why payments to them were still made after they lost

4 control of the companies. In principle, there is

5 nothing strange or suspicious in the fact that the

6 companies continued to discharge its legal obligation to

7 pay wages to their employees, notwithstanding the

8 purported change of ownership or bankruptcy proceedings.

9 It is also understandable that our clients were

10 disinclined to question these payments in view of their

11 extremely straitened, even desperate circumstances.»

12 That’s the end of the quote.

13 Now, Mrs Arkhangelskaya, there is no reference in

14 the Withers letter, which appears to be based on

15 confirmation from you and your husband, there is no

16 reference in there to the matters you have just given

17 evidence about, namely being paid to keep silent. Can

18 you explain to his Lordship why the Withers letter gives

19 the explanation that it does? Can you reconcile the

20 inconsistency there between what you have just said now

21 and what was said on your behalf in this letter?

22 A. Sir, I’m sorry, what is the inconsistency? Everything

23 matches up. We were receiving money but we didn’t

24 understand quite why we were receiving the money, and

25 with regard to this being payment for us keeping silent,

1 can see that the rouble amount also halved compared to

2 2014.

3 Q. Mrs Arkhangelskaya, isn’t it more likely that these

4 payments from the Vyborg Port companies to you and your

5 husband were made because you and your husband still

6 have an interest in those businesses?

7 A. No, I don’t think so. Again, please know that this is

8 my personal opinion: €3,000 is a minimal amount that can

9 be paid to an owner, as they thought, for us to keep

10 silent. That’s it. No one pays 3,000 to an owner.

11 That is very little.

12 Q. I’m going to ask you now about City Centre,

13 Mrs Arkhangelskaya. Are you aware of the questions that

14 have been raised in this case about some certain entries

15 in OMG company accounts to an entity seemingly called

16 City Centre?

17 A. No, I am not aware of that, I know nothing about that,

18 sorry. I don’t have any information to that effect.

19 Q. I want to show you some accounts that seem to have been

20 signed on behalf of LPK Scan, if I may.

21 A. Is LPK Scan a company name?

22 Q. Yes, could we see {D116/1726.3/0.1} and {D116/1726.3/1}.

23 {D116/1726.3/1} is the Russian and {D116/1726.3/0.1} is

24 the English.

25 Mrs Arkhangelskaya, from your accounting — with

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1 that’s my personal opinion. This is purely my opinion.

2 How else could that be explained? That’s why, if you

3 would explain, sir, what the inconsistency is, I shall

4 endeavour to explain.

5 Q. The copies of the Société Générale accounts that we have

6 been served with recently, going back over the last two

7 years, look as if you and your husband have received

8 approximately €130,000 from Vyborg Port company, so

9 that’s Vyborg Port or Port Equipment, over that period;

10 does that sound about right? €130,000 over two years

11 from those sources, roughly?

12 A. 2014, that amount is correct. For 2015, that amount

13 dropped significantly, and now it’s about 3,300 per

14 year, starting from 2015, for the whole of 2015, that

15 it’s a completely different number. These are not

16 regular payments.

17 In 2014 there were a few months without any payments

18 and currently in the last few months the payment became

19 quite regular, 1,600 or 1,700 twice a month.

20 So now the amount dropped significantly, even in

21 roubles — because the Russian rouble dropped, it halved

22 in value — but the amount in roubles also halved. Even

23 though you might not be able to see it from the

24 statements, you can see how much has arrived in roubles

25 in the Bank, because the statement is in euros, but you

1 your accounting and auditing experience, can you confirm

2 that this looks to be a financial statement for

3 a company called Scandinavia LPK LLC?

4 A. I wouldn’t be able to confirm off the top of my head.

5 Yes, a breakdown of the balance sheet line, short term

6 investments, yes. That is a breakdown of one of

7 the balance sheet lines, what I can see in front of me.

8 Q. And if you go, please, to — if you go on — if we could

9 just scroll down the pages slowly, please, one by one,

10 we can see that some of these pages seem to have been

11 signed by RI Tarasova, don’t they? {D116/1726.3/0.2},

12 {D116/1726.3/2}

13 Can you see that?

14 A. Yes, I can see that.

15 Q. Is your mother RI Tarasova; are those her initials and

16 her name?

17 A. Yes, that is my mother. RI Tarasova is my mother.

18 Q. And is it right that she was, certainly at one stage,

19 general director of this company?

20 A. Yes. As I already mentioned, I recall that she was

21 a director of one, or even two companies. I think of

22 one company. She was a nominal director.

23 Q. And if we go on through the page, we can see — does

24 that look like her signature? {D116/1726.3/2}

25 A. It’s similar, I think.

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1 Q. And if we go through the — if we turn the pages, you

2 can just go through and see a number of other entries,

3 if we may. Just keep turning the pages, please, one

4 after the other. {D116/1726.3/4} {D116/1726.3/0.4},

5 {D116/1726.3/5} {D116/1726.3/0.5}, {D116/1726.3/6}

6 {D116/1726.3/0.6}, {D116/1726.3/7} {D116/1726.3/0.7}.

7 And you can see, on {D116/1726.3/7} in Russian, and

8 {D116/1726.3/0.7} in English, there look to be two

9 different entries in relation to Raisa Tarasova. It

10 looks as if — well, she is described as being both

11 «Chief Accountant» as well as director general — sorry,

12 «Top Manager». I think that must mean director general.

13 Mrs Arkhangelskaya, do you think that your mother

14 was the chief accountant as well as the director general

15 of this company, as at April 2009?

16 A. Unfortunately that’s a definite error. Most definitely.

17 You can see where it says the «Top Manager»,

18 {D116/1726.3/7} there is no signature there. I think

19 there should have been a place for a signature.

20 Indeed, she was a manager, but purely a nominal one.

21 She did not take any part in operations of any

22 companies.

23 Q. And presumably, if she was a nominal director, would it

24 be right to say that the effective control of that

25 company was carried out by your husband,

1 A. Is there a specific question whether she checked

2 something at all? I don’t think so.

3 Q. There is a reference. If we go, please, to

4 {D116/1726.3/0.3}, there is a breakdown of the balance

5 sheet as at 31 March 2009:

6 «‘Accounts Receivable’ for the First Quarter 2009.»

7 And you can see that about a quarter of the way up

8 from the foot of the page, there is a reference to

9 City Centre LLC; can you see that, Mrs Arkhangelskaya?

10 RUB 950 million, or thereabouts; can you see that? Can

11 you see that entry?

12 A. No.

13 Q. Do you have the Russian? Sorry, you should have

14 {D116/1726.3/3} as well.

15 Can you see, it is nine entries up from the bottom.

16 So above «Total», if you go up nine lines, it’s after

17 «Scantrade» and before «Breeze»; can you see that? Do

18 you have that?

19 A. Yes, I have.

20 Q. And can you see what it says? Does it say

21 «City Centre LLC»? Can you perhaps …

22 A. Maybe. Maybe it says something there.

23 Q. You are smiling. Are you aware of City Centre? Can you

24 cast any —

25 A. Quite to the contrary. I just don’t know why you are

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1 Dr Arkhangelsky?

2 A. Either by my husband or someone was a general director.

3 I don’t know who that was — I mean the executive

4 director, because there is a nominal director and there

5 is an executive director. Of course there must have

6 been someone, but definitely not my mum. She was not

7 a chief accountant. That, indeed, is an error.

8 Q. And would it be fair to say that what happened in

9 relation to this company is that although your mother

10 was said to be — or your mother was described as the

11 director general, as you say, that was really a nominal

12 role and the company was really being managed or run by

13 other people?

14 A. Yes.

15 Q. And can you identify who those people were? Who it is

16 most likely to be? Would that be your husband? Would

17 he be involved?

18 A. I don’t know the answer to that question. It would be

19 best to ask my husband on Monday. He would be better

20 placed to say who was the executive director of that

21 company at that time.

22 Q. If it is right that your mother was only a nominal

23 director, when she signed these accounts she must have

24 been relying on somebody else for the accuracy of them,

25 mustn’t she?

1 asking me such narrow questions when I already said that

2 I was not involved in the activities, especially in such

3 depth, and you are asking me — showing me some cool

4 amounts, because that’s actually a breakdown of

5 the balance sheets. They are extremely specialist

6 questions so that’s why, I’m sorry, I smiled.

7 Q. That’s all right, and if I say to you, might the

8 City Centre transaction have involved the transfer of

9 funds from OMG companies to an entity in which you or

10 your husband had an interest, what would you say to

11 that, if I asked you that question?

12 A. I wouldn’t be able to say anything in this respect. If

13 you could, please, ask my husband, perhaps he will

14 recollect. He was quite deeply involved in that. He

15 was involved on a daily basis in 2009 and in all the

16 previous years.

17 Q. Is it possible that could be an explanation?

18 MR JUSTICE HILDYARD: What do you mean by that? What are

19 you asking this witness?

20 MR LORD: I won’t ask that question.

21 MR JUSTICE HILDYARD: «Possible» in sort of philosophical

22 terms?

23 MR LORD: I won’t ask that question, my Lord. Sorry,

24 I won’t ask that question.

25 A. Should we ask my husband on Monday, perhaps he will be

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1 able to answer. He might be able to give a specific

2 answer to assist the court.

3 Q. Yes, I have asked him about that, Mrs Arkhangelskaya,

4 but thank you.

5 Could I please ask you to go in your witness

6 statement, please, to paragraph 23. {C1/2/4} in the

7 English and {C1/2/11} in the Russian, please.

8 You were talking about the purchase of your flat in

9 Nice, I think; do you see that?

10 A. Yes.

11 Q. And you can see in paragraph 23 you say:

12 «My understanding was that the funds I used to

13 purchase the flat represented part of my personal income

14 to which I was entitled.»

15 Do you see that?

16 A. Yes, I’ve read it.

17 Q. Might it be the case that those funds came from monies

18 that had been borrowed by other OMG companies?

19 A. The funds that were used to purchase the apartment? Do

20 I understand correctly, sir?

21 Q. Yes.

22 A. These were our personal funds.

23 Q. Can you identify the source of those; where did those

24 funds come from? Were they payments out of dividends,

25 or were they from some other source? How did you get

1 Q. Were you not shown documents that referred to

2 the potential repurchase of the shares back from

3 Sevzapalians for the same price?

4 A. No, I’ve seen a document signed, as I thought by someone

5 else, definitely not myself, saying that I’ve sold my

6 share for — it was a very small amount in roubles,

7 RUB 10,000, or RUB 20,000. I’ve definitely seen that

8 document. Then I even had to go to court and provide

9 specimens of my signature, saying that I’ve never signed

10 that document.

11 Q. If we go to {D122/1954/1} and also have {D122/1954/5} on

12 the screen, please, you can see what appears to be

13 a judgment of the Court of Arbitration of

14 St Petersburg, June 23, 2009.

15 You have the Russian on screen there. If you just

16 familiarise yourself with it, you can see that it’s

17 a judgment that appears to be concerning a claim by you

18 against Sevzapalians and OMGP; can you see that?

19 A. Yes.

20 Q. On the first page it says, «In the presence of», and

21 then for Arkhangelsky UA, her representative,

22 Erokhina NV.

23 Did you have a lawyer called Erokhina at that stage?

24 A. Mr Erokhin, Nikolai Erokhin, yes.

25 Q. I think at that stage, April 2009, you were still living

85 87

1 the money to buy the flat, I suppose?

2 A. Salaries, dividends. Various sources of income.

3 Q. Can I ask you, please, to go to {C1/2/13}, paragraph 34,

4 and it is {C1/2/6} in the English. I want to ask you,

5 Mrs Arkhangelskaya, about the evidence you give under

6 the heading, «Claims to set aside transfer of shares in

7 Western Terminal LLC and Scandinavia Insurance LLC»; can

8 you see that?

9 Can you see what you say there? Can you read

10 paragraphs 34 and 35 to yourself, please. (Pause)

11 A. I have read it.

12 Q. I think in paragraph 35 you say:

13 «I understood that the basis on which the transfer

14 was disputed was that the price paid for the shares by

15 Sevzapalians LLC and the new shareholders of

16 Scandinavia Insurance LLC was nominal.»

17 Can you see that?

18 A. Yes.

19 Q. And how did you get that understanding? How was that

20 understanding derived? Where did the information come

21 from?

22 A. From the group’s lawyers, and more specifically it was,

23 I think, Mr Vasiliev who shown me a document, allegedly

24 signed by myself, saying that I’ve sold my share for

25 a very small amount of money.

1 in St Petersburg, weren’t you?

2 A. Yes.

3 Q. If you look through this judgment, Mrs Arkhangelskaya,

4 you can see what appears to be the basis of

5 the complaints that were being made on your behalf in

6 this claim. If you go to the second page, {D122/1954/2}

7 {D122/1954/6}, second paragraph:

8 «In support of her claims, the plaintiff refers to

9 the fact that the contentious transaction conceals

10 a gift agreement and that the contentious transaction

11 results in a considerable damage for ‘Oslo Marine Group

12 Ports’ LLC.»

13 Can you see that?

14 A. Yes.

15 Q. So, one of the complaints being made on your behalf in

16 these Russian proceedings was that this share transfer

17 to Sevzapalians was a concealed gift?

18 A. I wouldn’t be able to answer this question precisely

19 now, because then, a considerable legal department was

20 operating at OMG, so in essence they were dealing with

21 all the proceedings. They were providing consultancy

22 services to me, so I wouldn’t be able to respond at this

23 point in time.

24 Q. Because I don’t want to ask you questions that you are

25 not able to answer, but I just assumed, as this was the

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1 judgment in the claim that was made by you, that you

2 might have authorised what was being said in this claim;

3 is that wrong, or is that right? Did you authorise the

4 various points to be made in these proceedings by

5 Mr Erokhin?

6 A. Mr Erokhin and the law firm, indeed, were acting for me,

7 on my behalf, because I was the owner, most likely. But

8 I would not be able to answer your question, sir,

9 because a large legal department was involved in that,

10 and I think there were about 20 people there.

11 I wouldn’t be able to answer that question being here

12 now.

13 Q. Were you not required to sign off on, or authorise,

14 various documents filed with the court as part of this

15 claim? It was a claim made by you, wasn’t it?

16 A. Mr Erokhin in this particular case must have had a power

17 of attorney, given by myself, to go to court and to

18 represent me, because without a power of attorney from

19 me, he simply does not have the right to go to court on

20 my behalf.

21 I visited the court two or three times and for the

22 rest of it, the group’s lawyers were involved in that;

23 the groups of Oslo Marine Group.

24 Q. If you just read down page 2 and page 3, you can see

25 that, from the judgment, at least, it looks as if one of

1 Q. Was your husband involved in this claim? Did he help

2 provide information to the lawyers to prepare this

3 claim?

4 A. I think he was, but, again, this is a question better

5 asked of him. He was a company director. I presume

6 that he was aware of everything that was happening.

7 Q. Because this judgment doesn’t seem to record any

8 reference to the repurchase agreement; in other words,

9 the agreements that Sevzapalians had entered into to

10 sell the shares back, to transfer them back to

11 OMG Ports.

12 Are you aware, Mrs Arkhangelskaya, that the

13 agreement that this judgment refers to has been known as

14 a repurchase agreement, and has a sale agreement and

15 then a repurchase agreement? Are you aware of that, or

16 not? Do you know what I am talking about here?

17 A. I am afraid not. I’m not aware of this.

18 MR JUSTICE HILDYARD: What was the date of the hearing? The

19 judgment is 23 June; does it state, earlier up? Does

20 that say June? I don’t know.

21 It’s just Dr Arkhangelsky left for Bulgaria on

22 9 June, I think it was. I don’t know whether this was

23 before or after.

24 A. I think the judgment was handed down after that.

25 MR LORD: Well, the judgment is 23 June, it says at the top,

89

1 the complaints that was being made in these proceedings

2 on your behalf, was that there was a big discrepancy

3 between the purchase price of RUB 1 billion, which

4 Western Terminal — sorry, which OMG Ports had paid for

5 these shares, and the RUB 9,900 which Sevzapalians had

6 paid to buy the shares from OMGP.

7 You can see that if you read down page 2, which for

8 you is the second page, so it is {D122/1954/6}, and if

9 you read halfway down {D122/1954/7} you can see why

10 I say that.

11 That appears to be one of the material factors that

12 the judgments addresses, the difference between those

13 two sales figures. Can you see that?

14 You look a bit puzzled. Are you not really familiar

15 with any of this, Mrs Arkhangelskaya?

16 A. I really have no comment to offer with respect to

17 a court judgment. I am not quite up to speed on this.

18 This is Russian legalese, the Russian language used by

19 lawyers, so it would be very difficult for me to even

20 understand what it says.

21 I can tell you my side of the story. I did attend

22 at court. I did not sign the document that had been

23 shown to me by a group lawyer, by an in-house lawyer,

24 but this legalese is really something that I would

25 struggle with.

91

1 2009.

2 MR JUSTICE HILDYARD: Yes.

3 MR LORD: But your Lordship is asking about the hearing.

4 MR JUSTICE HILDYARD: Anyway, I don’t know whether there is

5 any other — if in the files there is any document which

6 shows the date of the actual hearing, I would be

7 obliged.

8 MR LORD: Could we be shown Day 9, please, of

9 the transcript. My Lord, it may be a point, really,

10 more for your Lordship than for this witness, but I do

11 think it is right to point this out, at this point, for

12 your Lordship’s note.

13 Can we go to {Day9/38:1}. Your Lordship will

14 recollect that Mr Stroilov asked a series of questions

15 of Ms Stalevskaya about various accounts that had been

16 given under interview by her and others.

17 MR JUSTICE HILDYARD: Oh yes.

18 MR LORD: It is important for your Lordship to note, in

19 light of the questions I have asked and the answers I’ve

20 had, it’s a line of questioning which may not need to be

21 followed much with this witness, but I do think at this

22 point your Lordship should see these questions. I think

23 there is one question I can fairly ask of this witness.

24 MR JUSTICE HILDYARD: Right. Ask it slowly and I can take

25 a view.

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1 MR LORD: Your Lordship can see, from page 38, if one

2 scrolls on down to page 39, {Day9/39:1} Mrs Stalevskaya

3 is being asked about a — well, there is a record of

4 an interview she gave in relation to the transfer of

5 the Western Terminal shares. Your Lordship will

6 recollect that line of questioning?

7 MR JUSTICE HILDYARD: Yes.

8 MR LORD: It produced a certain reaction from the witness in

9 the end, which has been referred to by Dr Arkhangelsky

10 several times in his evidence.

11 MR JUSTICE HILDYARD: Yes.

12 MR LORD: It goes over the page to page 39, and Mr Stroilov

13 said in line 3: {Day9/39:3}

14 «Question: … Now, Mrs Stalevskaya, pausing here,

15 that is quite misleading, isn’t it?»

16 She said:

17 «Answer: No. Well, for me this is not misleading.»

18 He said this at line 6, Mr Stroilov: {Day9/39:6}

19 «Question: Well, but obviously in this interview,

20 you presented the deal as no more and no less than

21 a genuine sale of a company; isn’t that right?»

22 Then for your Lordship, similar points are made on

23 pages 74, 75, 76, 77 and, really, onwards. {Day9/74:1}

24 {Day9/75:1} {Day9/76:1} {Day9/77:1}

25 I was going to ask, Mrs Arkhangelskaya: Mr Stroilov

1 doubt as to Mr Stroilov’s ability to represent her, and

2 that’s a rather different question, but as to the

3 authority when she doesn’t even know about the repo, it

4 seems unlikely that she gave express authority.

5 MR LORD: No, but there was a very vigorous —

6 MR JUSTICE HILDYARD: You interrupted at some point to make

7 clear that you would be asking.

8 MR LORD: I did.

9 MR JUSTICE HILDYARD: And that’s why I was trying to find

10 the nature of your interruption.

11 MR LORD: I did. It was on page 81, I haven’t got the line,

12 I am afraid. It was on page 81 — {Day9/81:12}

13 MR JUSTICE HILDYARD: Thank you. You gave a warning in this

14 regard.

15 MR LORD: I was just concerned — it did seem that —

16 anyway, that is a matter for submission; it is not

17 a matter for this witness.

18 MR JUSTICE HILDYARD: This is a question I shouldn’t really

19 be asking now, so I do so with anxiety: did

20 Mrs Arkhangelskaya sign the authority to Mr Stroilov?

21 MR LORD: We are checking whether we have ever had a signed

22 copy. We may or may not have, we will check.

23 MR JUSTICE HILDYARD: I know it is not the burden of your

24 question, but do you mind if I check with

25 Mrs Arkhangelskaya?

93

1 has been licensed to conduct the litigation on behalf of

2 the defendants, including you; are you aware of that?

3 Have you authorised Mr Stroilov to act on your behalf in

4 these proceedings? (Pause)

5 A. It’s very difficult for me to answer that question.

6 It’s a different thing. Mr Stroilov, I think,

7 represents me as a friend. He is not my barrister. He

8 does not act for me. He is not an advocate, is he?

9 Q. Have you authorised Mr Stroilov to put a line of

10 questioning to witnesses to the effect that the sale of

11 Western Terminal shares by OMGP to Sevzapalians

12 in December 2008, if that transaction is presented

13 without reference to the repurchase agreement, that

14 would be misleading? That would be a misleading

15 presentation of that or those transactions?

16 A. My apologies, I am not sure I understand your question

17 and so I cannot answer that.

18 Mr Stroilov does act for me in court, but I am

19 afraid I cannot answer your question, the way it was

20 asked.

21 MR JUSTICE HILDYARD: This witness has said, I think, that

22 she doesn’t really know about the repurchase.

23 MR LORD: No.

24 MR JUSTICE HILDYARD: I’m not sure how far you can take

25 this. I mean, I would be concerned if there is any

95

1 MR LORD: And to be clear, it wasn’t the burden of my

2 question.

3 MR JUSTICE HILDYARD: No.

4 MR LORD: My concern was this line of questioning.

5 MR JUSTICE HILDYARD: Yes, well, finish it if you like,

6 but —

7 MR LORD: No, I have finished; I have nearly finished in

8 general, actually.

9 MR JUSTICE HILDYARD: Yes.

10 Mrs Arkhangelskaya, you are absolutely right that

11 Mr Stroilov is not a barrister, and he is acting pro

12 bono, and he has no rights of advocacy, but my

13 understanding is that both you and your husband have

14 authorised him to speak on your behalf in these

15 proceedings, and a document has been prepared which

16 I think should be signed by you both, confirming those

17 facts. Were you aware of this?

18 A. I think there was a document. I do understand that the

19 English court made an exception for us, for my husband

20 and myself, because we are impecunious. We cannot

21 afford paying a lawyer, so we wanted to be represented

22 by a lawyer, and a friend, and we understand that the

23 English court kindly made an exception for us.

24 MR JUSTICE HILDYARD: Yes. And so I can take it that what

25 Mr Stroilov says, you may not know each and every bit of

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1 what he says, but he is appearing before me with your

2 agreement to represent you; yes?

3 A. Yes, of course.

4 MR JUSTICE HILDYARD: Yes.

5 MR LORD: Mrs Arkhangelskaya, can I ask you, please, to go

6 to {C1/2/5} in the English, and it is paragraph 33,

7 {C1/2/13} in the Russian.

8 You give some evidence as to the purpose of

9 a marriage property contract, I think it is probably

10 fair to describe it as, that you entered into

11 in May 2009; can you see that?

12 A. Yes, I’ve read it.

13 Q. And you say in paragraph 33:

14 «The purpose of this agreement was to clarify how

15 matters stood between Vitaly and me, and to safeguard my

16 position and that of our children for the future.

17 Neither it, nor any other actions of mine were intended

18 to put property that was really my husband’s beyond the

19 reach of his creditors.»

20 Can you see that?

21 A. Yes, and that is true.

22 Q. And what did you, or what do you mean by safeguarding

23 your position and that of your children for the future;

24 what do you mean by that in that context? What are you

25 talking about?

1 were being interviewed by the police, some people were

2 in prison. Raider attacks continued at a pace, so what

3 would you expect me to have done under the

4 circumstances? But, unfortunately, we were not able

5 even to safeguard one flat for us.

6 So I did ask lawyers to draft a nuptial contract

7 whereby at least my flat, the flat that I had owned

8 prior to the marriage, would be ringfenced, it would be

9 kept as my property, but unfortunately it was not

10 properly drafted so nothing what I wanted to see

11 happening actually happened.

12 MR LORD: My Lord, I have about another 15 or 20 minutes,

13 and I anticipate that Mrs Arkhangelskaya might well want

14 to get away. I don’t know whether your Lordship would

15 wish to have a break or just keep going. I have, as

16 I said, probably about another 15 minutes all told.

17 I am in your Lordship’s hands, but it may be that we

18 don’t need to break for an hour and then come back for

19 15 minutes, particularly if Mrs Arkhangelskaya would

20 rather get back and away. So, I am in your Lordship’s

21 hands.

22 MR JUSTICE HILDYARD: Well, I think we should have a break

23 in any event, but not necessarily …

24 Which would you prefer: do you want a longer break

25 now, which means that you will get away later, or do you

97

1 A. Well, I think that was the idea, but that contract was

2 not properly drafted, unfortunately; it was not properly

3 drafted by our lawyer back in 2009. I understood,

4 I think, that my husband had problems. Back in 2005,

5 someone broke his nose, smashed his nose in, in

6 the forest, so that’s when the problems started. So

7 I realised that anything can happen to me or to my

8 husband in the Russian Federation. We could be killed

9 for all I know.

10 And that contract, however, did not work to my

11 benefit because it was not properly drafted. I could

12 not even safeguard the flat that I bought in 1996.

13 Legally, I was the legal owner of that flat, and my

14 mother was the actual owner of the flat.

15 If you have seen that contract, it was not properly

16 drafted and all the assets were actually split 50/50 and

17 so I was unable to ringfence any of the assets.

18 Q. And why would you want to ringfence the assets? What

19 were you ringfencing them from?

20 A. Well, I have three children, and no one knows what may

21 happen to my husband. There were lots of personal

22 threats. Every day we had lots of bodyguards

23 accompanying myself, my children and my husband. Our

24 house was being protected by bodyguards.

25 Now, he was summoned for interviews. His employees

99

1 wish to have a break of, say, 15 minutes now, and then

2 come back and try and finish it off by 2.00, which would

3 enable you to get home …

4 A. My Lord, I am in your hands. I have a flight at 18.55,

5 6.55 pm, so I just need to make sure that I can hop on

6 the bus and go straight to the airport.

7 MR JUSTICE HILDYARD: I’m really enquiring whether you feel

8 tired and need a break for longer than, say, 15 or

9 20 minutes? I can’t tell that for you.

10 A. My Lord, if I could have half an hour, that would be

11 greatly appreciated.

12 MR JUSTICE HILDYARD: Shall we do a short break of half

13 an hour?

14 MR LORD: Yes.

15 MR JUSTICE HILDYARD: And halve the difference between us,

16 if you like, and hope to finish by 2.30 or so. I will

17 have one or two questions.

18 So we will have a break for half an hour now.

19 MR LORD: My Lord, it is obviously right that the witness

20 shouldn’t speak to anyone. I’m sure she knows that.

21 MR JUSTICE HILDYARD: I am so sorry, yes.

22 Mrs Arkhangelskaya, you mustn’t talk to anyone about

23 this case, your husband or Mr Stroilov or anyone else;

24 best to keep yourself to yourself until you are freed

25 from this.

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1 (1.03 pm) 1 (Hearing in private)
2 (The Luncheon Adjournment) 2 [REDACTED]
3 (1.33 pm) 3
4 MR LORD: May it please your Lordship. I am going to ask 4
5 some questions now about certain matters pertaining to 5
6 accounts that we have had recently disclosed and, again, 6
7 I am in your Lordship’s hands as to the regime in which 7
8 those questions are to proceed. 8
9 MR JUSTICE HILDYARD: Well, I think that we decided that the 9
10 dangers were sufficient to justify it being in private; 10
11 is that right, because of the potential for there being 11
12 confidential information, or very sensitive information; 12
13 do you object to that? 13
14 MR LORD: I do not. 14
15 MR JUSTICE HILDYARD: So, shall we mark this — 15
16 MR LORD: Sorry, my Lord, nor do I want it to be said 16
17 against me that I have pushed for the closing up — 17
18 MR JUSTICE HILDYARD: No, you have simply been fair about 18
19 it. 19
20 MR LORD: I am being very fair. It is no business of mine 20
21 to cause any embarrassment or breach of confidence, so 21
22 I am not objecting to that regime at all. 22
23 MR JUSTICE HILDYARD: What I propose to do is direct that 23
24 this be in private. I just want to explain the effect 24
25 to Mrs Arkhangelskaya, in case she has any concerns or 25
101 103
1 objections to that. 1 [REDACTED]
2 Your husband provided documents, which I think you 2
3 had obtained from your bank, Société Générale. They 3
4 include various entries, some of which may be — I don’t 4
5 know whether they are, but may be personal or 5
6 confidential, doctors’ fees, that sort of thing. For 6
7 that reason, when Mr Lord asked your husband questions 7
8 about this, we moved from being a public hearing to 8
9 being a private hearing. 9
10 Now, the effect of that is that it is still evidence 10
11 in these proceedings, but that the public, the wider 11
12 public, cannot obtain any record of it without my 12
13 permission. 13
14 So Mr Lord, not because it is in his interests or 14
15 his clients’, but simply out of concern for you and 15
16 Dr Arkhangelsky, has mentioned the matter to me, very 16
17 fairly, and has indicated that he has no objection to 17
18 this part of the proceedings being in private. I assume 18
19 you would like that also, and unless you state 19
20 otherwise, therefore, we will continue in private until 20
21 I say otherwise. 21
22 Is that all right? 22
23 A. No objections, sir. I agree. 23
24 MR LORD: Thank you, my Lord. 24
25 (1.36 pm) 25
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8 8 (2.10 pm)
9 9 (Hearing in open court)
10 10 MR LORD: Mrs Arkhangelskaya, could you please go in your
11 11 witness statement to paragraph 25, which is at
12 12 {C1/2/12}, and it is {C1/2/4} in the English; can you
13 13 see what you say in paragraph 25?
14 14 A. Yes.
15 15 Q. It looks from that paragraph as if your husband was
16 16 operating in a rather dangerous business environment
17 17 from as early as 2005; would that be fair?
18 18 A. I wouldn’t call it dangerous business. You see, when
19 19 you carry on business in Russia, any kind of business,
20 20 even small business, it is dangerous because if you have
21 21 money, then this means that you have something that can
22 22 be taken away from you, but within the Russian legal
23 23 system there is no way you can defend your rights or
24 24 your position. So in that sense, I agree. Yes.
25 25 Q. And those sorts of concerns you describe in
121 123
1 [REDACTED] 1 paragraph 25, they started well before you allege any
2 2 conspiracy against Bank of St Petersburg; that’s right,
3 3 isn’t it?
4 4 A. Well, it says that he was attacked for the first time
5 5 back in 2005. So he was summoned to attend police
6 6 interviews; I think it was the same investigator all the
7 7 time.
8 8 Q. And I think, from paragraph 25, you are saying that you
9 9 hired security guards for you and your husband and
10 10 family after the 2005 attack; is that right?
11 11 A. It wasn’t quite the case, ie we did have bodyguards but
12 12 when Vitaly contacted the law enforcement agencies in
13 13 2005 with a statement saying that he was beaten up and
14 14 his nose was broken, the law enforcement agencies
15 15 offered a specific company to us, where we should have
16 16 booked bodyguards. That’s the way it works in Russia.
17 17 Q. But this position that you found yourself in in Russia,
18 18 it predated your complaints about the
19 19 Bank of St Petersburg, didn’t it?
20 20 A. Yes, there was this one-off case which was extremely
21 21 unpleasant. Yes, it did happen before, it was in 2005.
22 22 Q. And did you continue with — did your husband and you
23 23 continue to have security guards thereafter; in other
24 24 words all the way through, up until the time you left
25 25 Russia?
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1 A. Yes, that’s correct.

2 Q. And if I could ask you, please, to look in paragraph 16

3 of your witness statement, which is {C1/2/3} in

4 the English, {C1/2/11} in the Russian, please, you can

5 see that you describe how in 2007 you and Vitaly:

6 «… decided to acquire holiday flats in …

7 Bulgaria…»

8 Can you see that?

9 A. Yes.

10 Q. And you see what you say later on in that paragraph:

11 «The main purpose of this investment was to obtain

12 a Bulgarian residence permit for our family to live in

13 the EU, since I wanted to spend extended periods of time

14 in Europe with the children.»

15 Can you see that?

16 A. Yes, that’s correct.

17 Q. So would it be fair to say that from about spring 2007,

18 you were contemplating going to bring up your family in

19 western Europe, somewhere in the EU, rather than in

20 Russia?

21 A. No. This is absolutely ruled out. I wanted to say the

22 following in the paragraph: with a Russian passport,

23 being in the European Union, one can only stay there for

24 three months. After that one needs to leave. And the

25 same applies to Bulgaria. Would you like to spend four

1 wasn’t part of my plan. Maximum, to spend holiday away

2 when he would join us as well.

3 Q. And the problems that your husband’s businesses ran into

4 in 2009, did that not just really speed up a decision to

5 go and live somewhere other than Russia? Did it not

6 just speed things up?

7 A. No, not at all. This is not the case, and I repeat:

8 I had no plans to leave Russia. This is confirmed by

9 the fact that as of 2009, I had neither a Bulgarian

10 passport or French passport or any other documents other

11 than the Russian documents.

12 Q. And is it right — paragraph 28, I think, of your

13 witness statement, {C1/2/5}, and {C1/2/12} in

14 the Russian — that when you left Russia in June 2009,

15 you were going on holiday to Bulgaria; is that right?

16 It was a planned holiday, wasn’t it?

17 A. Yes, for three months, for about three months, that’s

18 correct.

19 Q. And was it planned that your husband was going to join

20 you on that holiday?

21 A. Yes, in 2009, I think that was the third year on the run

22 when we spent in Bulgaria. Usually he would spend

23 a week with us and then come back. That’s the way it

24 was. I would spend the whole summer with the kids in

25 Bulgaria and he would visit us from time to time, as he

125 127

1 or five months in a year in Bulgaria, you need to get

2 a residence permit in any European country. So that was

3 the only goal, to spend some holiday there, no more,

4 because my husband wanted to continue working in Russia,

5 we had no plans to leave for good, but our objective was

6 to spend some holidays there because the St Petersburg

7 climate is not very good for lengthy holidays, and we

8 wanted to spend lengthy holidays that a standard tourist

9 visa would allow us.

10 Q. And is it perhaps right that you were — your husband,

11 obviously — well, you describe the security issues

12 surrounding your husband as starting in 2005, and then

13 you give some evidence about buying holiday flats in

14 Bulgaria in 2007, and then in paragraph 22 on {C1/2/4}

15 you describe buying a holiday home in the south of

16 France; do you see that?

17 MR JUSTICE HILDYARD: I think in the Russian that is at

18 {C1/2/11}.

19 A. Yes. Yes, I can see that.

20 MR LORD: Were you already making plans by about 2008 to go

21 and maybe bring your family up outside Russia, given the

22 security issues that you and your husband had found in

23 Russia?

24 A. No. We had no such plans because my husband was working

25 six days a week and I had no plans to leave him. It

1 could, either for a weekend or for a week.

2 Q. Could you go, please, to paragraph 46 in your witness

3 statement, which is {C1/2/14} and {C1/2/7} in

4 the English. You can see what you say there. You say:

5 «When Vitaly and I brought proceedings in the BVI

6 against the Bank and Mr Savelyev … I believed the

7 claims we brought against them to be true, and I still

8 believe this to be the case.»

9 Can you see that?

10 A. Yes.

11 Q. Mrs Arkhangelskaya, you don’t have any independent basis

12 to support the claims your husband makes against the

13 Bank in these proceedings, do you? You rely on what he

14 tells you, don’t you, really?

15 A. Well, of course he understands the case better, but I am

16 completely convinced that he is right. I have no

17 grounds not to believe him.

18 MR LORD: Thank you, Mrs Arkhangelskaya.

19 Thank you, my Lord.

20 Questions by MR JUSTICE HILDYARD

21 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, I have one or two

22 questions for you. I am so sorry to detain you.

23 I won’t have the command of the documents that Mr Lord

24 has.

25 There was one small detail which I wanted to clarify

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1 with you, in case there was a language issue. I wonder

2 if you could go to today’s [draft] transcript at about

3 page 26, is my note.

4 Yes, in lines 17 to 19, where you were explaining,

5 I think your mother’s involvement as a director, you say

6 in line 17:

7 «Answer: That is true. I don’t deny it. I didn’t

8 like the situation very much because anything linked to

9 my husband, everything is very strange.»

10 I wondered what you meant by that; would you like to

11 explain it a little bit more? Do you mean complicated,

12 or do you mean peculiar?

13 A. Rather complicated. I think it rather means it’s closer

14 to complicated, because that was a complex, not

15 straightforward period in his life, so I didn’t want my

16 mum to be a nominal director. I didn’t want that very

17 much. But there were no other people with a different

18 surname available, and so my mum was a nominal director.

19 But the word, perhaps, shouldn’t be the word

20 «strange», but rather it depicts complexities that

21 I already felt at that time. I didn’t want her to be

22 a nominal director, but that was a bank requirement, for

23 a different person with a different surname to be

24 a director.

25 MR JUSTICE HILDYARD: And did you express your concerns to

1 A. To put it this way, in these proceedings sometimes

2 I sign documents in English, based on my trust in

3 the translators, in my husband saying that that is

4 a true document. That could be the case. That could

5 happen.

6 However, this is within the proceedings, within the

7 framework of the proceedings of our case.

8 MR JUSTICE HILDYARD: But not a transactional document;

9 a document involving some transaction.

10 In your adult life, and since 2006, do you ever

11 recollect a time when you signed knowingly, but unclear

12 as to what the effect of the document would be?

13 A. That is completely ruled out because I have learned in

14 my bitter experience, since I was 18, I had my first

15 apartment and everything worked out so well in the end;

16 and my mum taught me, never, ever sign any blank

17 documents, never sign any other documents, just be

18 really careful. So with regard to anything that has my

19 name to it, with regard to anything to do with money,

20 I’m very careful. I’m quite careful because that could

21 backfire and I may end up with a problem for myself.

22 MR JUSTICE HILDYARD: Can you be quite clear that there was

23 never an occasion after 2006 when your husband suggested

24 to you that your spousal consent was required to enable

25 the Bank to provide money which was needed in the

129 131

1 your husband that you didn’t want your mother involved

2 in this way?

3 A. To be honest, yes. I did.

4 MR JUSTICE HILDYARD: But he convinced you that if that is

5 what the Bank required, that is what you should do?

6 A. Rather, he made an agreement with my mum, without my

7 involvement. She trusted him that that, indeed, was

8 necessary, that that’s a purely nominal appointment, and

9 she agreed because it was my mum’s consent, not my

10 consent, in that particular case. She trusted him

11 completely and agreed to be a nominal director to aid

12 the cause.

13 MR JUSTICE HILDYARD: I see. Now, did you, as best you can

14 recollect, ever sign a document which you didn’t really

15 understand, but simply because your husband told you it

16 was necessary to sign it for some purpose of

17 the business?

18 A. I tried never to sign documents. So the answer is

19 rather no than yes. I do not sign documents as simply

20 as that.

21 MR JUSTICE HILDYARD: Did you ever sign a document, so far

22 as you recollect, without quite knowing what it

23 signified?

24 A. So, ever in my life?

25 MR JUSTICE HILDYARD: Well, ever since 2006, let us say.

1 business?

2 A. There was never such an occasion. I can be quite clear.

3 I confirm.

4 MR JUSTICE HILDYARD: I’m just going to ask you a little bit

5 more about that because, of course, now, and with the

6 rather dismal benefit of hindsight, the documents

7 obviously expose you and your family to risk; but at the

8 time, when things were happier and the business looked

9 as if it had good prospects, provided that the Bank

10 provided money, it might have looked rather different,

11 and your husband might have said something along the

12 lines of: oh, come on Julia, sign, because then we get

13 the money from the Bank, after all we’ve got no money

14 outside our companies, what’s the harm of it?

15 Do you recollect anything like that taking place?

16 A. Sir, are you trying to say that my husband could have

17 misled me? No, that is ruled out. No.

18 MR JUSTICE HILDYARD: Not mislead you, but try and persuade

19 you that because of the need for money, signing

20 a guarantee when the prospects look good and you have no

21 assets outside the companies might not look as dangerous

22 then as it looks now.

23 A. No, that simply could not happen because the documents

24 you have put to me about my guarantees, the sums are

25 astronomical, they are crazy, they are large amounts of

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1 money.

2 MR JUSTICE HILDYARD: Can I just make sure that I have

3 understood your evidence on that point, because

4 I explained to you, in a way which I dare say was not as

5 clear as I should have liked, but I explained to you

6 that the legal effect of the document is simply to give

7 your consent to a liability undertaken by your husband,

8 not to give your consent to any liability personally on

9 your part. And I felt you understood that.

10 Do I understand your true position to be that in

11 economic terms, if your husband had guaranteed it, your

12 family had guaranteed it, in economic terms; is that the

13 effect of your evidence?

14 A. I can see my name and I can see a large amount of money.

15 That suffices to understand that that should never be

16 signed, because this is my surname. This is not my

17 husband’s surname.

18 Well, I have a husband today, I might have no

19 husband tomorrow, but it is still my name to it.

20 MR JUSTICE HILDYARD: So the effect of your evidence is that

21 anything with such sums and with your name on the same

22 bit of paper, your evidence is you would never have

23 signed such a piece of paper; is that right?

24 A. With the full understanding of what I am signing,

25 perhaps, but I’ve never signed documents in my life to

1 certificate?

2 A. My Lord, do you mean within the proceedings with the

3 Bank, or in my life, ever?

4 MR JUSTICE HILDYARD: Yes, I am so sorry, it was a bad

5 question. In relation to some transaction with the

6 Bank.

7 A. I visited the Bank once or twice, maybe twice in my

8 life. That was pertaining to purchasing an apartment in

9 Nice, because I had to arrive at the bank and sign

10 a payment order for the money transfer. I have never

11 visited the Bank after that, and I don’t think I had

12 a personal account in that bank either.

13 MR JUSTICE HILDYARD: You were asked this by Mr Lord, but

14 I just want to make quite sure that I know your evidence

15 on it. As best you can recollect, did anyone employed

16 by the Bank come to your home with a document and ask

17 you to sign it, where that document related to

18 a transaction with the Bank?

19 A. No. That never happened. No employees would visit my

20 house. My house was closed territory for such type of

21 visits.

22 MR JUSTICE HILDYARD: Can I ask you a question in relation

23 to paragraph 26 of your witness statement, which in

24 the English is at {C1/2/4} and in the Russian

25 translation is at {C1/2/12}. Mr Lord asked you some

133 135

1 that amount. It’s a very large amount. With large

2 amounts, property transactions — I had some property

3 transactions in my life, but I understood what was at

4 hand. They were completely different amounts of money.

5 MR JUSTICE HILDYARD: Can we just have a look at {O1/12/1}

6 which I think is in the English at {D13/305/1}.

7 A. Have you put this document to me already today?

8 MR JUSTICE HILDYARD: Yes, you were taken to this.

9 Now, according to the English translation, and in

10 brackets, under a reference to «Certificate I-AK N6/7356

11 03.08.2002», in English, it states:

12 «(Full name, marriage certificate, passport

13 details).»

14 Do you ever recall providing either your marriage

15 certificate or passport details in respect of such

16 a document?

17 A. My passport details and all the other documents, all the

18 documents that exists, at least at the employment

19 department, at the human resources department, I did

20 provide them, but that type of data is not secret. It’s

21 easy enough to find it anywhere.

22 MR JUSTICE HILDYARD: I see. Right. Yes.

23 Do you ever recollect someone witnessing your

24 signature having in your presence checked the details on

25 a piece of paper relating to your passport or marriage

1 questions on this. You say that:

2 «In March and April 2009 [you] realised, from

3 speaking to [your husband], that the business was under

4 serious threat.»

5 Your husband gave evidence, which was not

6 surprising, that the Lehman collapse back

7 in September 2008 had been a searing experience for him,

8 which he would never forget; and it is clear that

9 business in Russia, as in many places, was stressful at

10 that time and that OMG and its various companies were

11 under stress.

12 Did your husband share with you any concerns in that

13 regard? The reason I ask is because you only state in

14 your witness statement that your concerns arose in March

15 and subsequently.

16 A. My husband, of course, did share his concerns because

17 about once a week he would go and speak to

18 an investigator, and usually in Russia it’s a very bad

19 indicator if investigatory bodies would take interest in

20 you, because in Russia they don’t work in a honest way

21 for the most part.

22 I disliked it, and even in 2006 there were attacks

23 at his companies. I do not recall the exact companies

24 now, that was very unpleasant, he was very upset. That

25 was incredible stress for him. So it wasn’t a one-off

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1 case. That was in 2008, in 2007. Then in 2008 his

2 chief accountant spent three days in prison. That was

3 a nightmare because there was a complete pressure on my

4 husband because, well, a chief accountant, that was

5 a lady drawing up balance sheets. She couldn’t have any

6 guilt upon her. Then an employee, I think his name was

7 Shevelev, he spent some time in prison.

8 So I had many reasons for disquiet. I could list

9 them. But in 2009, Vitaly said that the business,

10 actually the business, was under serious threat, and he

11 explained to me it wasn’t as much for the crisis, but

12 I knew about the raider attacks, there is such practice

13 in Russia, because as soon as a person gets some

14 property in Russia, immediately some people would spring

15 up that would like to take that property away. Laws

16 don’t work, there is no defence and this is what he

17 explained to me.

18 MR JUSTICE HILDYARD: I see. So in paragraph 26 in

19 the first sentence, when you say «under serious threat»,

20 you mean under serious threat from a raider attack,

21 rather than from economic or financial problems; is that

22 right?

23 A. Yes. Yes. The financial crisis, I think my husband

24 with his knowledge and skills, he would have sailed

25 through that quite calmly. No, that was a threat of

1 A. No, unfortunately I wouldn’t be able to answer this

2 question. I knew that there were two main banks at that

3 point in time issuing loans to my husband’s businesses,

4 but I don’t know the detail, who did he meet with, and

5 their surnames, et cetera.

6 MR JUSTICE HILDYARD: So he didn’t share his business

7 worries and their solution with you at all; you were

8 rather kept in the dark, would that be fair?

9 A. Up until April 2009 when I had to take part in the court

10 proceedings, I knew very little detail.

11 MR JUSTICE HILDYARD: You told us that you had, in

12 the difficult circumstances in Russia, many security

13 guards. Were they there when you had to return for the

14 court case in June/July 2009?

15 A. My Lord, do you mean 1 September 2009, the proceedings,

16 the hearing of 1 September?

17 MR JUSTICE HILDYARD: When you came back, yes, yes.

18 A. On 1 September 2009, yes, Mr Kapustin was there,

19 definitely. One or two lawyers of Oslo Marine were

20 present, that’s right.

21 MR JUSTICE HILDYARD: They were still employed, were they?

22 A. Yes. For some point in time. But I don’t think that

23 for a long time. When we did not come back to Russia

24 in September, the bodyguards let us down, they gave

25 evidence against us that they should not have done,

137 139

1 a raider attack, of course. The economic crisis,

2 I don’t think so, because his port was something unique.

3 All his other projects were unique for St Petersburg.

4 They could not have been a lost cause. He could not

5 have lost them because, for example, the port in

6 Finland, 97 per cent of cars imported into Russia were

7 imported through the Kotka port in Finland.

8 So, my husband was doing interesting projects,

9 important for developing the industry in Russia, but of

10 course, other people liked that business as well,

11 apparently.

12 MR JUSTICE HILDYARD: Did he ever share with you, or tell

13 you, that he was having to have important meetings with

14 the Bank because he needed loans to be extended because

15 of the financial situation where people were not paying

16 their bills and there were other pressures?

17 A. My husband, no, he didn’t tell me such serious amount of

18 detail. Now I wouldn’t be able to say about specific

19 meetings. I don’t think I know about a specific

20 meeting.

21 MR JUSTICE HILDYARD: It is his evidence that there came

22 a time when he agreed with Mr Savelyev that there was

23 a moratorium such as would save the company or

24 companies; did he ever mention that to you? This would

25 be towards the end of 2008.

1 definitely, because that was about something they didn’t

2 know, and also they stole all our cars and sold them,

3 because they had keys to our cars, there were three

4 quite expensive cars, and they hijacked them, car-jacked

5 them, and sold them.

6 MR JUSTICE HILDYARD: Mr Lord asked you various questions on

7 your expenditure. Just a small detail: most of your

8 holidays in Germany and in Italy were with one or more

9 of your children, but not with your husband; is that

10 right?

11 A. My husband has not been leaving France since 2010. He

12 has never left France, but Monaco is just an exception

13 because there is a special arrangement between Monaco

14 and France with respect to my husband personally.

15 MR JUSTICE HILDYARD: But, have I got this right, he did go

16 with you to Martinique because that is an arrondissement

17 of France?

18 A. Absolutely, yes, Martinique is a department of France.

19 MR JUSTICE HILDYARD: Please give me one second. (Pause)

20 Thank you very much, Mrs Arkhangelskaya.

21 Are there any questions which arise from that,

22 Mr Lord?

23 MR LORD: No, my Lord.

24 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, thank you very

25 much indeed for coming to assist me today and to give

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1 your evidence and be cross-examined. I know these

2 things are very stressful, particularly in circumstances

3 such as these, and I hope you have a good journey back

4 to Nice.

5 A. Thank you very much, my Lord. I would like to thank

6 your Lordship and the court for coming to France to try

7 to understand our position, and I want to thank our

8 interpreters for their excellent work. Thank you very

9 much indeed.

10 MR JUSTICE HILDYARD: So you are free to go, although you

11 have a bit of a wait before your connection.

12 A. Thank you very much, my Lord. Thank you and goodbye.

13 (The witness withdrew)

14 MR JUSTICE HILDYARD: Mr Lord, well done in finishing. Is

15 there anything beyond just touching base as to what’s to

16 happen on Monday, which we can profitably deal with?

17 MR LORD: I don’t think so, my Lord. I think there is one

18 issue about the continued reporting of the trial by

19 Dr Arkhangelsky, which I need to, I think, just apprise

20 your Lordship of, and I need to reflect on it over the

21 weekend and potentially raise it on Monday when

22 Mr Stroilov is there.

23 I don’t know if I could hand in those two copies of

24 a document, please. (Handed)

25 One is an article that appeared, I think, in

1 regards publicity given to a trial is quite a vexed

2 issue, but I have, I hope, warned Dr Arkhangelsky of

3 the very great dangers of a party to the proceedings,

4 especially whilst being cross-examined, apparently

5 putting his own material out, if I can put it that way.

6 MR LORD: And especially, seemingly, trying to direct

7 internet interest in to a potential witness, potential

8 witnesses, who don’t work for one of the parties.

9 MR JUSTICE HILDYARD: Yes.

10 MR LORD: That is a very serious turn of events. It is

11 a very serious turn of events. I won’t say any more

12 than that at this stage, but —

13 MR JUSTICE HILDYARD: I fully understand your —

14 MR LORD: It is a very big matter, and it is likely to

15 feature — I won’t say any more now, but my clients are

16 very concerned about this and the fairness of this

17 process means just that, I am afraid, and it may have

18 got to a very, very difficult stage now.

19 MR JUSTICE HILDYARD: Have you an update such as you could

20 give, provided we re-established a confidentiality

21 regime with respect to Mr Smirnov?

22 MR LORD: I have something of an update which I am happy to

23 share with your Lordship in private, and subject to

24 the strict understanding that this is to be kept

25 strictly confidential and is not to feature in any

141 143

1 Fontanka, which is an online news publication in Russia

2 on 24 February 2016; the other is a translation of

3 a posting, I think, on Dr Arkhangelsky’s Facebook page.

4 Your Lordship will see that it appears to be the case

5 that the video shown in court earlier this week has been

6 posted, and it’s the hashtags with all the names that

7 I would draw your Lordship’s attention to. I think

8 there are hashtags of witnesses or potential witnesses

9 in this case. I think the purpose of hashtags, in my

10 understanding, is to facilitate people who search the

11 internet to be able to alight upon a particular posting,

12 and Mr Smirnov, who is currently — well, your Lordship

13 knows his position, and Mr Sklyarevsky appear there, as

14 well as Mr Savelyev and Bank of St Petersburg.

15 So there are matters that I am going to raise,

16 I think I have to raise, on Monday. Without being too

17 cryptic, a fair and open trial means exactly that: it

18 means a fair and open trial, and it means a fair and

19 open trial for both parties. Your Lordship has made

20 observations about reporting of this case before.

21 I need to collect the references, I need to reflect on

22 things and take some further instructions, but the

23 matter has already got to a really rather serious stage

24 now and I will have to raise it on Monday, I am afraid.

25 MR JUSTICE HILDYARD: What people may and may not do as

1 outside reporting of any sort.

2 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, and I speak now to

3 Mr Stroilov and your husband, and anyone who sees this

4 transcript: anything to do with our next issue is

5 strictly private and confidential, and you must keep it

6 entirely confidential, not tell anybody else about it.

7 I know you will understand this, because you were

8 equally concerned to make sure that your evidence in

9 different medical but similar otherwise circumstances

10 was only seen by me and by the other side, and by no one

11 else. So I know you will understand how crucial this

12 is. I would be more than disappointed, I would be very

13 angry, if this were in any sense to leak out to anyone

14 other than the people immediately concerned now in this

15 case.

16 (2.50 pm)

17 (Hearing in private)

18 [REDACTED]

19

20

21

22

23

24

25

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1 [REDACTED] 1 get all those witnesses completed within three days.
2 2 MR JUSTICE HILDYARD: Right. So it is Mr Pasko, Mr Ameli
3 3 and housekeeping on the 29th; it is Ms Meylanov,
4 4 Mr Ashurkov and Mr Nazarov on the 1st.
5 5 MR LORD: It’s Mr Bromley-Martin, I think, coming on the 1st
6 6 now.
7 7 MR JUSTICE HILDYARD: I’m sorry. Mr Nazarov?
8 8 MR LORD: Mr Nazarov is, I think, coming on the Wednesday,
9 9 with Mr Bromley-Martin spilling over to that day if
10 10 required.
11 11 MR JUSTICE HILDYARD: I see, okay.
12 12 MR LORD: I would hope to be a day with Mr Bromley-Martin,
13 13 but obviously, if more witnesses come on the Tuesday,
14 14 that’s going to make it less likely that I’m going to be
15 15 able to finish him in a day.
16 16 MR JUSTICE HILDYARD: Then we have an overspill day or two.
17 17 MR LORD: Yes, although we would invite your Lordship to
18 18 consider on Monday allowing us to call some of our
19 19 witnesses next week. If, for example, we spend two and
20 (2.52 pm) 20 a half days on the completion of the other witnesses for
21 (Hearing in open court) 21 the defendants, it would be, in my submission,
22 Housekeeping 22 appropriate to start one of our witnesses next week so
23 MR JUSTICE HILDYARD: Now, Monday, you have indicated 23 that we don’t just have a two and a half day week; we
24 concerns you wish to raise. Mr Stroilov has indicated 24 will try and make some progress and try to use the court
25 concerns he may wish to raise. How will this affect 25 time.
145 147

1 next week’s timetable, in your view?

2 MR LORD: Well, the witnesses who are meant to be coming on

3 Monday are Mr Pasko — it was going to be Ms Meylanov,

4 Mr Pasko and Mr Ameli. I understand that Mr Pasko

5 and Mr Ameli are still proposed to come on Monday.

6 Again, if that has changed for any reason, I would hope

7 that — if the calling of a witness, or the order of

8 the calling of a witness changes, I would hope that

9 I will be given fair notice of that, because I am going

10 to prepare, to a degree, with that sequence in mind.

11 MR JUSTICE HILDYARD: It is only fair in a normal process.

12 MR LORD: Yes, I am sure it will be, but if, for example, if

13 for any reason a witness were not coming now, for any

14 reason, or coming on a different date, then I would

15 welcome being told as soon as possible that that is the

16 case. You saw Mr Stroilov’s —

17 MR JUSTICE HILDYARD: I am trying to remind myself of it.

18 When does he propose to call Ms Meylanov?

19 MR LORD: What he suggested is that Ms Meylanov is called on

20 Tuesday the 1st and on Monday we have Mr Pasko and

21 Mr Ameli and housekeeping.

22 MR JUSTICE HILDYARD: And you are agreeable to that?

23 MR LORD: Yes. I think, my Lord, so your Lordship knows,

24 subject to how long the housekeeping takes, I would hope

25 that I don’t need a full three days. I would hope I can

1 Your Lordship is aware of the cost of this case,

2 which is being entirely borne, as things stand, by the

3 claimant, and therefore every day is expensive. People

4 are hired, interpreters are booked, and there are

5 running costs which go up every day.

6 MR JUSTICE HILDYARD: Every day costs a lot, I quite agree,

7 whether we are sitting fully or not at all; I appreciate

8 that.

9 MR LORD: If we could start to call the next witness and —

10 MR JUSTICE HILDYARD: Have you raised that with Mr Stroilov?

11 MR LORD: I haven’t yet. Mr Sklyarevsky was going to come

12 on Friday the 4th, so he was always meant to start

13 a week today, but if, for example, we were to finish

14 sooner next week, let’s say we finished on Tuesday with

15 a following wind, we would hope that Mr Sklyarevsky, for

16 example, could maybe start on the Thursday, because if

17 he could start on the Thursday and two days proved to be

18 enough with him, then he would be away by the weekend.

19 We would like your Lordship to consider actively how

20 we might start to —

21 MR JUSTICE HILDYARD: Well, I shall consider it actively

22 but, naturally, you need to raise it with Mr Stroilov

23 and I need to know what his position is in that respect.

24 MR LORD: Of course, yes, I understand, my Lord. My Lord

25 will, I am sure, read those two articles I handed in.

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1 I would ask your Lordship to consider those, please.

2 MR JUSTICE HILDYARD: Yes. Some time when you are back in

3 London, you will complete my core bundles with the

4 additional material.

5 MR LORD: RPC have that in hand. The logistical side is

6 being undertaken back in London for obvious reasons.

7 That is in train. The identification of additional

8 material not yet in your Lordship’s abridged D file has

9 already been undertaken, is in train, and we anticipate

10 being able to make some good progress once we are back

11 in London with updating the files themselves.

12 MR JUSTICE HILDYARD: One horrible thought occurs to me, and

13 can I raise it with you whilst Mrs Arkhangelskaya is

14 still with us.

15 In paragraph 46, {C1/2/7} {C1/2/14} she has affirmed

16 the truth of all that’s gone on before in

17 the proceedings and in the BVI. Your cross-examination

18 has been broadly limited to her witness statement in

19 these proceedings; do you know what the position is on

20 that? It’s a late thought.

21 MR LORD: My Lord, I did challenge paragraph 46.

22 MR JUSTICE HILDYARD: Yes.

23 MR LORD: And it is true that there is a cross-reference to

24 other affidavits, just as Dr Arkhangelsky in his

25 supplemental statement did the same thing.

1 sure she has cross-referred to another statement or

2 affidavit. So I don’t understand that by reference,

3 this statement appends, or brings into evidence for

4 the trial, those matters. So I —

5 MR JUSTICE HILDYARD: But they are all in the bundles and

6 there is a bit of a want of clarity on that. But there

7 we are.

8 MR LORD: But, my Lord, they are in other proceedings; they

9 are there, they are in BVI proceedings, so they are

10 there on the record.

11 MR JUSTICE HILDYARD: They are there as a matter of record,

12 but not of evidence.

13 MR LORD: My Lord, they are a matter of record and obviously

14 a source of potential cross-examination, but you would

15 expect, in terms of the adduction of evidence in-chief,

16 that would actually have to be done in the usual way.

17 MR JUSTICE HILDYARD: I agree, but there are peculiarities

18 in this case. I just don’t know what 46 signifies.

19 MR LORD: Well, this statement does not say: I cross-refer

20 and adopt affidavits 1, 2, 3, 4, 6, somewhere else, and

21 therefore you must challenge them all if you want to, it

22 doesn’t say that, and I have proceeded on the basis

23 I have explained to your Lordship, which I think is the

24 fair and proper basis.

25 These statements were prepared when the defendants

149 151

1 MR JUSTICE HILDYARD: Yes.

2 MR LORD: But I have taken that, in fairness, any particular

3 substantive point that is going to be relied upon in

4 the trial —

5 MR JUSTICE HILDYARD: That’s all right then. That’s okay.

6 MR LORD: And if that is not right, I would want to

7 consider, because it can’t be right that I would have to

8 trail around through 10 or 20 or 50 statements to find

9 the relevant material. That can’t be right.

10 MR JUSTICE HILDYARD: With Dr Arkhangelsky, you had

11 obviously identified bits in other, previous,

12 affidavits. With Mrs Arkhangelskaya, for understandable

13 reasons, less so. But she has, with the qualification

14 she has expressed, confirmed the accuracy of what she

15 has previously stated. So I just raise that. If there

16 is a problem, you must let me know.

17 MR LORD: Yes. I am not sure whether there are any more, if

18 you like, really substantive points that would properly

19 and fairly be viewed to be allowed to come in through

20 that route.

21 MR JUSTICE HILDYARD: Well, certainly it would cause

22 a problem, but I just raise it because I suddenly had

23 a concern about it.

24 MR LORD: My Lord, she has confirmed that the claims are

25 true. I don’t think that she has actually — I’m not

1 and counterclaimants had the benefit of legal

2 representation and it wouldn’t be appropriate, in my

3 respectful submission, for material to be brought in by

4 this side wind in that way.

5 MR JUSTICE HILDYARD: Mrs Arkhangelskaya, although you have

6 been released, I just want to explain what we are

7 talking about.

8 In paragraph 46 of your witness statement in these

9 proceedings, you refer to and confirm as true other

10 evidence given in the BVI and previously in these

11 proceedings.

12 MR LORD: My Lord, I am not sure she has given — to be fair

13 to the witness, I don’t think, from memory, that she has

14 given evidence in the BVI. She brought the BVI

15 proceedings.

16 MR JUSTICE HILDYARD: I am sorry.

17 MR LORD: It is my fault, probably, for not assuaging

18 your Lordship’s concern more directly and neatly;

19 I apologise for that.

20 So I don’t think she is in quite the same position,

21 with a corpus of other evidence that she has previously

22 deposed to in the BVI.

23 MR JUSTICE HILDYARD: Yes, but in these proceedings, there

24 is no problem. What she has said in these proceedings

25 you are content is on the record here?

150 152
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1 MR LORD: It must be, yes. 1 what the effort is.
2 MR JUSTICE HILDYARD: Yes, very good. 2 MR LORD: Thank you very much. Thank you, that is
3 MR LORD: It is on the record, but the evidence that is 3 appreciated, my Lord.
4 being relied upon in-chief I take from this statement. 4 MR JUSTICE HILDYARD: Have a good weekend. Have a good
5 MR JUSTICE HILDYARD: It’s there. That’s the anxiety 5 journey, all of you.
6 I have: that ordinarily, when people are legally 6 (3.06 pm)
7 represented, they will identify and not take as read 7 (The court adjourned until 10.30 am on
8 evidence given previously, and I am just a little bit 8 Monday, 29 February 2016)
9 concerned about that. 9
10 MR LORD: My Lord, when they served the witness statements 10
11 in August, they had had Withers on the record for six 11
12 months, and Mr Milner — we have heard Mr Milner seems 12
13 to have been involved in the statement drafting. 13
14 I must say, I do reserve — I don’t accept there 14
15 could be any scope for any basis for relaxation of 15
16 the ordinary rules that would — 16
17 MR JUSTICE HILDYARD: I raise it with you simply out of 17
18 anxiety and concern. 18
19 Mrs Arkhangelskaya, our rules of evidence are quite 19
20 strict. In court proceedings, you can only rely on 20
21 evidence which is put properly before the court. 21
22 Although you have given evidence in these proceedings on 22
23 many times, and Mr Lord has taken you to certain parts 23
24 of that evidence, the evidence on which you rely is, and 24
25 is exclusively, in the witness statement which has been 25

153

1 prepared for you, the truth of which you have confirmed.

2 That is the position under our rules.

3 If Mr Stroilov, in reading this, has any concerns,

4 he will have to raise them, but that is the basis on

5 which I am proceeding.

6 Sorry to trouble you yet further. These are

7 important but nevertheless technical rules.

8 Right, so we meet again at 10.30 am on Monday.

9 I understand a huge logistical task is now required, and

10 I feel a certain, but limited, sense of guilt in skiving

11 off and letting you all attend to that.

12 As you can see, Mrs Arkhangelskaya, it is no easy

13 feat to recreate a court abroad, and I do, once again,

14 thank everyone concerned —

15 MR LORD: Thank you, my Lord.

16 MR JUSTICE HILDYARD: — because, as I was working away

17 yesterday, I was just looking around me at all the

18 screens and all the files and the logistical effort

19 which lies behind them, and which must now be

20 duplicated, and I do thank everyone involved very much

21 indeed.

22 MR LORD: Thank you, my Lord. I will pass that on, because

23 there is a lot of unsung work that goes on, really.

24 MR JUSTICE HILDYARD: Hugely unsung, and I waft in, waft

25 out. Please don’t take it that I don’t understand quite

155

1 INDEX
2 PAGE
3 MRS JULIA ALEKSANDROVNA ARKHANGELSKY …………….. 1
4 (Affirmed) ………………
Cross-examination by MR LORD 3
5 (Hearing in private) …………………………. 103
6 (Hearing in open court) ………………………. 123
7 Questions by MR JUSTICE HILDYARD ………… 128
8 (Hearing in private) …………………………. 144
9 (Hearing in open court) ………………………. 145
10 Housekeeping ………………………………… 145
11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

154 156
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157

February 26, 2016 Day 17 — Redacted

A

A1 (1) 34:11 A1/2/73 (1) 33:16 A1/2/74 (1) 34:3

A10 (2) 56:17 64:16

A11 (5) 56:17 62:6,9 64:8,16

A12 (6) 33:6 39:24,24 40:10 56:12,17

A29 (4) 33:6 56:13,17 69:7

A7 (3) 33:6 56:12,16

A8 (4) 56:16 58:6,12 60:13

A9 (2) 56:16 60:13 ability (3) 38:16 57:13

95:1

able (25) 2:7 8:4,8 21:19 22:11 27:25 28:1 48:25 51:17 78:23 80:4 84:12 85:1,1 88:18,22,25 89:8,11 99:4 138:18 139:1 142:11 147:15 149:10

abridged (1) 149:8 abroad (1) 154:13 absence (1) 14:7 absolutely (7) 13:7

46:1 59:5 68:20 96:10 125:21 140:18

accept (3) 49:17 50:3 153:14

accompanied (1)

27:15 accompanying (1)
98:23

account (4) 10:1,21

75:17 135:12 accountancy (8) 4:4

4:20,25 5:1,22 7:9 9:19 63:25

accountant (6) 27:20 81:11,14 82:7 137:2,4

accountants (2) 5:14 6:2

accounting (27) 4:13 4:18,21 5:6,7,9,13 5:14,24 6:1,6,12,13 6:17 7:7 8:19 9:4 9:16,20,22 10:5,9 10:15 64:6 72:24 79:25 80:1

accounts (19) 6:3 9:7 9:14,24 10:2,19,23 12:14 13:12,23 73:23 76:1 78:5 79:15,19 82:23 83:6 92:15 101:6

accreditation (1) 8:9 accruing (2) 17:24,25 accuracy (2) 82:24

150:14

accurate (2) 30:9 46:1 accused (1) 37:25 acquire (1) 125:6

act (3) 94:3,8,18 acting (2) 89:6 96:11 actions (1) 97:17 actively (3) 76:24

148:19,21 activities (8) 18:20

19:7,13,21 20:9 22:1,3 84:2
actual (7) 4:16 8:5

46:8 73:2 75:25 51:16 60:23 61:1,7 87:25 136:2 139:9 76:15 84:1,3,19 87:2 91:10,10 98:3 bit (9) 4:13 90:14
92:6 98:14 63:6 69:15 73:13 Arbitration (1) 87:13 92:3 95:7,19 98:4 99:18,20 96:25 129:11 132:4
add (3) 2:25 3:2 12:3 74:25 78:12,12,20 Arkhangelskaya (118) asks (1) 57:12 100:2 124:5 127:23 133:22 141:11
additional (6) 3:1 65:6 78:22 79:1,8 86:25 1:5,19,24 3:21 5:25 asserts (1) 53:19 136:6 139:17,23 151:6 153:8
66:7,9 149:4,7 87:6 133:14 134:1 8:17 11:17,23 asset (3) 59:17,17 141:3 149:2,6,10 bits (3) 10:4,14
additions (1) 2:23 134:1 138:17 12:25 14:2,13 15:3 74:6 backfire (1) 131:21 150:11
address (2) 31:9,10 amounts (12) 17:11 16:22 17:5,17 assets (7) 10:23 63:14 background (2) 46:12 bitter (1) 131:14
addresses (1) 90:12 36:9 37:16 63:6 18:23 19:10 21:8 67:7 98:16,17,18 46:23 blank (1) 131:16
adduction (1) 151:15 67:6 68:1,3 73:10 23:8,9,22,24 24:13 132:21 bad (2) 135:4 136:18 bodies (1) 136:19
adjourned (1) 155:7 84:4 132:25 134:2 24:20,23 26:1,10 assist (4) 9:13 70:15 balance (6) 9:25 80:5 body (2) 8:9,14
Adjournment (1) 134:4 29:2,3,6,8,14,24 85:2 140:25 80:7 83:4 84:5 bodyguards (5) 98:22
101:2 analysed (1) 48:2 31:5,16 32:23 assistance (1) 44:11 137:5 98:24 124:11,16
adjust (1) 29:1 and/or (2) 62:1 76:21 33:22,24 34:6,17 assistant (2) 9:10,11 bank (56) 25:3 26:16 139:24
admitted (1) 41:20 angry (1) 144:13 35:16 36:11,21 assistants (5) 8:5 9:11 26:19,20 28:4 bono (1) 96:12
adopt (1) 151:20 annum (1) 17:15 38:15 39:15,25 9:12 10:13,14 34:21,22 35:7,8,18 book (9) 13:15,15,21
adult (1) 131:10 answer (54) 1:14 7:22 41:3 42:5 44:14 assisting (1) 27:12 39:12 42:21 49:8 13:21 17:20,21,23
advisory (1) 9:21 22:1,12 27:23,25 45:5 47:1 48:16 assuaging (1) 152:17 50:8,9 54:1 59:14 18:11 72:24
advocacy (1) 96:12 28:1,15,15 37:14 49:4,24 51:23 52:9 assume (1) 102:18 60:23 61:1 62:12 booked (2) 124:16
advocate (1) 94:8 38:6,10,21,22 39:3 52:19 53:18 55:1 assumed (2) 56:15 63:15 64:19,23,25 148:4
affect (1) 145:25 39:4 41:13 44:7,8,9 55:15 56:11,23 88:25 64:25 67:3,3,15,16 borne (1) 148:2
affidavit (15) 3:6,8,10 44:12 56:10 57:12 57:6,22 58:7 60:4 assuming (1) 55:5 67:16,17,18 69:11 borrowed (1) 85:18
16:21,23 17:16 57:21 62:14 67:24 60:12,18 61:12,20 astronomical (1) 69:16 71:6 78:25 borrower (1) 42:12
18:15 19:1,5 20:10 67:25 68:5 69:19 62:2,8,15,19 63:4,8 132:25 102:3 124:2,19 bottom (5) 12:5 33:22
21:3,16 28:5,8 70:1,1,3,8,15 71:24 65:19 67:5,8 69:10 Asylum (1) 22:15 128:6,13 129:22 33:25 44:1 83:15
151:2 72:14 73:16,16 69:14 70:3,18 71:1 attach (1) 63:11 130:5 131:25 132:9 bought (2) 59:17
affidavits (5) 48:6 74:8 76:7 82:18 73:18 74:10 77:13 attaching (1) 40:24 132:13 135:3,6,7,9 98:12
52:16 149:24 85:1,2 88:18,25 79:3,13,25 81:13 attack (3) 124:10 135:11,12,16,18 boxes (2) 30:23 48:3
150:12 151:20 89:8,11 93:17 94:5 83:9 85:3 86:5 88:3 137:20 138:1 138:14 142:14 brackets (1) 134:10
affiliated (2) 26:17,18 94:17,19 129:7 90:15 91:12 93:25 attacked (1) 124:4 banking (3) 50:5,7 breach (1) 101:21
affirmed (3) 1:21 130:18 139:1 95:20,25 96:10 attacks (3) 99:2 64:6 break (14) 29:3,5
149:15 156:3 answered (5) 47:8,9,9 97:5 99:13,19 136:22 137:12 bankruptcy (1) 77:8 59:24 60:2,5,10
affixed (2) 39:8,11 51:13 72:12 100:22 101:25 attend (4) 71:22 banks (4) 50:9 68:6,7 99:15,18,22,24
afford (1) 96:21 answering (2) 27:19 123:10 128:11,18 90:21 124:5 154:11 139:2 100:1,8,12,18
afraid (11) 12:1 35:9 38:20 128:21 140:20,24 attention (2) 10:24 barrister (2) 94:7 breakdown (4) 80:5,6
35:12 43:4,9 44:8 answers (3) 1:22 63:9 144:2 149:13 142:7 96:11 83:4 84:4
91:17 94:19 95:12 92:19 150:12 152:5 attorney (2) 89:17,18 base (1) 141:15 Breeze (1) 83:17
142:24 143:17 anticipate (2) 99:13 153:19 154:12 audit (18) 4:4 5:22 7:9 based (2) 77:14 131:2 bring (2) 125:18
agencies (2) 124:12 149:9 Arkhangelskaya’s (1) 7:14,15 8:4 9:19,21 basically (2) 17:21 126:21
124:14 anxiety (3) 95:19 33:19 9:23 10:11,17 11:6 65:3 brings (1) 151:3
ago (5) 6:15 53:11 153:5,18 Arkhangelsky (28) 12:11,14,16 13:12 basis (12) 43:19 55:9 broadly (1) 149:18
54:10 66:3 72:9 anybody (1) 144:6 1:10,21 14:5 23:1 15:23 63:25 55:9 73:10 84:15 broke (1) 98:5
agree (12) 15:7 33:7 anyway (3) 60:3 92:4 25:18 34:12,20 audited (1) 11:9 86:13 88:4 128:11 broken (1) 124:14
38:4,9 42:4,8 58:10 95:16 36:1,4 40:9 42:11 auditing (4) 9:10,18 151:22,24 153:15 Bromley-Martin (3)
68:25 102:23 apart (3) 3:1,5 12:4 46:4 62:23 63:3,12 14:4 80:1 154:4 147:5,9,12
123:24 148:6 apartment (3) 85:19 76:20,23 77:2 82:1 auditor (3) 9:12 10:3 bear (2) 2:14 65:15 brought (4) 128:5,7
151:17 131:15 135:8 87:21 91:21 93:9 10:12 beaten (1) 124:13 152:3,14
agreeable (1) 146:22 apologies (4) 38:22 102:16 141:19 auditor’s (4) 7:10 8:10 beginners (1) 10:7 BSP (4) 26:19 39:13
agreed (6) 47:20 45:4 62:25 94:16 143:2 149:24 11:24 12:3 beginning (1) 6:24 48:23 61:8
50:15 51:3 130:9 apologise (4) 28:24 150:10 156:3 auditors (4) 5:15 8:6 begins (1) 2:3 build (1) 68:2
130:11 138:22 44:22 45:24 152:19 Arkhangelsky’s (4) 10:10,13 behalf (19) 32:25 Bulgaria (9) 66:5
agreeing (2) 36:2 apparently (2) 138:11 14:10 24:15 42:11 August (2) 12:12 36:22 44:4 46:6 91:21 125:7,25
49:10 143:4 142:3 153:11 59:8,9,12 66:15,21 126:1,14 127:15,22
agreement (15) 35:25 appear (6) 18:25 arose (2) 31:20 authorisation (2) 52:2 77:21 79:20 88:5 127:25
42:2,20 51:8 68:24 30:10 32:2,14 34:8 136:14 59:3 88:15 89:7,20 90:2 Bulgarian (2) 125:12
88:10 91:8,13,14 142:13 arrangement (1) authorise (2) 89:3,13 94:1,3 96:14 127:9
91:14,15 94:13 appeared (1) 141:25 140:13 authorised (6) 59:4,7 believe (3) 21:14 bundles (3) 45:25
97:2,14 130:6 appearing (3) 41:23 arrive (1) 135:9 89:2 94:3,9 96:14 128:8,17 149:3 151:5
agreements (2) 51:6 42:13 97:1 arrived (2) 28:8 78:24 authorising (1) 73:4 believed (1) 128:6 burden (2) 95:23 96:1
91:9 appears (9) 35:4 42:2 arrondissement (1) authorities (2) 73:22 belle-mère (3) 25:21 bus (1) 100:6
Ah (1) 26:5 44:13 77:14 87:12 140:16 76:10 25:24 26:5 business (32) 2:1 8:8
aid (1) 130:11 87:17 88:4 90:11 article (1) 141:25 authority (3) 95:3,4 belong (1) 74:5 9:17 10:18 18:20
airport (1) 100:6 142:4 articles (1) 148:25 95:20 benefit (3) 98:11 19:7,13,21 20:8,21
ALEKSANDROVNA (2) appendix (2) 33:5,15 ascertain (1) 23:20 automatically (2) 7:17 132:6 152:1 20:22 23:19 59:17
1:21 156:3 appends (1) 151:3 Ashurkov (1) 147:4 8:1 benefits (1) 13:25 68:2,16,23,23
alight (1) 142:11 applied (1) 6:2 aside (1) 86:6 available (3) 21:4 best (18) 12:15 17:3,4 101:20 123:16,18
allege (1) 124:1 applies (1) 125:25 asked (31) 8:12 26:15 61:16 129:18 31:14 33:4 38:15 123:19,19,20
alleged (1) 38:13 applying (1) 4:25 27:4,7 31:10 37:2 aware (14) 59:13,13 39:5 44:24 57:13 130:17 132:1,8
allegedly (2) 52:23 appointment (1) 38:19,24 43:11,22 61:2 68:3 79:13,17 57:18 67:1,21 70:4 136:3,9 137:9,10
86:23 130:8 47:23 51:23 54:13 83:23 91:6,12,15 76:14 82:19 100:24 138:10 139:6
allocated (1) 73:24 appreciate (1) 148:7 54:14 57:2 65:2 91:17 94:2 96:17 130:13 135:15 businesses (4) 13:12
allow (3) 22:22 66:15 appreciated (2) 68:11,12 71:25 148:1 better (6) 9:2 51:24 79:6 127:3 139:3
126:9 100:11 155:3 73:15 84:11 85:3 awful (1) 47:11 65:2 82:19 91:4 busy (1) 66:22
allowed (3) 64:24 apprise (1) 141:19 91:5 92:14,19 93:3 128:15 buy (2) 86:1 90:6
70:22 150:19 apprised (1) 68:8 94:20 102:7 135:13 B beyond (3) 12:18 buying (2) 126:13,15
allowing (1) 147:18 appropriate (3) 30:16 135:25 140:6 back (28) 12:23 37:22 97:18 141:15 BVI (7) 128:5 149:17
Ameli (4) 146:4,5,21 147:22 152:2 asking (20) 15:22 19:3 big (4) 22:19 51:16 151:9 152:10,14,14
46:11 60:6 61:6
147:2 approximately (3) 19:14 39:24 42:7 90:2 143:14 152:22
65:14,20 70:6
amount (25) 30:6 17:15 51:15 78:8 52:19,20 55:2 56:8 billion (1) 90:3
72:12 76:17 78:6
35:16,17 36:6 51:4 April (5) 60:24 81:15 63:16 67:9,14 72:2 bills (1) 138:16

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C

C1/1/8 (1) 14:9 C1/2/1 (2) 2:2,4 C1/2/10 (7) 11:1

12:24 29:16,19 33:3 54:25 64:11

C1/2/11 (3) 85:7 125:4 126:18

C1/2/12 (3) 123:12

127:13 135:25

C1/2/13 (2) 86:3 97:7 C1/2/14 (3) 2:9 128:3

149:15

C1/2/2 (7) 3:23 11:1 12:24 29:17 33:2 54:25 64:12

C1/2/3 (1) 125:3 C1/2/4 (4) 85:6

123:12 126:14 135:24

C1/2/5 (2) 97:6 127:13

C1/2/6 (1) 86:4 C1/2/7 (2) 128:3

149:15

C1/2/9 (3) 2:2,6 3:23 cake (1) 66:6

call (5) 4:19 123:18 146:18 147:18 148:9

called (8) 7:5 11:3 74:9,23 79:15 80:3 87:23 146:19

calling (2) 146:7,8 calmly (1) 137:25 capital (2) 10:6 16:19 car-jacked (1) 140:4 careful (5) 2:18 68:21

131:18,20,20 carefully (5) 2:16 31:4

53:22 55:7 57:11 carried (3) 21:17 22:8

81:25

carry (6) 8:4,8 9:16 22:2 23:9 123:19

carrying (2) 21:17 75:9

cars (4) 138:6 140:2,3 140:4

case (37) 8:24 11:8 12:13 25:9 32:7 36:7 40:19 53:19 53:19 57:7 59:1 64:20 65:24 74:21 79:14 85:17 89:16 100:23 101:25 124:11,20 127:7 128:8,15 129:1 130:10 131:4,7 137:1 139:14 142:4 142:9,20 144:15 146:16 148:1 151:18

cash (1) 35:14 cast (1) 83:24 category (1) 53:23 cause (6) 52:21 54:5

101:21 130:12 138:4 150:21

caused (1) 30:5 cease (2) 22:2 72:7 ceased (1) 72:20 cent (9) 10:22 14:18

14:18 15:21,22 16:14 17:7 26:13 138:6

Centre (6) 79:12,16 83:9,21,23 84:8

certain (13) 8:12 30:5 147:13 148:11 confidence (2) 45:19 control (2) 77:4 81:24
31:19 56:11 70:10 150:19 101:21 controller (4) 17:14
71:17,18,25 79:14 comes (2) 35:21 62:12 confidential (5) 17:19 18:5 72:3
93:8 101:5 153:23 coming (10) 2:17 101:12 102:6 convinced (2) 128:16
154:10 28:11 35:19 140:25 143:25 144:5,6 130:4
certainly (5) 29:19 141:6 146:2,13,14 confidentiality (1) cool (1) 84:3
50:6 59:11 80:18 147:5,8 143:20 copied (1) 31:25
150:21 command (1) 128:23 confirm (21) 21:10 copies (6) 30:7 31:18
certainty (1) 39:7 commencement (1) 26:21 27:21 35:4 32:1,2 78:5 141:23
certificate (5) 11:24 17:9 38:1 46:16,19,22 copy (8) 31:21,22
134:10,12,15 135:1 comment (4) 43:3 50:11,14 53:2 55:5 38:17 40:11,24
cetera (1) 139:5 49:1 51:17 90:16 56:9 61:14 74:11 41:21,23 95:22
challenge (2) 149:21 comments (2) 40:25 74:12 76:20 80:1,4 core (1) 149:3
151:21 46:4 132:3 152:9 corner (1) 38:8
chance (1) 43:3 commit (2) 50:19,20 confirmation (1) corpus (1) 152:21
change (1) 77:8 communicated (1) 77:15 correct (13) 4:5 11:24
changed (1) 146:6 21:13 confirmed (8) 7:23,25 16:4 25:8 31:14
changes (1) 146:8 communication (1) 46:20 55:3 127:8 56:6,10,18,22
charge (6) 8:14 9:16 76:5 150:14,24 154:1 78:12 125:1,16
10:4,5,8,14 companies (28) 12:20 confirming (1) 96:16 127:18
check (4) 28:9 30:25 15:1,8,14,17 23:6 connection (1) 141:11 correctly (4) 15:16
95:22,24 23:24 24:4,9 25:2 consent (23) 32:14 22:6 48:12 85:20
checked (3) 55:6 83:1 26:8 28:23 59:15 34:5,12,19 35:5,15 correspondence (2)
134:24 64:24 76:24 77:4,6 35:25 36:4,6 39:25 73:14,21
checking (3) 9:24 22:7 79:4 80:21 81:22 42:10,23 49:5,9 cost (1) 148:1
95:21 84:9 85:18 132:14 50:11,14 64:2 69:9 costs (2) 148:5,6
cheque (1) 72:11 132:21 136:10,23 130:9,10 131:24 counterclaim (2) 33:6
chief (7) 10:3,12 136:23 138:24 133:7,8 33:15
81:11,14 82:7 company (44) 6:20,21 consenting (1) 49:11 counterclaimants (1)
137:2,4 6:24 8:3,7,13 9:6 consents (9) 29:9 30:5 152:1
child (1) 13:24 9:10,18 10:18,19 31:7 34:9 48:15 country (1) 126:2
childcare (1) 13:4 11:3,11 12:21 14:4 57:1 62:21 63:20 counts (1) 7:20
children (8) 13:20 14:4,6 16:3,15,16 67:9 couple (1) 13:24
71:22 97:16,23 18:1 26:14,24 consequently (1) course (27) 2:21 5:23
98:20,23 125:14 27:20 35:18 49:7 38:12 6:4 7:3 9:2 24:2
140:9 72:19,20 74:9 78:8 consider (8) 22:22 27:10 30:22 33:20
circumstances (6) 79:15,21 80:3,19 33:10 41:6 147:18 33:20 47:13 48:1
51:19 77:11 99:4 80:22 81:15,25 148:19,21 149:1 48:12 51:7 58:1
139:12 141:2 144:9 82:9,12,21 91:5 150:7 66:24 68:25 69:3
City (6) 79:12,16 83:9 93:21 124:15 considerable (2) 75:25 82:5 97:3
83:21,23 84:8 138:23 88:11,19 128:15 132:5
claim (8) 87:17 88:6 comparators (1) 40:12 Considérant (1) 25:15 136:16 138:1,10
89:1,2,15,15 91:1,3 compared (1) 79:1 considered (6) 40:10 148:24
claimant (1) 148:3 complaints (4) 88:5 53:23 55:17,22,23 court (37) 22:15,22
claimants (2) 46:2,9 88:15 90:1 124:18 71:13 23:12,13 24:12
claims (5) 86:6 88:8 complete (2) 137:3 Considering (1) 22:20 37:23,23 44:2,11
128:7,12 150:24 149:3 conspiracy (1) 124:2 54:15 70:15 75:5
clarification (1) 37:11 completed (3) 41:17 Constantly (1) 48:1 85:2 87:8,13 89:14
clarify (4) 15:10 24:10 42:13 147:1 constitute (1) 51:8 89:17,19,21 90:17
97:14 128:25 completely (6) 68:20 consultancy (2) 9:20 90:22 94:18 96:19
clarity (1) 151:6 78:15 128:16 88:21 96:23 123:9 139:9
classical (1) 59:16 130:11 131:13 consulting (2) 6:21 139:14 141:6 142:5
clear (8) 24:23 35:11 134:4 11:6 145:21 147:24
95:7 96:1 131:22 completion (1) 147:20 contact (8) 28:13,14 153:20,21 154:13
132:2 133:5 136:8 complex (1) 129:14 28:19 73:7 75:24 155:7 156:6,9
clearly (1) 41:12 complexities (1) 76:3,7,12 cover (2) 67:7,18
clients (2) 77:9 143:15 129:20 contacted (1) 124:12 crazy (1) 132:25
clients’ (1) 102:15 complicated (4) 30:13 contained (1) 22:20 create (1) 28:3
climate (1) 126:7 129:11,13,14 contemplating (1) created (1) 23:5
close (1) 75:16 concealed (1) 88:17 125:18 creation (1) 23:2
closed (1) 135:20 conceals (1) 88:9 content (1) 152:25 credibility (1) 20:16
closer (1) 129:13 concept (2) 13:17 contentious (2) 88:9 creditors (1) 97:19
closing (1) 101:17 18:7 88:10 crisis (3) 137:11,23
collapse (1) 136:6 concern (8) 63:9,13 contents (3) 2:19,20 138:1
collating (1) 9:13 63:14 96:4 102:15 21:10 criticising (2) 23:25
collation (1) 3:13 150:23 152:18 context (4) 32:10 33:1 65:18
colleague (3) 23:14 153:18 51:20 97:24 criticism (3) 24:1 26:9
54:11 58:23 concerned (11) 10:3 continue (5) 72:13 59:23
colleagues (1) 53:13 21:11 57:14 63:23 102:20 124:22,23 cross-examination (9)
collect (1) 142:21 94:25 95:15 143:16 126:4 3:20 53:11 54:10
college (3) 4:8 5:18 144:8,14 153:9 continued (4) 13:2 54:19 58:23 75:18
6:20 154:14 77:6 99:2 141:18 149:17 151:14
come (20) 33:23 concerning (1) 87:17 contract (7) 39:25 156:4
37:22 41:16 56:13 concerns (10) 63:13 72:22 97:9 98:1,10 cross-examined (5)
60:6 71:10 73:5,10 101:25 123:25 98:15 99:6 2:24 23:15 31:17
85:24 86:20 99:18 129:25 136:12,14 contracts (2) 34:8 141:1 143:4
100:2 127:23 136:16 145:24,25 65:22 cross-refer (1) 151:19
132:12 135:16 154:3 contrary (2) 20:11 cross-reference (1)
139:23 146:5 conduct (1) 94:1 83:25 149:23

cross-referred (1)

151:1

crucial (1) 144:11 cryptic (1) 142:17 currently (6) 39:24 74:4,25 75:23 78:18 142:12

cut (1) 59:25

D

D (1) 149:8

D116/1726.3/0.1 (2)

79:22,23

D116/1726.3/0.2 (1)

80:11

D116/1726.3/0.3 (1)

83:4

D116/1726.3/0.4 (1)

81:4

D116/1726.3/0.5 (1)

81:5

D116/1726.3/0.6 (1)

81:6

D116/1726.3/0.7 (2)

81:6,8

D116/1726.3/1 (2)

79:22,23

D116/1726.3/2 (2)

80:12,24

D116/1726.3/3 (1)

83:14

D116/1726.3/4 (1)

81:4

D116/1726.3/5 (1)

81:5

D116/1726.3/6 (1)

81:5

D116/1726.3/7 (3)

81:6,7,18

D122/1954/1 (1)

87:11

D122/1954/2 (1) 88:6

D122/1954/5 (1)

87:11

D122/1954/6 (2) 88:7 90:8

D122/1954/7 (1) 90:9 D13/305/1 (2) 34:15

134:6

D32/520/3 (1) 12:10 D32/520/61 (2) 11:16

11:20

D38/654/1 (1) 49:3 D40/691/1 (1) 52:8 D42/737/1 (1) 60:16 D49/855/1 (1) 62:7 D55/957/1 (1) 61:18 D98/1265/1 (1) 69:8 daily (3) 21:21 22:5

84:15 damage (1) 88:11

dangerous (4) 123:16 123:18,20 132:21

dangers (2) 101:10 143:3

dare (2) 1:7 133:4 dark (1) 139:8 data (1) 134:20 date (13) 12:7 17:18

22:9 38:25 39:2 42:4,12 65:15,21 66:2 91:18 92:6 146:14

dated (5) 42:2,12 65:21,23 71:4

dates (2) 41:22 64:18 datur (1) 61:15

day (13) 13:15,22

31:3 92:8 98:22 147:9,12,15,16,23 148:3,5,6

Day9/38:1 (1) 92:13 Day9/39:1 (1) 93:2 Day9/39:3 (1) 93:13 Day9/39:6 (1) 93:18 Day9/74:1 (1) 93:23 Day9/75:1 (1) 93:24 Day9/76:1 (1) 93:24 Day9/77:1 (1) 93:24 Day9/81:12 (1) 95:12 days (6) 126:25 137:2 146:25 147:1,20

148:17

deal (4) 19:20 71:21 93:20 141:16

dealing (2) 43:5 88:20 deceiving (2) 37:23,25 December (1) 94:12 decide (1) 57:7 decided (2) 101:9

125:6 decision (4) 22:14

23:12,13 127:4 declaration (2) 18:10

42:10 deeply (1) 84:14

defence (4) 33:5,15 34:9 137:16 defend (1) 123:23 defendant (2) 36:23

41:19 defendants (7) 44:6

45:6 46:3,10 94:2 147:21 151:25

deferred (2) 1:8,15 definite (1) 81:16 definitely (18) 3:4

8:24 9:4 10:24 14:8 16:5 26:21 27:16 27:21 35:13 73:9 73:21 81:16 82:6 87:5,7 139:19 140:1

degree (9) 4:7,15 5:22 7:23,24 8:18 19:25 23:20 146:10

degrees (1) 8:15 deny (3) 26:25 27:5

129:7 department (10) 6:25

8:11 72:24 73:23 76:1 88:19 89:9 134:19,19 140:18

depends (1) 32:20 depicts (1) 129:20 deposed (1) 152:22 depth (1) 84:3 derived (1) 86:20 describe (7) 8:23

60:19 97:10 123:25 125:5 126:11,15

described (3) 42:10 81:10 82:10

describing (2) 55:7,18 Design (1) 6:21 desperate (1) 77:11 detail (5) 128:25

138:18 139:4,10 140:7

details (7) 43:7 68:7,8 134:13,15,17,24

detain (1) 128:22 developed (1) 59:18 developing (1) 138:9 difference (5) 63:22

64:2,5 90:12 100:15

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

159

February 26, 2016 Day 17 — Redacted

different (28) 7:6 16:10 25:4 26:17 27:7,9 30:10,18 36:16,19 40:22 41:10,11,12 55:14 67:8 68:17 78:15 81:9 94:6 95:2 129:17,23,23 132:10 134:4 144:9 146:14

differently (1) 57:5 difficult (12) 7:20

35:11 44:8,12 55:4 57:8 70:8 75:4 90:19 94:5 139:12 143:18

difficulties (1) 57:15 diploma (3) 7:10 8:3

8:10 diplomas (1) 8:15 dire (1) 75:5 direct (2) 101:23

143:6

directly (1) 152:18 director (33) 9:3

11:12 23:4 25:2 26:24 27:6 73:6,14 73:15 75:3,22,23 80:19,21,22 81:11 81:12,14,23 82:2,4 82:4,5,11,20,23 91:5 129:5,16,18 129:22,24 130:11

director’s (1) 74:3

Director-General (1)

12:7

disagree (2) 40:17 42:8

disappointed (1)

144:12 discharge (1) 77:6 disclose (1) 17:13 disclosed (2) 31:1

101:6 discrepancy (1) 90:2 discuss (2) 21:22

43:19

discussed (3) 15:6

30:17 31:3

discussing (3) 19:22

21:12 32:11 discussion (2) 21:23

22:5

discussions (2) 21:12 22:5

disinclined (1) 77:10 disliked (1) 136:22 dismal (1) 132:6 dispute (2) 41:2 56:15 disputed (1) 86:14 disquiet (1) 137:8 disturbing (1) 47:6 dividends (2) 85:24

86:2

division (1) 68:15 doctors’ (1) 102:6 document (144) 2:3

2:10,11,12,15,19 3:11,15 12:2 14:12 30:10,25 32:7 34:7 34:16,24 35:4,10 35:12,24 36:3 37:15,18,20 38:2,2 38:11,12 39:5,8,11 39:13,16,18,18,24 40:2,4,13,21,21 41:19,24 42:1,10 42:13,17 43:10,13 43:13,20,23 45:18

45:22 46:17,19 47:2,19 48:9,19,21 49:2,5,12,13,15,18 50:13 51:3,25 52:3 52:4,5,10,11,12,14 52:16,21 53:3,15 53:20 54:5,8,16,18 55:12 58:5,15,19 58:21 59:4,8 60:13 60:22,25 61:4,6,21 61:23,23,24,25 62:1,9,10 63:16,17 64:16,16 65:17,21 66:17 69:13,20,24 70:11,12,19,22 72:6 73:22,24 76:9 86:23 87:4,8,10 90:22 92:5 96:15 96:18 130:14,21 131:4,8,9,12 133:6 134:7,16 135:16,17 141:24

documentation (1)

10:15

documents (103) 1:10 1:11 3:9 22:20 30:7 30:14,19 31:2,5,11 31:17,18,21,22,24 32:4,5,14,15,20,24 33:5,9,11 37:12 40:18 41:1,6,8,9 44:21,22 45:24 46:20 47:22 48:2,3 51:17,18,20 53:2,8 53:13,14,23,24 54:2,12,12 55:7,18 55:24 56:2,3,12,13 56:20 57:24 58:1,6 58:8,10,24 59:9,10 59:11 60:19 61:3 62:24 63:19 64:20 64:24 65:4,7,8,14 65:15,25 66:1,4,15 66:18 67:11 69:19 69:25 71:15 76:8 87:1 89:14 102:2 127:10,11 128:23 130:18,19 131:2,17 131:17 132:6,23 133:25 134:17,18

doing (10) 5:17 9:23 22:8 48:4 55:10 57:18 63:25 70:3 71:20 138:8

double-barreled (1)

24:19

doubt (2) 12:18 95:1 Dr (21) 1:10 14:5,10 23:1 24:15 34:12 34:20 36:1,4 46:4 62:23 63:12 82:1 91:21 93:9 102:16

141:19 142:3 143:2 149:24 150:10

draft (2) 99:6 129:2 drafted (5) 98:2,3,11

98:16 99:10 drafting (1) 153:13 draw (3) 6:3 73:23

142:7

drawing (7) 9:6 18:7 52:16 53:15 54:9 54:17 137:5

drawn (7) 1:10 48:23 52:17 53:4,6 55:13 58:22

draws (1) 20:4 dropped (3) 78:13,20

78:21

duplicated (1) 154:20

E

E (5) 41:17,18 42:16 46:5,9
e-mail (2) 1:6 40:24 E1/6/1 (1) 36:24 E1/6/10 (1) 40:6 E1/6/5 (1) 39:23 earlier (4) 65:15,21

91:19 142:5

earlier-dated (1)

65:17

early (2) 73:20 123:17 earth (1) 37:18 easier (1) 25:7

easily (1) 56:4

easy (3) 37:15 134:21 154:12

economic (6) 4:8 63:5 133:11,12 137:21 138:1

economical (1) 23:2 Economics (2) 4:13

5:23

effect (11) 47:22 50:12 67:20 79:18 94:10 101:24 102:10 131:12 133:6,13,20

effective (1) 81:24 effort (3) 42:18

154:18 155:1 either (17) 7:9 13:3

31:25 36:16 38:1 41:17 51:25 61:12 61:15 62:3,15 70:18 71:10 82:2 128:1 134:14 135:12

elaborate (1) 55:23 electronic (1) 76:5 embarrassment (1)

101:21 employed (9) 11:11

12:20 13:2 17:13 17:18,25 18:9 135:15 139:21

employee (3) 13:8 73:2 137:6

employees (4) 21:13 77:7 98:25 135:19

employment (5)

13:15,21 17:22 72:22 134:18

enable (2) 100:3 131:24

endeavour (1) 78:4 enforcement (2)

124:12,14

English (41) 3:24 5:17 11:2 12:9,24 14:12 21:6 25:12 29:16 33:25 41:4 43:6,20 44:2,23 45:9,17 48:4,7 49:4 55:1 60:15 69:8 71:11 71:15,20 79:24 81:8 85:7 86:4 96:19,23 97:6 123:12 125:4 128:4 131:2 134:6,9,11 135:24

enormous (1) 51:4 enquiring (1) 100:7 enquiry (1) 30:6 ensure (1) 23:6 enter (2) 68:22,23

entered (2) 91:9 exist (1) 41:20 familiar (20) 2:19 38:3
97:10 existed (1) 41:24 38:11 39:5,17
entering (1) 36:5 exists (1) 134:18 40:20 43:4 48:21
enterprise (1) 18:8 expect (4) 45:20 48:22 49:1,15 52:5
entirely (2) 144:6 46:14 99:3 151:15 52:12 58:21 65:25
148:2 expected (4) 31:19,23 66:3 69:20 70:11
entities (1) 26:18 37:18 39:3 70:12 90:14
entitled (2) 20:20 expenditure (1) 140:7 familiarise (1) 87:16
85:14 expensive (2) 140:4 familiarised (1) 61:25
entity (2) 79:15 84:9 148:3 familiarity (1) 20:21
entries (8) 31:19 32:3 experience (12) 6:7 family (7) 66:22
43:2 79:14 81:2,9 7:12,16,18,21 8:6 124:10 125:12,18
83:15 102:4 8:18,25 9:6 80:1 126:21 132:7
entry (2) 42:9 83:11 131:14 136:7 133:12
environment (1) expert (4) 8:24 36:20 far (17) 10:2 20:1
123:16 37:5 69:23 21:10,24 25:1,3
equally (1) 144:8 expertise (1) 6:8 26:14,16 47:15
Equipment (7) 71:7 expired (1) 8:1 48:22 57:8 63:23
74:9,13,15,20 explain (15) 31:13 75:22,24 76:13
76:22 78:9 35:3 44:24 45:16 94:24 130:21
Erokhin (5) 87:24,24 45:21 50:25 51:5 fault (2) 60:16 152:17
89:5,6,16 72:18 74:19 77:18 favour (2) 34:20 35:6
Erokhina (2) 87:22,23 78:3,4 101:24 feat (1) 154:13
error (2) 81:16 82:7 129:11 152:6 feature (2) 143:15,25
especially (3) 84:2 explained (9) 47:22 February (3) 1:1 142:2
143:4,6 62:20 71:17 78:2 155:8
essence (1) 88:20 133:4,5 137:11,17 Federation (1) 98:8
establish (4) 22:7 24:1 151:23 feel (5) 37:12 59:24
24:3 28:12 explaining (2) 48:5 70:13 100:7 154:10
et (1) 139:5 129:4 feeling (1) 3:7
EU (2) 125:13,19 explains (2) 45:16 feels (1) 30:16
Europe (2) 125:14,19 71:16 fees (1) 102:6
European (2) 125:23 explanation (8) 32:8 felt (4) 48:9 51:2
126:2 32:19 65:16,19 129:21 133:9
euros (2) 58:2 78:25 66:11,13 77:19 field (2) 8:19 64:7
event (2) 1:15 99:23 84:17 fifty (1) 23:6
events (2) 143:10,11 explanations (1) figures (1) 90:13
everyone’s (1) 60:6 65:12 file (3) 2:2 22:21
evidence (53) 3:1,4,16 explore (1) 20:21 149:8
5:21 11:2 31:9 expose (2) 50:13 filed (3) 17:17 19:1
32:12 40:8,14 132:7 89:14
52:13 53:18 54:4 exposing (2) 51:6,8 files (3) 92:5 149:11
54:20 55:2,16 exposure (1) 50:22 154:18
56:23 58:17 63:18 express (2) 95:4 filled (1) 46:10
63:21 64:15 66:25 129:25 film (1) 9:3
67:1 69:23 72:18 expressed (1) 150:14 final (1) 37:8
77:17 86:5 93:10 expression (1) 5:17 Finance (2) 4:14 5:23
97:8 102:10 126:13 extended (3) 68:1 financial (10) 17:14,19
133:3,13,20,22 125:13 138:14 18:5 63:10 72:3
135:14 136:5 extensive (1) 31:10 75:4 80:2 137:21
138:21 139:25 extremely (4) 2:18 137:23 138:15
141:1 144:8 151:3 77:11 84:5 124:20 find (5) 25:8 75:14
151:12,15 152:10 95:9 134:21 150:8
152:14,21 153:3,8 F fine (1) 29:7
153:19,21,22,24,24 fabricated (1) 54:1 finish (5) 96:5 100:2
exact (2) 22:11 136:23 100:16 147:15
Facebook (1) 142:3
exactly (8) 1:17 12:2 148:13
facilitate (1) 142:10
15:5 23:15 42:7 finished (4) 13:13
fact (7) 22:22 32:3
68:18 72:2 142:17 96:7,7 148:14
42:25 52:17 77:5
exam (2) 7:19,21 finishing (1) 141:14
88:9 127:9
examined (2) 32:16 Finland (2) 138:6,7
factors (1) 90:11
40:3 firm (3) 9:19,19 89:6
facts (1) 96:17
examiner (2) 40:18 first (16) 1:4 3:10 5:1
fair (23) 8:17 33:13
69:24 19:20 21:3 22:19
37:9 39:22 50:23
example (9) 6:13 28:6 25:13 34:13 35:4
57:9 60:20 63:12
66:12,23 138:5 42:3 48:16 83:6
68:10 82:8 97:10
146:12 147:19 87:20 124:4 131:14
101:18,20 123:17
148:13,16 137:19
125:17 139:8
exams (2) 7:15,16 fish (1) 30:20
142:17,18,18 146:9
excellent (1) 141:8 fit (1) 53:23
146:11 151:24
exception (5) 18:21 five (5) 4:10,17 8:21
152:12
19:8 96:19,23 8:22 126:1
fairer (1) 57:10
140:12 flat (9) 85:8,13 86:1
fairly (5) 47:16 51:19
exchange (1) 73:14 98:12,13,14 99:5,7
92:23 102:17
exclusively (1) 153:25 99:7
150:19
executive (3) 82:3,5 flats (2) 125:6 126:13
fairness (5) 37:6 39:19
82:20 flight (1) 100:4
39:20 143:16 150:2
exercise (2) 31:8 focus (3) 57:11,12,20
false (1) 55:9
73:12 focused (1) 31:4

followed (1) 92:21 following (2) 125:22
148:15

Fontanka (1) 142:1 foot (1) 83:8 forest (1) 98:6 forge (1) 37:15 forged (1) 54:1 forgery (3) 53:20

56:15 66:24 forget (2) 4:15 136:8 forgot (1) 52:25 forgotten (1) 27:19 fork (1) 35:22

form (1) 43:23 forma (1) 13:10 formally (2) 13:2,8 found (2) 124:17

126:22 foundation (1) 5:19 founded (1) 14:16 four (4) 3:3 8:21,22

125:25

framework (3) 44:2

45:14 131:7

France (10) 27:24 73:23 75:5 126:16 140:11,12,14,17,18 141:6

free (3) 37:12 70:13 141:10

freed (1) 100:24 French (9) 22:14,15

23:13 24:17,21 25:5,7,11 127:10

Friday (2) 1:1 148:12 friend (2) 94:7 96:22 front (7) 1:25 2:6

36:13 40:4 48:11 64:13 80:7

full (4) 46:12 133:24 134:12 146:25

fully (2) 143:13 148:7 functions (1) 18:1 funds (12) 49:21,23

74:13 75:7,7 76:21 84:9 85:12,17,19 85:22,24

further (4) 4:9 30:14 142:22 154:6

future (2) 97:16,23

G

G1/21/2 (1) 16:21 G1/21/3 (1) 18:15 gain (1) 7:8

gained (2) 7:11 8:18 gaining (1) 8:25 general (12) 3:12 4:8

15:10 21:23 23:4 80:19 81:11,12,14 82:2,11 96:8

Générale (2) 78:5

102:3

generally (3) 68:12,24 68:25

generate (1) 46:19 generated (3) 39:13

41:12 61:8 generating (1) 61:4 genuine (1) 93:21 Germany (1) 140:8 getting (3) 35:2 72:11

74:19

gift (2) 88:10,17 gist (2) 60:25 62:25 give (16) 3:1 28:6

35:14 36:1 48:24

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

160

February 26, 2016 Day 17 — Redacted

67:17 68:5 85:1 86:5 97:8 126:13 133:6,8 140:19,25 143:20

given (37) 3:5 7:10 11:2 12:11 29:10 29:11 32:9 33:7 34:20 35:5,6 39:1 40:13 41:21 49:7,9 49:25 53:18 56:14 56:24 62:22 64:15 66:25 67:2,10 70:2 77:16 89:17 92:16 126:21 143:1 146:9 152:10,12,14 153:8 153:22

gives (1) 77:18 giving (12) 43:3 49:6

49:10,12 50:10,12 50:13 54:19 55:16 58:17 62:21,22

go (37) 2:9,14 11:20 12:23 20:13 21:5 22:16 32:13 41:25 68:24 71:8 80:8,8 80:23 81:1,2 83:3 83:16 85:5 86:3 87:8,11 88:6 89:17 89:19 92:13 97:5 100:6 123:10 126:20 127:5 128:2 129:2 136:17 140:15 141:10 148:5

goal (1) 126:3

goes (4) 22:24 29:20 93:12 154:23

going (35) 18:15,16 28:20 30:4 31:13 32:21,23 34:11 37:2 41:6 45:21 47:10 51:18,20 59:22 60:4 65:22 71:1 73:17 78:6 79:12 93:25 99:15 101:4 125:18 127:15,19 132:4 142:15 146:3,9 147:14,14 148:11 150:3

GOM’ (1) 14:17 good (17) 1:3,18 3:18

8:18 18:12 21:1 44:20 60:3 126:5,7 132:9,20 141:3 149:10 153:2 155:4 155:4

goodbye (1) 141:12 graduate (1) 4:3 graduated (1) 5:3 graduating (1) 6:9 graduation (3) 8:21

9:1,9

grandchildren (1)

27:12

great (3) 25:7 54:11 143:3

greatly (1) 100:11 grounds (1) 128:17 group (16) 10:11,11 14:17 15:1,8,14 16:3 17:7 18:20 19:7 23:23 25:1

26:22 88:11 89:23 90:23

group’s (2) 86:22 89:22

groups (1) 89:23 guarantee (34) 34:12

34:20 35:6 36:1,5,6 40:1 42:11,22,22 48:24 49:6,9,10,12 49:21,22 50:11,12 61:8 62:11,19 63:1 63:2,4,7 64:2,3 65:22 67:2,15,17 67:22 132:20

guaranteed (2) 133:11 133:12

guarantees (15) 29:11 33:7 42:24 52:23 52:24 56:5,6,7,10 62:13,21,22 63:20 67:10 132:24

guards (3) 124:9,23 139:13

guilt (2) 137:6 154:10

H

H1/6/3 (1) 21:4

H1/6/5 (1) 21:6

H1/6/7 (1) 21:2

H1/6/9 (1) 21:5 half (7) 23:17 33:22

100:10,12,18

147:20,23 halfway (2) 34:5 90:9 halve (1) 100:15 halved (3) 78:21,22

79:1

hand (4) 30:8 134:4 141:23 149:5

handed (4) 32:25 91:24 141:24 148:25

hands (5) 54:23 99:17 99:21 100:4 101:7 hands-on (7) 6:6 7:11 7:16,18,21 8:6,25 handwriting (1) 36:20

happen (6) 98:7,21 124:21 131:5 132:23 141:16 happened (6) 9:9

39:14 75:17 82:8 99:11 135:19

happening (2) 91:6

99:11 happier (1) 132:8

happy (4) 6:8 38:22 71:24 143:22

hard (2) 37:13 38:1 harm (1) 132:14 hashtags (3) 142:6,8,9 head (2) 56:4 80:4 headed (1) 10:12 heading (2) 34:4 86:6 heard (1) 153:12 hearing (19) 3:16

22:21 28:5 54:19 75:15 91:18 92:3,6 102:8,9 103:1 123:9 139:16 144:17 145:21 156:5,6,8,9

hearings (1) 44:21 held (2) 16:13,15 help (4) 33:20 57:7,17

91:1

hesitate (1) 46:22 highly (2) 8:23 40:10 hijacked (1) 140:4 HILDYARD (147) 1:3

1:14,18,24 2:7,12 2:16,20,22 3:14,18 16:24 17:3 20:13 20:16,19,23 21:1

28:25 29:5 30:20 30:22 31:13 33:17 33:21 36:25 37:4,9 38:21,24 43:11,16 47:4,13,18 48:8,13 49:24 50:5,7,25 51:12,22 57:6,20 59:21 60:4,15 84:18,21 91:18 92:2,4,17,24 93:7 93:11 94:21,24 95:6,9,13,18,23 96:3,5,9,24 97:4 99:22 100:7,12,15 100:21 101:9,15,18 101:23 126:17 128:20,21 129:25 130:4,13,21,25 131:8,22 132:4,18 133:2,20 134:5,8 134:22 135:4,13,22 137:18 138:12,21 139:6,11,17,21 140:6,15,19,24 141:10,14 142:25 143:9,13,19 144:2 145:23 146:11,17 146:22 147:2,7,11 147:16 148:6,10,21 149:2,12,22 150:1 150:5,10,21 151:5 151:11,17 152:5,16 152:23 153:2,5,17 154:16,24 155:4 156:7

hindsight (1) 132:6 hired (2) 124:9 148:4 holder (1) 8:2 holding (1) 23:5 holds (1) 16:19 holiday (8) 125:6

126:3,13,15 127:1 127:15,16,20

holidays (4) 126:6,7,8 140:8

home (4) 48:4 100:3 126:15 135:16 honest (7) 8:11,13 43:6,17 45:23 130:3 136:20 honestly (1) 15:24

hop (1) 100:5

hope (11) 30:9 49:24 100:16 141:3 143:2 146:6,8,24,25 147:12 148:15

hoped (1) 59:22 horrible (1) 149:12 hour (5) 23:17 99:18

100:10,13,18

house (3) 98:24

135:20,20

housekeeping (5)

145:22 146:21,24 147:3 156:10

HR (1) 8:11

huge (5) 37:16 60:23 63:5 67:6 154:9

Hugely (1) 154:24 human (1) 134:19 husband (118) 11:12

12:19,21 17:6 18:2 18:8 19:24 20:3 21:13,21 23:18,18 26:1,15,20 27:2,5 29:11 31:16,19,23 31:25 32:5,15 35:6 40:25 43:5 44:3,18 44:24 45:7,16

47:20,21 49:6,9,11 49:11 51:8 52:25 53:25 54:15 57:2 57:19 59:7,10,16 63:11 64:24 65:2 66:13 67:2,10,13 67:15 68:14,22 69:11 71:10,15 73:19 74:12,22 75:3 77:15 78:7 79:5,5 81:25 82:2 82:16,19 84:10,13 84:25 91:1 96:13 96:19 98:4,8,21,23 100:23 102:2,7 123:15 124:9,22 126:4,10,12,22,24 127:19 128:12 129:9 130:1,15 131:3,23 132:11,16 133:7,11,18,19 136:3,5,12,16 137:4,23 138:8,17 140:9,11,14 144:3

husband’s (8) 24:19 32:12 50:21 63:2 97:18 127:3 133:17 139:3

I

I-AK (1) 134:10 I15/15/103 (1) 71:3 I15/15/105 (2) 71:8

76:18 icing (1) 66:6 idea (1) 98:1

identification (1)

149:7

identified (1) 150:11 identify (6) 35:2 56:11 57:24 82:15 85:23

153:7

IFRS (2) 6:18 7:5

Ignore (3) 28:16,20,20

II (1) 33:5 imagine (1) 17:20 immediately (3) 9:9

137:14 144:14 impecunious (1)

96:20 important (12) 7:17

10:22 16:4,6 23:2 52:5 65:24 66:6 92:18 138:9,13 154:7

imported (2) 138:6,7 in-chief (2) 151:15

153:4 in-depth (1) 4:10 in-house (1) 90:23

include (2) 5:24 102:4 including (2) 77:1

94:2

income (3) 17:8 85:13 86:2

income’ (1) 17:11 inconsistency (3)

77:20,22 78:3 increase (1) 73:15 increased (2) 73:19

76:11

incredible (1) 136:25 independent (1)

128:11 independently (2)

56:25 57:23

INDEX (1) 156:1 indicated (4) 1:23

102:17 145:23,24 indicator (1) 136:19 industry (1) 138:9 inelegantly (1) 51:1 influence (1) 73:12 information (9) 3:13
9:14 67:20 71:9 79:18 86:20 91:2 101:12,12

initials (1) 80:15 insisted (1) 66:16 instance (2) 10:21

57:10 instructions (1)

142:22 insurance (3) 4:14

86:7,16 intangibles (1) 10:6 intended (1) 97:17 interest (5) 14:5 79:6

84:10 136:19 143:7 interested (4) 6:7

24:24 25:10 28:19 interesting (1) 138:8 interests (2) 60:6

102:14

international (2) 6:17

7:14

internet (2) 142:11 143:7

interpretation (1)

15:5 interpreted (1) 1:22 interpreter (3) 14:21

14:22,22 interpreters (2) 141:8

148:4 interrogated (1) 27:14 interrupt (1) 47:19 interrupted (2) 57:10

95:6

interruption (1) 95:10 interview (3) 92:16

93:4,19 interviewed (1) 99:1 interviews (2) 98:25

124:6 invested (1) 23:1

investigator (2) 124:6 136:18

investigatory (1)

136:19 investment (1) 125:11 investments (1) 80:6 invite (1) 147:17 involve (1) 9:23 involved (33) 13:11

14:3 15:1,9,14 16:2 16:5 19:18 20:1,5,8 21:21,25 24:25 26:22 27:10,17,21 37:16 68:16 72:10 76:24 82:17 84:2,8 84:14,15 89:9,22 91:1 130:1 153:13 154:20

involvement (13)

18:19,24 19:3,6,13 19:15,20 25:10 26:23 28:22 67:5 129:5 130:7

involves (2) 61:7 63:5 involving (2) 70:22

131:9

issue (10) 20:14 30:21 31:2,20 41:21 54:20 129:1 141:18 143:2 144:4

issues (6) 1:12 20:17

20:20 21:22 126:11 126:22

issuing (2) 8:15 139:3 Italy (1) 140:8

J

January (2) 13:14,22 join (2) 127:2,19 joined (1) 9:10 journey (2) 141:3

155:5

judgment (14) 22:17 22:25 25:6 87:13 87:17 88:3 89:1,25 90:17 91:7,13,19 91:24,25

judgments (1) 90:12 Julia (5) 1:21 40:9

63:4 132:12 156:3 July (3) 17:17 20:10

71:5

June (11) 34:22 35:8 38:18 40:1 42:2 87:14 91:19,20,22 91:25 127:14

June/July (1) 139:14 junior (4) 9:10,11

10:12,13

JUSTICE (147) 1:3,14 1:18,24 2:7,12,16 2:20,22 3:14,18 16:24 17:3 20:13 20:16,19,23 21:1 28:25 29:5 30:20 30:22 31:13 33:17 33:21 36:25 37:4,9 38:21,24 43:11,16 47:4,13,18 48:8,13 49:24 50:5,7,25 51:12,22 57:6,20 59:21 60:4,15 84:18,21 91:18 92:2,4,17,24 93:7 93:11 94:21,24 95:6,9,13,18,23 96:3,5,9,24 97:4 99:22 100:7,12,15 100:21 101:9,15,18 101:23 126:17 128:20,21 129:25 130:4,13,21,25 131:8,22 132:4,18 133:2,20 134:5,8 134:22 135:4,13,22 137:18 138:12,21 139:6,11,17,21 140:6,15,19,24 141:10,14 142:25 143:9,13,19 144:2 145:23 146:11,17 146:22 147:2,7,11 147:16 148:6,10,21 149:2,12,22 150:1 150:5,10,21 151:5 151:11,17 152:5,16 152:23 153:2,5,17 154:16,24 155:4 156:7

justify (1) 101:10

K

Kapustin (1) 139:18 keen (1) 70:14 keep (8) 62:19,23

77:17 79:9 81:3 99:15 100:24 144:5

keeping (4) 75:2,9,13 77:25

kept (7) 13:19,19 17:21 68:8 99:9 139:8 143:24

keys (1) 140:3 kidding (1) 49:20 kids (2) 23:19 127:24 killed (1) 98:8

kind (4) 9:15 29:15 70:24 123:19

kindly (1) 96:23 knew (6) 59:16,19

75:4 137:12 139:2 139:10

know (73) 5:25 10:7,8 11:13 12:16,21 15:5 17:2 27:13 28:10 32:10,22 33:21 36:16 37:17 38:23 39:17 40:21 43:7,18 44:2 46:8 46:12 47:9,24 49:16 51:16 52:4 54:8,16 61:9,24,24 66:1 67:23,25,25 68:4 71:24 74:3,4,6 74:16 75:23 76:14 79:7,17 82:3,18 83:25 91:16,20,22 92:4 94:22 95:3,23 96:25 98:9 99:14 102:5 135:14 138:19 139:4 140:2 141:1,23 144:7,11 148:23 149:19 150:16 151:18

knowing (1) 130:22 knowingly (2) 33:10

131:11 knowledge (8) 12:15

18:19 67:1,14,17 67:19,22 137:24

known (1) 91:13 knows (4) 98:20 100:20 142:13

146:23

Kotka (1) 138:7

L

labour (7) 13:15,20 17:20,23,24 18:11 72:23

lady (2) 6:25 137:5 language (3) 45:9 90:18 129:1

large (10) 53:13 61:1 61:7 68:1 69:15 89:9 132:25 133:14 134:1,1

larger (1) 10:23 lasts (1) 7:21 late (1) 149:20 law (4) 50:1 89:6

124:12,14

Laws (1) 137:15 lawyer (8) 27:16

54:14 87:23 90:23 90:23 96:21,22 98:3

lawyers (6) 86:22 89:22 90:19 91:2 99:6 139:19

lead (1) 76:25 leak (1) 144:13 learned (2) 4:16

131:13 learning (1) 5:17 leave (11) 6:23 7:24

13:4,5,17,18 14:2

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

161

February 26, 2016 Day 17 — Redacted

125:24 126:5,25 154:9,18
127:8 London (5) 53:12
leaving (1) 140:11 54:10 149:3,6,11
left (6) 13:20,21 91:21 long (2) 139:23
124:24 127:14 146:24
140:12 longer (6) 11:10 63:14
left-hand (2) 2:8 12:5 66:5 73:7 99:24
legal (10) 26:24 50:3 100:8
72:25 77:6 88:19 look (33) 3:21 10:18
89:9 98:13 123:22 10:25 18:11,14
133:6 152:1 29:15 32:22 34:25
legalese (2) 90:18,24 36:11 38:4,17 39:4
legally (4) 26:14 74:17 39:6 42:9 47:1
98:13 153:6 52:21 54:5 60:22
Lehman (1) 136:6 60:24 69:16,18,22
lending (1) 59:14 70:5,14 78:7 80:24
lengthy (2) 126:7,8 81:8 88:3 90:14
let’s (5) 8:20 32:22 125:2 132:20,21
45:2 74:2 148:14 134:5
letter (14) 41:17,18 looked (10) 28:6
41:18 42:16 71:4,9 40:12,13 52:9
71:13,24 74:11 55:24,25 56:1,16
76:6,17 77:14,18 132:8,10
77:21 looking (11) 10:20,20
letting (1) 154:11 43:8 63:16,17 66:1
level (2) 21:23,24 67:6,11 70:4 76:19
liabilities (1) 63:11 154:17
liability (9) 50:14,16 looks (25) 12:10 34:19
50:19,21 51:4,7,9 34:22 35:5,12
133:7,8 36:15,16,18 38:10
liable (1) 63:10 39:1,9 41:5 45:22
licensed (1) 94:1 61:23 69:9,13,21
lies (1) 154:19 69:25 70:16,17
life (9) 27:3 28:3 80:2 81:10 89:25
129:15 130:24 123:15 132:22
131:10 133:25 Lord (177) 1:9,9,17
134:3 135:3,8 3:18,20,21 14:24
light (4) 28:15 30:16 16:25,25 17:4
56:23 92:19 20:13,15,15,18,18
liked (2) 133:5 138:10 20:20,25 21:2
limited (6) 18:19 19:6 28:24 29:1,8 30:4,4
19:11,13 149:18 30:21,21,24 32:9
154:10 32:13,18,23 33:19
line (9) 80:5 92:20 33:20,22 36:25
93:6,13,18 94:9 37:2,6,14 38:4,8
95:11 96:4 129:6 39:15 43:15 44:10
lines (9) 6:14,16 22:24 47:4,7,7,14,14 48:1
52:23 53:14 80:7 48:12,14 49:24
83:16 129:4 132:12 50:2,2,6,6,23,24
linked (2) 27:1 129:8 51:10,11,11,18,23
list (7) 41:1,6 46:9 53:9 57:8,18,21,22
54:2 56:13 58:6 59:21 60:3,3,6,8,12
137:8 60:16,16 84:20,23
listed (2) 33:5,6 84:23 91:25 92:3,8
listening (2) 15:4 92:9,18 93:1,8,12
71:11 94:23 95:5,8,11,15
litigation (3) 17:9 95:21 96:1,4,7 97:5
53:25 94:1 99:12,12 100:4,10
little (9) 4:13 21:14 100:14,19,19 101:4
43:7 60:5 79:11 101:14,16,16,20
129:11 132:4 102:7,14,24,24
139:10 153:8 123:10 126:20
live (2) 125:12 127:5 128:18,19,23 135:2
lived (2) 19:23 20:7 135:13,25 139:15
lives (1) 27:23 140:6,22,23,23
living (1) 87:25 141:5,12,14,17,17
LLC (15) 14:17 17:8 143:6,10,14,22
72:4 74:9,14 76:21 146:2,12,19,23,23
76:22 80:3 83:9,21 147:5,8,12,17
86:7,7,15,16 88:12 148:9,11,24,24,24
loan (15) 33:8 34:13 149:5,21,21,23
34:21 35:7,16,17 150:2,6,17,24,24
36:2 42:2,3,20,21 151:8,8,13,13,19
48:16 49:6 67:18 152:12,12,17 153:1
69:10 153:3,10,10,23
loans (4) 59:18 68:1 154:15,15,22,22
138:14 139:3 155:2,3 156:4
local (1) 76:25 Lordship (37) 16:2
logistical (3) 149:5 18:24 19:15 26:7

28:1 30:8,13,15,17 31:10 47:12 54:7 55:15 62:20 77:18 92:3,10,13,18,22 93:1,5,22 99:14 101:4 141:6,20 142:4,12,19 143:23 146:23 147:17 148:1,19 149:1 151:23

Lordship’s (8) 39:23 92:12 99:17,20 101:7 142:7 149:8 152:18

lose (1) 76:15 loss (1) 10:1

lost (3) 77:3 138:4,5 lot (8) 3:2 44:21 47:11 47:25 59:14 68:2

148:6 154:23 lots (4) 9:14 58:24

98:21,22

LPK (3) 79:20,21 80:3

Lukina (5) 75:22,25 76:1,4 77:1

Luncheon (1) 101:2

M

Madame (2) 24:22

25:17

Magnum (3) 1:10,11

17:1

maiden (1) 24:12 main (8) 19:16 23:5

26:20 63:12,13 71:18 125:11 139:2

making (5) 16:11 24:1 41:1 60:3 126:20

managed (2) 23:7 82:12

management (18)

9:14 15:1,9,14,22 16:3,4,5,6,7,16 20:2 23:6,10,10,23 27:10 76:25

manager (3) 81:12,17 81:20

manages (1) 74:4 managing (6) 16:10

16:14,15 24:8 26:8 74:1

manuscript (1) 46:10

March (4) 22:15 83:5 136:2,14

Marine (9) 14:17 15:8 17:7 18:20 19:7 25:1 88:11 89:23 139:19

maritime (1) 23:3 mark (3) 42:14,25
101:15

Marketing (1) 6:20 markings (1) 41:22 marriage (5) 97:9 99:8

134:12,14,25

Martinique (2) 140:16

140:18 matches (1) 77:23

material (7) 1:9 90:11 143:5 149:4,8 150:9 152:3

materials (2) 10:21,21 maternity (6) 6:23

7:24 13:4,17,18 14:2

matter (10) 1:15 25:9 34:6 95:16,17 102:16 142:23

143:14 151:11,13 33:11 neatly (1) 152:18 O1/29/1 (3) 69:7 70:4
matters (9) 1:8 18:18 mistaken (1) 21:20 necessarily (3) 36:18 70:19
60:7 71:2 77:16 misunderstood (2) 39:10 99:23 O1/7/1 (4) 47:2 48:14
97:15 101:5 142:15 51:13 53:5 necessary (2) 130:8 48:17 51:25
151:4 MKD (16) 11:3,6,9,12 130:16 O1/8/1 (4) 52:7,10
maximum (2) 44:11 11:24 12:8,11,14 need (24) 14:11 25:8 58:4,12
127:1 12:19 13:2,8,11,15 28:23 29:1,3,5 O1/9/1 (2) 59:20
mean (35) 5:25 22:4 13:22 14:3 17:23 30:12 59:18 60:1 60:14
33:17 36:10,18 moment (1) 40:5 64:10 66:18 92:20 O2/149/1 (1) 40:23
37:12 39:10,10 Monaco (2) 140:12,13 99:18 100:5,8 O2/149/5 (1) 41:25
45:20 50:17 52:15 Monday (15) 1:8,16 126:1 132:19 O2/149/6 (1) 44:13
53:6,17 55:23 82:19 84:25 141:16 141:19,20 142:21 object (1) 101:13
56:21 59:23,25,25 141:21 142:16,24 142:21 146:25 objecting (1) 101:22
65:11,17 67:21 145:23 146:3,5,20 148:22,23 objection (1) 102:17
68:19 70:24 71:25 147:18 154:8 155:8 needed (5) 68:2 73:22 objections (2) 102:1
81:12 82:3 84:18 money (27) 37:16 75:7 131:25 138:14 102:23
94:25 97:22,24 48:25 49:21 59:14 needs (5) 18:10,10 objective (1) 126:5
129:11,12 135:2 60:24 61:2,7 63:6 31:4 71:16 125:24 obligation (1) 77:6
137:20 139:15 67:6 68:2 69:15 negative (1) 73:16 obligations (1) 42:12
meaning (1) 17:12 73:13 77:23,24 neither (3) 73:11 obliged (1) 92:7
means (11) 16:7 86:1,25 123:21 97:17 127:9 observations (1)
17:24 72:25 76:5 131:19,25 132:10 never (30) 9:8 13:23 142:20
99:25 123:21 132:13,13,19 133:1 15:9 16:15,15 obtain (2) 102:12
129:13 142:17,18 133:14 134:4 24:25 26:13 27:10 125:11
142:18 143:17 135:10 33:9 51:3 53:1 obtained (1) 102:3
meant (7) 6:3 26:9 monies (1) 85:17 66:20,25 67:2,7,22 obvious (1) 149:6
41:18,23 129:10 month (3) 22:11 75:1 68:8 87:9 130:18 obviously (13) 10:1,17
146:2 148:12 78:19 131:16,17,23 132:2 10:18 30:4 43:19
mechanics (1) 68:9 months (7) 78:17,18 133:15,22,25 44:24 93:19 100:19
medical (1) 144:9 125:24 126:1 135:10,19 136:8 126:11 132:7
meet (2) 139:4 154:8 127:17,17 153:12 140:12 147:13 150:11
meeting (2) 11:12 moratorium (1) nevertheless (1) 151:13
138:20 138:23 154:7 occasion (4) 64:23
meetings (2) 138:13 morning (4) 1:3 45:19 new (1) 86:15 66:20 131:23 132:2
138:19 45:21 56:24 news (1) 142:1 occurs (1) 149:12
memory (4) 3:11 7:12 mother (20) 23:22 Nice (6) 19:23 20:7 October (3) 21:16,18
30:20 152:13 24:8,11,16,22,24 53:12 85:9 135:9 22:10
mention (1) 138:24 26:4 27:23 28:10 141:4 offer (3) 6:22,24
mentioned (7) 24:11 28:13,22 80:15,17 nightmare (1) 137:3 90:16
24:21 25:16 28:7 80:17 81:13 82:9 Nikolai (1) 87:24 offered (1) 124:15
72:9 80:20 102:16 82:10,22 98:14 nine (2) 83:15,16 office (3) 13:23 27:15
met (1) 12:21 130:1 nominal (14) 25:2 28:8
Meylanov (4) 146:3 mother’s (1) 129:5 27:6 80:22 81:20 official (1) 72:20
146:18,19 147:3 mother-in-law (7) 81:23 82:4,11,22 oh (3) 35:20 92:17
million (14) 35:13,22 23:8 24:15,18 86:16 129:16,18,22 132:12
36:10 48:24 49:20 25:22,23 26:3,6 130:8,11 okay (5) 25:16 46:13
52:12 58:2 59:5 move (1) 43:2 non (1) 61:15 46:16 147:11 150:5
62:12 63:6 69:11 moved (1) 102:8 normal (1) 146:11 Olga (2) 75:22,25
69:15 70:23 83:10 mum (16) 25:10,16,22 nose (3) 98:5,5 OMG (25) 11:9 12:14
Milner (2) 153:12,12 25:24,24,24 26:6,7 124:14 13:12 14:4 15:14
mind (15) 6:14 7:13 26:21 27:3,8 82:6 noses (1) 75:14 15:16 16:3 20:21
8:3 9:18 28:13 129:16,18 130:6 note (4) 39:23 92:12 20:22 23:5,11,23
32:20 49:25 57:12 131:16 92:18 129:3 24:4,9 26:8 32:21
64:5 65:5 67:6 mum’s (1) 130:9 notes (1) 65:5 59:14 64:24 79:15
70:24 75:20 95:24 mustn’t (2) 82:25 notice (1) 146:9 84:9 85:18 88:20
146:10 100:22 notwithstanding (1) 90:4 91:11 136:10
minding (1) 23:18 mystery (1) 72:14 77:7 OMGP (3) 87:18 90:6
mine (6) 2:5 53:16 nought (1) 26:13 94:11
55:9 70:14 97:17 N November (2) 69:12 once (11) 7:23 27:14
101:20 N (4) 41:18,23 46:5,9 70:6 42:16 44:20 45:14
minimal (8) 16:18 number (10) 8:5 45:23 46:18 135:7
N21/50/83 (1) 22:13
18:2,6,13 23:17,21 15:12 42:1,4,9 136:17 149:10
N21/50/88 (1) 22:16
23:21 79:8 54:11 56:12 65:7 154:13
N21/50/95 (1) 25:6
minimised (1) 75:8 78:15 81:2 one-off (2) 124:20
N6/7356 (1) 134:10
minute (1) 11:22 numbered (1) 58:6 136:25
name (16) 8:14 24:12
minutes (7) 7:21 72:9 numbers (5) 33:6 56:4 Onega (7) 34:13,22
24:19,19,19 25:4
99:12,16,19 100:1 56:14,19,21 35:8,18 36:2 42:3
26:15 63:2 79:21
100:9 nuptial (1) 99:6 42:21
80:16 131:19
minutes’ (1) 60:7 NV (1) 87:22 ones (1) 69:17
133:14,19,21
minutiae (1) 68:9 online (1) 142:1
134:12 137:6
mischaracterising (1) O onwards (2) 13:3
names (2) 68:5 142:6
62:23 93:23
narrow (1) 84:1 O/12 (1) 40:2
mislead (1) 132:18 opaque (1) 36:8
naturally (1) 148:22 O1/10/1 (2) 61:17,22
misleading (5) 37:23 open (8) 13:19 123:9
nature (2) 19:15 O1/11/1 (3) 62:6,9
93:15,17 94:14,14 142:17,18,19
95:10 64:9
misled (2) 53:10 145:21 156:6,9
Nazarov (3) 147:4,7,8 O1/12/1 (5) 34:14
132:17 operating (3) 59:16
near (1) 27:24 36:12 40:2,13
missing (1) 31:19 88:20 123:16
nearly (2) 20:23 96:7 134:5
mistake (2) 25:23 operations (3) 21:21

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

162

February 26, 2016 Day 17 — Redacted

22:5 81:21 opinion (8) 12:3 40:14

40:17 61:14 75:11 78:1,1 79:8

opposed (1) 63:20 option (1) 61:16 order (5) 4:6 17:12

47:4 135:10 146:7 ordinarily (1) 153:6 ordinary (1) 153:16 organised (1) 74:17 orientate (1) 47:16 original (3) 16:24

31:21,22

Oslo (9) 14:17 15:8 17:7 18:20 19:7 25:1 88:11 89:23 139:19

outside (5) 18:18 126:21 132:14,21 144:1

overnight (1) 1:6 overspill (1) 147:16 owned (3) 14:17,18

99:7

owner (14) 16:9,9 18:2,3,8 19:24 20:3 74:22,24 79:9,10 89:7 98:13,14

owners (1) 75:10 ownership (2) 15:21

77:8

owning (1) 16:10 owns (1) 74:6

P

pace (1) 99:2

page (29) 2:9 11:17 11:20 12:6 21:3 22:18 29:18 33:23 38:25 45:12 46:11 70:4 80:23 83:8 87:20 88:6 89:24 89:24 90:7,8 93:1,2 93:12,12 95:11,12 129:3 142:3 156:2

pages (7) 3:3 34:2 80:9,10 81:1,3 93:23

paid (11) 8:12 13:18 72:16 73:8,13 75:12 77:17 79:9 86:14 90:4,6

paint (1) 38:8 paper (5) 54:22 56:8

133:22,23 134:25 paragraph (63) 4:3

10:25 12:23,25 14:10,13 15:4,11 15:20 16:8,23 17:5 17:10 18:14,17 19:1 21:5,7 22:4,19 25:8,13 26:2 29:16 29:20,21 33:1,12 40:6 54:25 55:6,8 55:16,25 56:11 57:24 58:9 60:19 65:4,11 85:6,11 86:3,12 88:7 97:6 97:13 123:11,13,15 124:1,8 125:2,10 125:22 126:14 127:12 128:2 135:23 137:18 149:15,21 152:8

paragraphs (9) 3:22 3:25 4:2 29:24 30:3 64:11,15 76:18

86:10 51:7 66:17 76:2 19:24 20:2,6 30:6 81:23 propose (2) 101:23 70:8,15 71:23
part (18) 4:17 5:5 18:6 133:8 140:14 30:18 37:6 40:16 presume (2) 12:13 146:18 72:12,15 74:8
19:16 20:1 33:25 personnel (1) 64:19 49:22 52:6 59:11 91:5 proposed (1) 146:5 77:10 82:18 83:1
44:4,5,6 71:19 persons (1) 26:18 61:20 63:5 67:8 pretty (1) 55:7 proposition (2) 40:9 84:11,20,23,24
81:21 85:13 89:14 persuade (1) 132:18 72:25 88:23 92:9 previous (12) 47:6 40:15 88:18 89:8,11 91:4
102:18 127:1 133:9 pertaining (3) 76:9 92:11,11,22 95:6 48:22 60:22,25 prospects (2) 132:9 92:23 93:14,19
136:21 139:9 101:5 135:8 133:3 139:3,22 61:19,23 69:13,16 132:20 94:5,16,19 95:2,18
particular (11) 20:13 petered (1) 75:16 150:3 69:19,25 84:16 protect (1) 27:4 95:24 96:2 135:5
39:8,11 43:23 Petersburg (27) 5:22 points (5) 30:16 31:9 150:11 protected (1) 98:24 135:22 139:2
48:11 68:22,23 8:15 23:3 28:4 89:4 93:22 150:18 previously (5) 70:1 proved (1) 148:17 questioning (5) 55:8
89:16 130:10 34:21 35:7,18 police (2) 99:1 124:5 150:15 152:10,21 proven (1) 22:22 92:20 93:6 94:10
142:11 150:2 39:12 42:21 49:8 poor (1) 31:22 153:8 provide (4) 87:8 91:2 96:4
particularly (4) 39:12 50:8 54:1 59:14 poorly (1) 31:25 price (3) 86:14 87:3 131:25 134:20 questions (43) 1:22
69:23 99:19 141:2 60:23 62:12 64:23 port (50) 17:7,13,19 90:3 provided (4) 102:2 3:19 7:22 18:18
parties (2) 142:19 67:16 69:11,16 18:5,21,25 19:3,8 primary (1) 9:14 132:9,10 143:20 20:22 24:5 27:18
143:8 71:6 87:14 88:1 19:14,16,21 20:9 principal (1) 63:9 provides (1) 11:6 27:19 30:1 38:8
parts (1) 153:23 124:2,19 126:6 21:14,18,22,25 principally (1) 13:4 providing (2) 88:21 43:18 44:7,9,10
party (1) 143:3 138:3 142:14 22:3,9 23:3 28:7,9 principle (2) 63:23 134:14 45:8,10 50:20 51:1
Pasko (5) 146:3,4,4,20 Petrograd (6) 18:22 71:7,7 72:3,8,24 77:4 public (5) 22:21 28:5 51:12 55:2,14 57:9
147:2 19:4,9,14,18,18 73:6,7,8,15 74:1,5 prior (4) 14:7 15:23 102:8,11,12 57:12,15 63:16
pass (1) 154:22 philosophical (1) 74:9,13,13,15,15 74:21 99:8 publication (1) 142:1 72:1 79:13 84:1,6
passport (7) 125:22 84:21 74:20 75:3,10,22 prison (3) 99:2 137:2 publicity (1) 143:1 88:24 92:14,19,22
127:10,10 134:12 physically (1) 44:25 76:21,22 78:8,9,9 137:7 pull (1) 31:1 100:17 101:5,8
134:15,17,25 pick (1) 42:25 79:4 138:2,5,7 private (11) 101:10,24 purchase (4) 85:8,13 102:7 128:20,22
Pause (6) 4:1 29:4 picked (1) 5:19 portion (1) 10:23 102:9,18,20 103:1 85:19 90:3 136:1 140:6,21
30:2 86:10 94:4 picking (1) 33:1 ports (4) 17:8 23:3 143:23 144:5,17 purchasing (1) 135:8 156:7
140:19 piece (3) 54:22 133:23 90:4 91:11 156:5,8 purely (4) 13:10 78:1 quiet (1) 27:3
pausing (1) 93:14 134:25 Ports’ (1) 88:12 pro (2) 13:10 96:11 81:20 130:8 quite (30) 3:9 4:22 5:8
pay (4) 10:24 72:11 pieces (3) 10:4,14 position (13) 13:18 probably (4) 60:1 97:9 purported (1) 77:8 7:6 14:1 20:4,11
75:1 77:7 56:8 53:21 97:16,23 99:16 152:17 purports (1) 71:9 23:12 36:8 60:3
paying (5) 18:10 pinpoint (1) 22:11 123:24 124:17 problem (6) 23:25 purpose (8) 7:2 47:10 61:19 77:24 78:19
72:13 75:9 96:21 place (6) 17:22 18:9 133:10 141:7 24:6 131:21 150:16 55:16 97:8,14 83:25 84:14 90:17
138:15 31:2 59:5 81:19 142:13 148:23 150:22 152:24 125:11 130:16 93:15 124:11
payment (5) 75:2,13 132:15 149:19 152:20 problems (6) 28:3,3 142:9 130:22 131:20,22
77:25 78:18 135:10 placed (1) 82:20 154:2 98:4,6 127:3 purposes (5) 11:11 132:2 135:14
payments (14) 72:19 places (1) 136:9 positions (1) 16:16 137:21 26:12,23 31:3 137:25 140:4 143:1
73:4,4,9 74:20,23 plaintiff (1) 88:8 positively (1) 53:19 proceed (2) 37:10 56:14 148:6 152:20
75:20,25 77:3,10 plan (1) 127:1 possible (5) 44:11 101:8 push (1) 35:21 153:19 154:25
78:16,17 79:4 planned (2) 127:16,19 49:17 84:17,21 proceeded (1) 151:22 pushed (1) 101:17 quote (1) 77:12
85:24 plans (5) 126:5,20,24 146:15 proceeding (1) 154:5 put (33) 1:9,11 5:4 quotes (2) 60:23 63:2
payroll (4) 10:5 72:11 126:25 127:8 possibly (4) 50:9 65:7 proceedings (47) 2:13 7:25 8:20 10:11
72:15 73:1 play (1) 73:2 70:12 76:11 3:5,9 16:21 19:2 18:12 26:12 32:24 R
pays (1) 79:10 played (5) 23:23 24:4 posted (1) 142:6 21:3 24:21 36:23 34:10 37:13 38:1 Radley (6) 36:21
peculiar (1) 129:12 24:8 26:8,13 posting (2) 142:3,11 37:17 41:2 44:3 45:19 46:4 48:9
39:20,21 40:2,7,12
peculiarities (1) pleaded (3) 20:14,17 potential (6) 87:2 45:15,25 54:13 49:18 51:19,20
raider (4) 99:2 137:12
151:17 53:19 101:11 142:8 143:7 58:16 71:19 75:6 52:25 53:6 54:8,11
137:20 138:1
pensions (1) 18:11 pleading (1) 33:19 143:7 151:14 75:10 77:8 88:16 56:18 60:12 67:19
Raisa (1) 81:9
people (19) 8:5,6 9:5 please (89) 1:18,20 potentially (4) 20:18 88:21 89:4 90:1 74:17 94:9 97:18
raise (14) 1:12 50:20
24:4 37:7 41:12 2:2,9 3:21,24,25 20:20 41:2 141:21 94:4 96:15 102:11 131:1 132:24 134:7
141:21 142:15,16
82:13,15 89:10 4:1 10:25 11:16,20 power (2) 89:16,18 102:18 128:5,13 143:5 153:21
142:24 145:24,25
99:1 129:17 137:14 11:24 12:23,25 practical (9) 5:6,19,24 131:1,6,7 135:2 putting (4) 51:24
148:22 149:13
138:10,15 142:10 14:9,9,14 15:10,17 6:4,11 8:25 11:11 139:10,15 143:3 54:13 58:24 143:5
150:15,22 153:17
142:25 144:14 16:20 18:14 19:15 26:12,23 149:17,19 151:8,9 puzzled (1) 90:14
154:4
148:3 153:6 19:21 21:2,5,7 Practically (1) 26:22 152:9,11,15,23,24
raised (3) 30:15 79:14
perfectly (3) 45:7,10 22:13,16 24:7 practice (10) 4:21,24 153:20,22 Q
148:10
57:9 25:12 29:2,9,14,18 5:12,16 50:5,7,8 process (10) 47:21,24
qualification (1) ran (1) 127:3
performed (1) 18:4 29:25 33:14 34:14 68:4 76:22 137:12 54:3,23 57:8,10
150:13 rate (1) 50:8
period (5) 19:22 48:3 35:1 36:20,24 precisely (1) 88:18 58:17 60:3 143:17
qualifications (1) 7:8 re-established (1)
73:25 78:9 129:15 40:23 41:25 44:13 predated (1) 124:18 146:11
qualified (5) 7:1 8:5,7 143:20
periods (1) 125:13 47:1,3 48:14 49:3 prefer (1) 99:24 produce (1) 54:16
8:23 10:13 reach (1) 97:19
permission (7) 61:13 52:7 54:7,24 55:21 prejudice (1) 41:20 produced (4) 43:14
quarter (3) 22:18 83:6 reaction (1) 93:8
62:4,17 66:12 55:22 57:4,20 58:4 premise (1) 51:13 44:17 45:6 93:8
83:7 read (28) 2:16 3:25
70:20,24 102:13 59:20 60:14,17 premised (1) 29:1 professional (3) 7:8
queries (2) 76:7,13 4:2 5:9 10:19 11:18
permit (2) 125:12 61:17 62:6 64:8 preparation (1) 71:14 8:9 40:18
query (1) 76:8 11:19,19 14:14
126:2 68:13 69:7,9 71:4,8 prepare (2) 91:2 profit (1) 10:1
question (78) 14:1 18:16 21:7,9 25:7
permitted (1) 70:22 79:7 80:8,9 81:3 146:10 profitably (1) 141:16
15:6,11,15,17,23 29:25 30:3 48:18
person (6) 27:3 52:1 83:3 84:13 85:5,6,7 prepared (5) 46:2,8 progress (2) 147:24
16:12,13 24:7 61:25 64:22 76:18
53:15 75:21 129:23 86:3,10 87:12 92:8 96:15 151:25 154:1 149:10
26:11 28:1,10,16 85:16 86:9,11
137:13 97:5 101:4 123:10 presence (3) 64:19 projects (4) 26:20
28:16,17,20,20,21 89:24 90:7,9 97:12
personal (30) 29:10 125:2,4 128:2 87:20 134:24 68:3 138:3,8
28:23 34:24 35:1 148:25 153:7
33:7,8 34:12,20 140:19 141:24 present (2) 31:3 proof (3) 65:6 66:7,9
37:8 38:6,20,21,22 reading (2) 25:14
35:6 50:11,22 56:5 149:1 154:25 139:20 proper (4) 9:22 45:8
39:3 41:10,13 154:3
56:6,9 61:8 62:11 plenty (1) 28:2 presentation (1) 45:10 151:24
42:14,25 44:20 reads (1) 71:15
62:13 63:1,7,20 plus (1) 4:9 94:15 properly (8) 7:1 98:2
46:14 47:17 53:14 real (4) 4:16 6:5 32:3
67:2,10,15,17,22 pm (8) 100:5 101:1,3 presented (3) 32:4 98:2,11,15 99:10
53:17 54:21 55:11 32:4
75:11 78:1 79:8 102:25 123:8 93:20 94:12 150:18 153:21
55:13,20 56:25 realised (2) 98:7
85:13,22 98:21 144:16 145:20 pressure (1) 137:3 property (7) 97:9,18
57:4,19 59:6 64:18 136:2
102:5 135:12 155:6 pressures (1) 138:16 99:9 134:2,2
65:2 68:13 69:4 really (43) 12:16 27:4
personally (6) 28:4 point (26) 11:13 13:10 presumably (2) 8:17 137:14,15

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

163

February 26, 2016 Day 17 — Redacted

35:2 36:7 38:1 6:19 7:5 8:10 9:25 91:8,14,15 94:13
40:19 43:1,3,7,24 16:8 18:25 26:1,2 94:22
45:19 46:22 49:8 33:14,16 42:6 request (1) 76:10
51:14,24 54:6 55:1 43:15 55:25 58:9 required (6) 45:18
55:4 60:21 64:6 58:11 68:13 70:25 89:13 130:5 131:24
66:8 67:23 68:8,11 75:19 76:17 147:10 154:9
70:3 82:11,12 refers (4) 32:21 35:13 requirement (5) 8:7
90:14,16,24 92:9 88:8 91:13 25:3 26:16 50:4
93:23 94:22 95:18 reflect (2) 141:20 129:22
97:18 100:7 127:4 142:21 reserve (1) 153:14
128:14 130:14 reformulate (2) 15:17 residence (2) 125:12
131:18 142:23 34:25 126:2
150:18 154:23 regard (8) 1:13 73:21 resource (1) 23:2
reason (7) 25:17 76:8 77:25 95:14 resources (1) 134:19
50:25 102:7 136:13 131:18,19 136:13 respect (13) 32:15
146:6,13,14 regarded (1) 73:1 43:10,12,22 57:3
reasonable (1) 12:18 regarding (2) 15:11 68:5 73:12 84:12
reasonably (1) 47:8 24:25 90:16 134:15
reasons (5) 27:15 regards (1) 143:1 140:14 143:21
72:17 137:8 149:6 regime (3) 101:7,22 148:23
150:13 143:21 respectful (1) 152:3
recall (37) 6:15 7:5,7 registered (1) 26:15 respond (2) 76:13
8:11,14 11:12 regular (6) 28:12,14 88:22
23:15 25:1,3 26:14 43:19 73:10 78:16 responsibilities (7)
26:16,19 27:16,20 78:19 18:4,6,12 68:15,16
37:14,19 38:2 41:8 regularly (1) 43:19 68:17 72:10
41:8,14 43:11 regulations (1) 4:25 responsibility (1)
44:22 45:23 47:21 reiterate (1) 40:20 19:16
56:4,19 61:3,11 relate (1) 18:18 rest (1) 89:22
65:8 68:6,7,19 74:3 related (4) 10:8 15:23 results (1) 88:11
75:24 80:20 134:14 67:12 135:17 retired (1) 27:11
136:23 relating (1) 134:25 return (2) 64:25
Receivable’ (1) 83:6 relation (15) 22:3,9 139:13
receive (2) 17:14 23:11 34:21 35:7 reviewing (1) 9:24
74:13 36:2 41:1 42:24 revisions (1) 2:22
received (4) 1:6 17:8 49:6 71:6 81:9 82:9 reword (2) 55:21 57:5
76:21 78:7 93:4 135:5,22 RI (3) 80:11,15,17
receiving (4) 18:3 relationship (1) 12:19 right (69) 4:4 11:9
19:17 77:23,24 relaxation (1) 153:15 13:6 15:13 16:1
recollect (15) 30:18 released (1) 152:6 17:16,18 20:4
35:9,11 38:11 relevant (9) 23:14 21:17 23:9,22 26:6
43:25 52:11 84:14 30:7 31:11 33:15 27:23 29:3 31:8,12
92:14 93:6 130:14 34:7,8 41:19 65:13 32:25 33:12 37:9
130:22 131:11 150:9 46:1,25 47:7 50:5
132:15 134:23 relied (2) 150:3 153:4 51:11 56:17 57:17
135:15 rely (3) 128:13 153:20 58:20,21 60:7
recollection (2) 33:4 153:24 64:23 66:20 69:4
37:1 relying (1) 82:24 72:21 74:10,14,15
reconcile (1) 77:19 remains (1) 19:24 76:3 78:10 80:18
record (16) 13:21 remember (10) 30:21 81:24 82:22 84:7
17:20,23,24 18:11 41:5,15 43:1,13 89:3,19 92:11,24
32:14 72:23 91:7 44:18 47:24 48:5 93:21 96:10 100:19
93:3 102:12 151:10 67:23 69:2 101:11 102:22
151:11,13 152:25 remembering (1) 124:2,10 126:10
153:3,11 45:24 127:12,15 128:16
records (3) 9:15 22:25 remind (2) 29:23 133:23 134:22
73:1 146:17 137:22 139:20
recreate (1) 154:13 reminded (1) 75:6 140:10,15 147:2
rectangular (1) 30:23 remuneration (1) 150:5,6,7,9 154:8
REDACTED (23) 103:2 74:24 rights (2) 96:12
104:1 105:1 106:1 repeat (4) 24:7 29:18 123:23
107:1 108:1 109:1 55:21 127:7 ringfence (2) 98:17,18
110:1 111:1 112:1 reply (1) 76:6 ringfenced (1) 99:8
113:1 114:1 115:1 repo (1) 95:3 ringfencing (1) 98:19
116:1 117:1 118:1 report (6) 9:12,13 risk (1) 132:7
119:1 120:1 121:1 36:21,22 39:19 role (16) 16:17,18
122:1 123:1 144:18 69:24 18:5 21:12 23:10
145:1 reporting (3) 141:18 23:17,20,23 24:8
refer (5) 24:13,14,14 142:20 144:1 26:8,13 71:18 72:7
66:9 152:9 represent (3) 89:18 72:20 73:2 82:12
reference (13) 42:1,3 95:1 97:2 roles (1) 24:3
42:23 56:12 58:12 representation (1) rouble (2) 78:21 79:1
77:13,16 83:3,8 152:2 roubles (5) 60:24
91:8 94:13 134:10 representative (2) 78:21,22,24 87:6
151:2 74:7 87:21 roughly (1) 78:11
references (1) 142:21 represented (3) 85:13 round (1) 70:7
referred (4) 10:16 96:21 153:7 route (1) 150:20
34:9 87:1 93:9 represents (1) 94:7 RPC (1) 149:5
referring (21) 4:19,22 repurchase (6) 87:2 RUB (13) 35:13,22

58:2 59:5 63:6 69:11,15 70:23 83:10 87:7,7 90:3,5

ruled (3) 125:21 131:13 132:17

rules (13) 4:24 5:6,13 5:14 6:1,12,13,17 7:6 153:16,19 154:2,7

run (2) 82:12 127:21 running (3) 10:17

76:24 148:5 runs (1) 10:11 Russia (34) 4:14,20

13:16 17:21 18:7 50:9,10 64:18 65:6 65:9,15 74:7 75:17 123:19 124:16,17 124:25 125:20 126:4,21,23 127:5 127:8,14 136:9,18 136:20 137:13,14 138:6,9 139:12,23 142:1

Russian (37) 2:3 3:23 6:13 7:6,14 14:11 14:15,20 21:4 33:18 34:16 35:11 43:20 44:25 45:2 47:23 48:6 50:1,3 78:21 79:23 81:7 83:13 85:7 87:15 88:16 90:18,18 97:7 98:8 123:22 125:4,22 126:17 127:11,14 135:24

S

sa (1) 26:5 safeguard (3) 97:15
98:12 99:5

safeguarding (1)

97:22

sailed (1) 137:24 Salaries (1) 86:2 salary (15) 17:14 18:3

18:7 19:17 20:4 28:7,9 72:13,16 73:8,15,19,24 76:9 76:10

sale (3) 91:14 93:21 94:10

sales (1) 90:13 sat (1) 56:1 satisfy (1) 55:18 save (1) 138:23 Savelyev (3) 128:6

138:22 142:14 saw (3) 47:19 52:23

146:16

saying (23) 15:20 16:8 23:16 25:16 26:12 27:17 35:20,23 36:3 38:23 49:8,25 53:4 62:19 66:16 68:19 75:19 86:24 87:5,9 124:8,13 131:3

says (22) 12:2,7,17 13:13 22:4 34:5 40:7 48:23 56:2,21 58:15 60:23 63:3 81:17 83:20,22 87:20 90:20 91:25 96:25 97:1 124:4

Scan (3) 14:16 79:20 79:21

Scandinavia (3) 80:3

86:7,16 76:8 signature (56) 2:10
Scantrade (1) 83:17 sentence (3) 13:1 36:11,15,17,17,18
schedule (2) 30:7,13 18:16 137:19 36:19 37:7,13,15
scientist (1) 9:3 September (6) 14:16 37:19,21,24 38:4,5
scope (1) 153:15 136:7 139:15,16,18 38:9,10,13,13,17
screen (21) 2:8 11:22 139:24 38:17 39:1,4,6,8,9
12:9 33:23,24 34:2 sequence (2) 47:6 39:11 40:9,11,11
34:14,14 36:13 146:10 40:15 41:11,11
38:16 40:4 47:2 series (1) 92:14 42:13 44:1,14 45:3
48:17 52:3,8 58:4 serious (8) 136:4 46:17,22 48:9 49:1
59:20 69:9 71:4 137:10,19,20 52:24 53:16 69:18
87:12,15 138:17 142:23 69:21,22,22 70:5,6
screens (1) 154:18 143:10,11 70:16,16 80:24
scroll (1) 80:9 served (6) 36:22 45:9 81:18,19 87:9
scrolls (1) 93:2 46:5 47:10 78:6 134:24
search (1) 142:10 153:10 signatures (4) 41:9,22
searing (1) 136:7 service (1) 6:24 46:7 70:13
second (8) 2:14 16:20 services (3) 6:22 11:7 signed (52) 32:24 33:9
19:1 24:19 88:6,7 88:22 33:11 37:1 41:7,19
90:8 140:19 set (2) 71:9 86:6 44:16,21 45:7
secret (1) 134:20 setting (1) 40:25 46:11 47:23 48:20
sector (1) 23:3 seven (1) 22:24 51:2,25 52:1,4 56:3
security (6) 10:6 Sevzapalians (7) 86:15 58:1,3,15,17,19
124:9,23 126:11,22 87:3,18 88:17 90:5 59:2 61:9,13,13
139:12 91:9 94:11 62:1,3,16 64:17,19
see (113) 2:7 10:2 share (10) 16:19 43:9 65:1,7 66:8,10,12
11:4,7,16,17,19,23 86:24 87:6 88:16 66:17,21 70:19,20
12:1,2,3 14:13 15:3 136:12,16 138:12 79:20 80:11 82:23
15:4 21:23 25:18 139:6 143:23 86:24 87:4,9 95:21
27:8 29:21 30:14 shareholder (3) 14:25 96:16 131:11
31:23 33:13,22,24 15:8 23:5 133:16,23,25
34:4,16 36:15 38:7 shareholders (1) significantly (2) 78:13
38:16 39:6,21 40:1 86:15 78:20
41:3,4,16,25 42:9 shares (8) 86:6,14 signified (1) 130:23
44:1 46:5,11 48:17 87:2 90:5,6 91:10 signifies (4) 42:17
48:23 49:3 50:17 93:5 94:11 49:5,13 151:18
52:3 57:14,21 sheet (4) 9:25 80:5,7 signify (2) 41:19 48:10
58:11 59:20 61:21 83:5 signifying (1) 44:16
64:14,20 65:11,17 sheets (2) 84:5 137:5 signing (11) 44:19
67:9 69:12 70:13 Shevelev (1) 137:7 45:12 50:17,18
78:23,24 79:1,22 Shipping (1) 49:7 56:5 57:1 59:11
80:7,10,13,14,23 short (3) 60:10 80:5 61:11 65:16 132:19
81:2,7,17 83:7,9,10 100:12 133:24
83:11,15,17,20 shove (1) 35:22 silent (6) 75:2,9,13
85:9,11,15 86:8,9 show (8) 31:23 34:7 77:17,25 79:10
86:17 87:12,16,18 36:20 37:12 39:19 similar (5) 58:24
88:4,13 89:24 90:7 48:14 70:13 79:19 61:19 80:25 93:22
90:9,13 92:22 93:1 showed (1) 47:21 144:9
97:11,20 99:10 showing (2) 63:19 simply (22) 13:20
123:13,18 125:5,8 84:3 17:23 28:6,18
125:10,15 126:16 shown (30) 14:9 37:14 38:1 41:14
126:19 128:4,9 16:20 20:12 21:2 44:25 45:17 50:14
130:13 133:14,14 22:13 23:13 25:5 54:2 58:2 75:8,16
134:22 137:18 31:18,21,25 33:14 89:19 101:18
142:4 147:11 36:24 40:23 41:13 102:15 130:15,19
154:12 43:24 44:13 46:18 132:23 133:6
seeing (3) 52:11 53:5 46:21 52:7 53:12 153:17
53:5 54:24 61:17 62:6 single (2) 13:15,22
seeking (2) 57:14,15 64:8 69:7 86:23 sir (33) 7:5 14:22 15:6
seemingly (2) 79:15 87:1 90:23 92:8 15:15 16:8 19:3
143:6 142:5 21:9 22:4,6 24:6,24
seen (28) 32:11 43:21 shows (2) 17:21 92:6 25:12 26:11 28:18
46:16 49:14 52:10 side (6) 2:8 5:6 90:21 29:18 38:7 49:14
52:14,15 53:1,3 144:10 149:5 152:4 49:20 52:15 53:5
54:10,12,18,21 sign (52) 2:11 13:24 53:17 54:21 55:10
55:14 56:2,7,8,20 33:4 34:24 39:16 55:20,22 57:4
58:16,16,22 61:3 44:23 45:15,18,22 70:25 77:22 78:3
61:10 72:6 87:4,7 47:20 49:18 51:5 85:20 89:8 102:23
98:15 144:10 52:1 54:6 55:19 132:16
sees (1) 144:3 57:24 58:25 59:4,7 sit (3) 1:24 7:15,19
self-evident (1) 41:24 59:8,10 60:21 61:6 sitting (4) 8:13 17:23
sell (1) 91:10 61:21 62:3,9,13,16 66:2 148:7
sending (1) 73:3 64:24 65:4,14,20 situation (4) 27:1 75:4
senior (2) 9:12 10:10 66:15,18,18 70:12 129:8 138:15
sense (8) 29:12 54:9 70:21,22 89:13 situations (1) 65:13
61:1,2,24 123:24 90:22 95:20 130:14 six (2) 126:25 153:11
144:13 154:10 130:16,18,19,21 skills (1) 137:24
sensitive (1) 101:12 131:2,16,17 132:12 skiving (1) 154:10
sent (4) 46:3,3,11 135:9,17 Sklyarevsky (3)

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

164

February 26, 2016 Day 17 — Redacted

142:13 148:11,15 spousal (12) 29:9 30:5 straight (1) 100:6
slightly (2) 57:5 67:8 31:7 32:14 34:11 straightaway (1) 28:2
slowly (2) 80:9 92:24 35:5 42:23 48:15 straightforward (1)
small (7) 25:23 69:5 57:1 63:19 67:9 129:15
86:25 87:6 123:20 131:24 straitened (1) 77:11
128:25 140:7 spouse (10) 23:7 straits (1) 75:5
smaller (2) 10:14 25:17 50:10,12,13 strange (6) 24:20 27:2
73:11 50:15,18,19,20 75:11 77:5 129:9
smashed (1) 98:5 62:22 129:20
smiled (1) 84:6 spreadsheet (7) 43:4 stress (2) 136:11,25
smiling (1) 83:23 43:15,21,23 45:23 stressed (1) 15:24
Smirnov (2) 142:12 46:17 48:11 stressful (2) 136:9
143:21 spring (2) 125:17 141:2
social (1) 10:5 137:14 strict (2) 143:24
Société (2) 78:5 102:3 St (27) 5:22 8:15 23:3 153:20
sold (4) 86:24 87:5 28:4 34:21 35:7,18 strictly (2) 143:25
140:2,5 39:12 42:21 49:8 144:5
solicitors (1) 71:5 50:8 54:1 59:14 Stroilov (23) 1:6 40:24
solution (1) 139:7 60:23 62:12 64:23 46:6,12 53:1 92:14
somebody (7) 52:1 67:16 69:11,16 93:12,18,25 94:3,6
59:1,1 61:13 66:11 71:6 87:14 88:1 94:9,18 95:20
75:20 82:24 124:2,19 126:6 96:11,25 100:23
soon (2) 137:13 138:3 142:14 141:22 144:3
146:15 stage (15) 6:12 29:4 145:24 148:10,22
sooner (1) 148:14 52:14,15,20 53:22 154:3
sorry (40) 15:15,19,24 56:20 71:13 72:7 Stroilov’s (2) 95:1
17:5 19:12 20:15 80:18 87:23,25 146:16
23:12,24 25:25 142:23 143:12,18 strong (2) 40:8,14
28:18,24 29:18,19 Stalevskaya (3) 92:15 structure (1) 74:17
30:22 33:24 43:10 93:2,14 struggle (1) 90:25
45:5 47:18 51:10 stamp (1) 30:21 studied (3) 5:12 6:12
51:15 53:8 55:20 stand (3) 1:20 42:19 7:2
55:22 57:18 58:2 148:2 studies (3) 4:9 8:12
60:16 77:22 79:18 standard (1) 126:8 64:1
81:11 83:13 84:6 standards (7) 4:18,21 study (11) 4:6,10,11
84:23 90:4 100:21 5:24 6:1,18 7:7,14 4:17 5:1,5,5,9,11
101:16 128:22 start (9) 3:23 4:16 6:20 64:7
135:4 147:7 152:16 25:14 147:22 148:9 studying (2) 5:21 6:15
154:6 148:12,16,17,20 style (1) 40:11
sort (9) 5:13 6:1 8:1 started (4) 10:17 73:8 sub (1) 36:6
22:2,8 65:16 84:21 98:6 124:1 subject (3) 5:3 143:23
102:6 144:1 starting (5) 22:19,19 146:24
sorts (3) 14:8 21:18 25:13 78:14 126:12 submission (3) 95:16
123:25 starts (4) 2:5 29:16,20 147:21 152:3
sound (1) 78:10 33:16 subparagraph (1) 65:3
source (3) 85:23,25 state (6) 5:22 20:3 subparagraphs (1)
151:14 57:20 91:19 102:19 65:10
sources (2) 78:11 86:2 136:13 subsequently (1)
south (1) 126:15 stated (2) 56:20 136:15
speak (4) 96:14 150:15 substantive (2) 150:3
100:20 136:17 statement (47) 2:13 150:18
144:2 2:16 3:3,12,22 11:1 suddenly (1) 150:22
speaker (1) 71:20 12:11,24 13:13 suffices (1) 133:15
speaking (4) 3:11 7:12 14:10 15:7 16:17 sufficient (6) 1:14
14:23 136:3 22:10 24:12 27:17 45:1 64:4 67:7
special (2) 20:6 29:15 33:2 53:20 74:23 101:10
140:13 54:24 55:17 56:16 suggest (7) 5:11 39:15
specialised (3) 4:9,11 56:18,22 57:25 61:12 62:2,15
7:2 58:9,11 60:20 64:20 70:18
specialist (2) 8:23 64:11 78:25 80:2 suggested (2) 131:23
84:5 85:6 123:11 124:13 146:19
specific (12) 15:11 125:3 127:13 128:3 suggesting (1) 35:24
68:3,5,6,14 71:23 135:23 136:14 summer (1) 127:24
72:1 83:1 85:1 149:18,25 151:1,3 summoned (2) 98:25
124:15 138:18,19 151:19 152:8 153:4 124:5
specifically (1) 86:22 153:13,25 sums (2) 132:24
specimens (1) 87:9 statements (5) 22:21 133:21
speculate (3) 69:21 78:24 150:8 151:25 supplemental (1)
72:17 77:2 153:10 149:25
speed (3) 90:17 127:4 states (1) 134:11 support (4) 40:8,15
127:6 stay (1) 125:23 88:8 128:12
spend (9) 125:13,25 sticking (1) 75:13 supports (1) 53:21
126:3,6,8 127:1,22 stole (1) 140:2 suppose (1) 86:1
127:24 147:19 stood (1) 97:15 sure (27) 3:2 4:22
spent (6) 8:21 13:14 stop (3) 50:2 69:1 7:13 16:11 23:12
64:4 127:22 137:2 75:16 30:14 36:8 42:6,17
137:7 stopped (3) 6:14,23 43:5 47:14,15 50:3
spilling (1) 147:9 72:13 52:18 66:20 94:16
split (1) 98:16 story (1) 90:21 94:24 100:5,20

133:2 135:14 144:8 146:12 148:25 150:17 151:1 152:12

surname (8) 27:7,8,9 74:4 129:18,23 133:16,17

surnames (2) 26:17 139:5

surprising (1) 136:6 surrounding (1)

126:12 suspicious (1) 77:5 swear (1) 1:4 swore (1) 3:6 sworn (3) 1:19 3:10

21:16 synopsis (1) 30:9 system (1) 123:23

T

table (10) 40:24 41:16 41:17 44:17,17,19 45:5,11 46:2,8

take (26) 19:10 22:16 30:12 32:22 34:7 44:4,6 47:4,7,13 48:8 55:15 63:8 64:10 71:19 81:21 92:24 94:24 96:24 136:19 137:15 139:9 142:22 153:4 153:7 154:25

taken (12) 2:2 20:19 31:17 33:8 53:21 63:15 69:10 76:25 123:22 134:8 150:2 153:23

takes (1) 146:24 talk (1) 100:22 talking (8) 6:1 37:16

40:3 75:21 85:8 91:16 97:25 152:7

talks (1) 15:21 Tarasova (11) 23:7

24:8,11,12,17,18 25:17 80:11,15,17 81:9

task (1) 154:9

taught (2) 4:17 131:16 tax (7) 10:8 18:10

27:15 28:8 73:22 75:1 76:9

taxes (1) 10:2 technical (1) 154:7 tell (15) 2:23 6:8 16:1

18:23 19:14,19 25:12 26:7 54:7 57:8 90:21 100:9 138:12,17 144:6

tells (1) 128:14 ten (1) 60:7 term (1) 80:5

Terminal (4) 86:7 90:4 93:5 94:11

terminated (1) 72:23 terms (6) 54:17 64:5 84:22 133:11,12

151:15 terribly (1) 45:5 territory (1) 135:20 tertium (1) 61:15 tests (2) 6:4,5

text (1) 41:22 textbooks (1) 5:8 thank (31) 12:9 14:24

24:6 29:23 32:19 32:23 34:4 46:23

47:14 60:8 64:13 64:14 85:4 95:13 102:24 128:18,19 140:20,24 141:5,5 141:7,8,12,12 154:14,15,20,22 155:2,2

theoretical (3) 5:18

6:5,10

theory (5) 4:19,20,24 5:1,9

thereabouts (2) 73:25 83:10

thing (15) 1:4 2:25 7:17,20 9:15 23:16 23:19,19 24:10 58:3 63:24 70:10 94:6 102:6 149:25

things (20) 5:20 10:7 10:8,9,15 16:10 22:8 32:5 36:16,19 40:22 42:19 48:5 71:17,18 127:6 132:8 141:2 142:22 148:2

think (145) 1:4 2:21 3:6,7,8,10 5:25 6:22 7:11,12 8:21 9:21 11:8,10 12:9 16:25 17:1,11,12 21:20 22:11 30:12 30:17 32:18,18 34:10 35:9 36:7,21 36:22 37:6,9 38:15 38:18,19,25 39:19 39:20,21 46:1,2,3,6 46:6,8,10 47:5,7,8 47:23 48:19 51:1 51:18,23 52:13,21 53:9,9 54:5,6 55:10 55:19 58:5,19 60:1 60:5,12,13 61:9,19 62:7 64:3,10,16 65:2 67:4,4,21 72:11,18 73:3,5,8 74:10 75:8,12,15 75:15 79:7 80:21 80:25 81:12,13,18 83:2 85:9 86:12,23 87:25 89:10 91:4 91:22,24 92:11,21 92:22 94:6,21 96:16,18 97:9 98:1 98:4 99:22 101:9 102:2 124:6,8 126:17 127:12,21 129:5,13 134:6 135:11 137:6,23 138:2,19 139:22 141:17,17,19,25 142:3,7,9,16 146:23 147:5,8 150:25 151:23 152:13,20

thinking (1) 54:23 third (3) 21:3 61:16

127:21 thoroughly (1) 32:17 thought (8) 32:5

56:25 57:11,23 79:9 87:4 149:12 149:20

threat (5) 136:4 137:10,19,20,25

threats (1) 98:22 three (19) 4:9 7:11

8:21 13:19,20,24 19:23 53:11 54:10 74:2 89:21 98:20

125:24 127:17,17 137:2 140:3 146:25 147:1

Thursday (2) 148:16 148:17

time (51) 8:16 11:10 11:13 12:20 17:25 19:22,24 20:2,3,5,6 20:9,19 24:9 26:9 35:14 38:18 45:1 48:2 49:22 59:22 60:7 61:10 64:4 70:7 73:9,25 74:6 74:12,12 76:21,21 82:21 88:23 124:4 124:7,24 125:13 127:25,25 129:21 131:11 132:8 136:10 137:7 138:22 139:3,22,23 147:25 149:2

times (7) 13:24,24 15:13 54:18 89:21 93:10 153:23

timetable (1) 146:1 tired (1) 100:8 today (21) 2:17 8:13

21:11 27:11 40:16 53:2 55:3,6 60:21 61:21 62:8 63:13 66:2 67:22 70:4 71:14 75:2 133:18 134:7 140:25 148:13

today’s (2) 75:15 129:2

told (5) 23:14 99:16 130:15 139:11 146:15

tomorrow (1) 133:19 top (7) 56:4 58:12

65:5 80:4 81:12,17 91:25

total (2) 4:10 83:16 totally (1) 43:17 touching (1) 141:15 tourist (1) 126:8 trail (1) 150:8

train (2) 149:7,9 training (1) 64:1 transacted (1) 43:6 transaction (7) 84:8

88:9,10 94:12 131:9 135:5,18

transactional (1)

131:8 transactions (3) 94:15

134:2,3 transcript (5) 32:12

60:1 92:9 129:2 144:4

transfer (7) 84:8 86:6 86:13 88:16 91:10 93:4 135:10

translate (1) 45:2 translated (3) 14:11

14:15,20 translating (1) 48:6 translation (10) 2:3

3:24 16:22 22:14 22:17 33:18 49:4 134:9 135:25 142:2

translators (2) 1:25 131:3

transpired (1) 31:24 trial (7) 141:18 142:17 142:18,19 143:1

150:4 151:4 tribunal (1) 22:18

trick (1) 54:4

tried (4) 50:25 51:19 66:18 130:18

trouble (1) 154:6 troubling (1) 57:16 true (19) 2:15,20 3:4

18:1,3 21:10 26:25 55:3,6 62:5,18 97:21 128:7 129:7 131:4 133:10 149:23 150:25 152:9

trust (7) 27:13 45:17 45:19 68:18,19,20 131:2

trusted (3) 68:11 130:7,10

truth (4) 26:10 54:7 149:16 154:1

try (11) 17:2,4 31:1 33:20 42:18 57:17 100:2 132:18 141:6 147:24,24

trying (14) 22:7 23:20 24:3 26:10 30:20 30:24 47:15 54:4 55:4,4 95:9 132:16 143:6 146:17

Tuesday (3) 146:20 147:13 148:14

tuition (1) 5:24 turn (3) 81:1 143:10

143:11 turned (1) 32:21

turning (2) 67:12 81:3 twice (4) 27:14 78:19

135:7,7

two (32) 4:8 8:2 10:12 10:13 28:7 36:16 36:19 40:21 55:14 64:5 65:12,13 68:6 74:1 76:18,24 78:6 78:10 80:21 81:8 89:21 90:13 100:17 128:21 139:2,19 141:23 147:16,19 147:23 148:17,25

type (4) 76:7,11 134:20 135:20

U

UA (1) 87:21 ultimately (3) 14:18
17:6 31:2 unable (1) 98:17 unclear (2) 32:17

131:11

undergo (1) 8:12 understand (74) 1:12

3:14 4:22 6:19 7:4 9:2,4 10:20 15:12 15:18,25 16:7,11 20:1 21:25 22:6 24:2 26:11,11 28:25 30:11 32:8 32:18,18 35:20 36:8 42:6,17,18 43:1 44:7 45:12 46:13,13,14,23 48:12 49:13,14,25 51:14 55:2,20 57:4 57:7,16,19 58:8 63:18,21 64:4 67:11,13,13 71:12 74:21 77:24 85:20 90:20 94:16 96:18 96:22 130:15 133:10,15 141:7

Opus 2 International transcripts@opus2.com
Official Court Reporters +44 (0)20 3008 5900

165

February 26, 2016 Day 17 — Redacted

143:13 144:7,11 146:4 148:24 151:2 154:9,25

understandable (2)

77:9 150:12 understanding (9) 1:7

55:11 85:12 86:19 86:20 96:13 133:24 142:10 143:24

understands (1)

128:15 understood (12)

15:15 35:3,3 42:15 45:11 48:10 64:1 86:13 98:3 133:3,9 134:3

undertaken (3) 133:7 149:6,9

undertook (1) 4:12 unfair (2) 47:5 54:3 unfortunately (12) 9:8

11:15 16:25 27:25 56:3,19 74:3 81:16 98:2 99:4,9 139:1

unified (1) 23:6 Union (1) 125:23 unique (2) 138:2,3 university (5) 5:18,23

6:10,10 11:3 unpaid (1) 13:4 unpleasant (2) 124:21

136:24

unsung (2) 154:23,24 update (2) 143:19,22 updating (1) 149:11 upset (1) 136:24

use (3) 5:17 25:3 147:24

usual (1) 151:16 usually (5) 10:7,10 68:10 127:22

136:18

V

valid (1) 72:23 value (1) 78:22 various (13) 24:3

29:10 30:6 31:17 43:12 47:22 86:2 89:4,14 92:15 102:4 136:10 140:6

Vasiliev (2) 77:1 86:23 vast (1) 54:11

VD (1) 42:11 venture (1) 68:23 veracity (2) 41:21,22 verify (2) 68:19,21 versa (1) 37:24 version (5) 3:23 21:4

25:5 32:1,4 versions (5) 30:10,15

30:18,25 32:3 vexed (1) 143:1 vice (1) 37:24 video (1) 142:5 videolink (1) 53:12 view (7) 13:10 28:21

63:5 72:25 77:10 92:25 146:1

viewed (1) 150:19 viewpoint (1) 26:24 views (1) 43:12 vigorous (1) 95:5 vii (1) 40:6

visa (1) 126:9

visit (2) 127:25 135:19 visited (4) 13:23

89:21 135:7,11

visits (1) 135:21 Vitaly (14) 33:8 43:18
46:21 63:3 69:1 73:11 75:6,24 76:14 97:15 124:12 125:5 128:5 137:9

volume (1) 53:13 Voropaev (2) 12:8,22 vote (1) 69:5 vouching (1) 35:21 Vyborg (36) 17:7,13

17:19 18:1,5,21,25 19:3,8,14,16,21 20:9 21:14,18,22 22:3,9 23:4 28:7,9 48:16 49:7 71:7 72:3,8 73:6,7 74:1 74:5,13,15 76:21 78:8,9 79:4

W

waft (2) 154:24,24 wages (1) 77:7 wait (1) 141:11 want (38) 2:23 11:18

22:15 24:1 27:4 28:12 30:13 32:9 37:4 40:16 44:9,10 46:19 47:14 50:4 57:11,16 62:24 69:21 72:14 79:19 86:4 88:24 98:18 99:13,24 101:16,24 129:15,16,21 130:1 135:14 141:7 150:6 151:6,21 152:6

wanted (12) 31:5 34:7 42:25 51:4 68:22 96:21 99:10 125:13 125:21 126:4,8 128:25

wants (2) 1:12 32:13 warned (1) 143:2 warning (1) 95:13 wasn’t (9) 14:1 52:17

89:15 96:1 124:11 127:1,16 136:25 137:11

water (1) 1:25

way (40) 5:4 6:2 8:20 12:3 15:2,9 18:12 22:4,18 24:20 26:12,22 31:11 36:10 37:11 38:1,7 48:21 49:18 54:8 59:17 66:7,10 67:19 70:21 71:13 73:11 83:7 94:19 123:23 124:16,24 127:23 130:2 131:1 133:4 136:20 143:5 151:16 152:4

we’ve (1) 132:13 Wednesday (1) 147:8 week (10) 126:25

127:23 128:1 136:17 142:5 147:19,22,23 148:13,14

week’s (1) 146:1 weekend (4) 128:1 141:21 148:18

155:4 weeks (1) 28:7

welcome (1) 146:15 went (7) 6:23 7:24 11:3 14:2 27:14

65:4 68:12

weren’t (4) 59:13 64:17 66:22 88:1
western (5) 86:7 90:4 93:5 94:11 125:19 wherefores (1) 47:11

whilst (2) 143:4 149:13

wholly (1) 14:16 whys (1) 47:11 wider (1) 102:11 wife (13) 14:19,25

16:18 18:9,9,10 20:4 23:7,18 26:2 35:25 36:3 68:14

wife’s (3) 18:11 34:5 50:21

wind (2) 148:15 152:4 wish (7) 2:22 3:15

47:5 99:15 100:1 145:24,25

withdraw (1) 28:16 withdrew (1) 141:13 Withers (8) 71:4,8,25

74:11 76:17 77:14 77:18 153:11

witness (54) 2:12 3:3 3:12,22 10:25 12:23 14:10,12 16:17 29:15 30:9 30:12 31:14 33:2 47:8,15,16 53:20 54:24 55:17 56:16 56:18,21 57:25 58:9,11 60:20 64:10 84:19 85:5 92:10,21,23 93:8 94:21 95:17 100:19 123:11 125:3 127:13 128:2 135:23 136:14 141:13 143:7 146:7 146:8,13 148:9 149:18 152:8,13 153:10,25

witness’s (1) 20:21 witnesses (10) 94:10 142:8,8 143:8

146:2 147:1,13,19 147:20,22

witnessing (1) 134:23 wonder (14) 11:16

16:20 18:23 20:12 25:5 29:14,25 34:13 37:3 52:7 61:17 64:8 71:3 129:1

wondered (1) 129:10 word (9) 16:4,6,7

25:13 45:3,3 55:23 129:19,19

words (8) 5:6,13 6:2 24:15 37:11 53:24 91:8 124:24

work (18) 4:16 6:9 9:23 11:3,13 13:13 13:18 18:21 19:8 20:7 21:18 48:7 98:10 136:20 137:16 141:8 143:8 154:23

worked (5) 6:21 8:3 13:11,22 131:15

working (7) 5:20 6:15 6:23 10:6 126:4,24 154:16

works (2) 18:8 124:16 world (1) 75:6 worried (1) 37:4 worries (1) 139:7

worry (1) 42:24 wouldn’t (17) 8:20,22
9:23 48:8 51:17 58:25 65:20 66:13 80:4 84:12 88:18 88:22 89:11 123:18 138:18 139:1 152:2

write (1) 76:6 writers (1) 60:1 written (1) 69:24 wrong (9) 11:25 31:15

43:17,18 55:8,10 55:11 62:25 89:3 wrote (4) 40:9,15 48:5

66:5

X

Y

YA (1) 42:11 year (9) 7:23 8:2
12:14 13:18 41:15 43:8 78:14 126:1 127:21

years (19) 4:6,9,10 6:15 7:11 8:22 12:22 13:19 19:23 27:12 53:11 54:10 66:3 71:21 74:2,2 78:7,10 84:16

years’ (2) 4:8,17 yesterday (1) 154:17 Yuri (1) 12:8

Z

0

0.01 (1) 10:22 03.08.2002 (1) 134:11

1

1 (6) 90:3 139:15,16 139:18 151:20 156:3

1,600 (1) 78:19

1,700 (1) 78:19

1.03 (1) 101:1

1.33 (1) 101:3

1.36 (1) 102:25

10 (4) 14:18 15:22 16:14 150:8

10,000 (1) 87:7

10.30 (2) 154:8 155:7

100 (2) 37:12 70:13

103 (1) 156:5

11.37 (1) 60:9

11.50 (1) 60:11

110 (3) 35:13,22 36:10

12 (15) 29:16,20,24 33:1,12 54:25 55:6 55:16,25 56:11 57:24 58:9 60:19 65:4,11

123 (1) 156:6

128 (1) 156:7

13 (3) 27:12 64:11,15

130 (3) 69:11,15 70:23

130,000 (2) 78:8,10 133/06 (1) 40:1

14 (8) 2:9 18:14 19:1 21:5,7 22:4 65:3,10

144 (1) 156:8

145 (4) 62:12 63:6 156:9,10

15 (11) 29:21,25

64:11,15 65:3,10 99:12,16,19 100:1 100:8

16 (1) 125:2

17 (2) 129:4,6

18 (1) 131:14

18.55 (1) 100:4

19 (1) 129:4

1996 (1) 98:12

1st (3) 146:20 147:4,5

2

2 (3) 89:24 90:7 151:20
2.00 (1) 100:2
2.10 (1) 123:8
2.30 (1) 100:16
2.50 (1) 144:16
2.52 (1) 145:20
2/1 (1) 2:5
2/9 (2) 2:5,5
20 (5) 17:17 89:10 99:12 100:9 150:8

20,000 (1) 87:7

2001 (3) 7:13 14:16
23:5
2003 (6) 6:22 13:3,13
13:22 14:7,7
2004 (1) 35:10
2005 (9) 35:9 66:2
98:4 123:17 124:5 124:10,13,21 126:12

2006 (11) 34:22 35:8 38:18 39:1,18 40:1 42:2 130:25 131:10 131:23 136:22

2007 (7) 12:14,17
66:2 125:5,17
126:14 137:1
2008 (12) 12:12 60:24
61:6 66:2 69:12 70:6 94:12 126:20 136:7 137:1,1 138:25

2009 (19) 81:15 83:5 83:6 84:15 87:14 87:25 92:1 97:11 98:3 127:4,9,14,21 136:2 137:9 139:9 139:14,15,18

2010 (1) 140:11

2012 (16) 3:7,10 13:3 13:9 17:17,22 19:22 20:10 21:16 21:18,19 22:1,10 22:15 23:16 76:23

2012/2013 (1) 48:3

2013 (9) 21:19,20,24 21:24 22:12 23:16 43:8 72:12 73:9

2013/2014 (1) 74:21

2014 (5) 73:20,20 78:12,17 79:2 2015 (8) 3:11 71:5

73:20 74:25 76:8 78:12,14,14

2016 (3) 1:1 142:2 155:8

22 (1) 126:14

23 (6) 71:5 85:6,11 87:14 91:19,25

24 (1) 142:2 24/7 (1) 71:21

25 (8) 12:12 42:1,16 42:20 123:11,13 124:1,8

26 (5) 1:1 42:22 129:3

135:23 137:18
27 (6) 14:10,13 15:12
15:20 16:8 42:22
28 (4) 42:9,23 69:12
127:12
29 (1) 155:8
29th (1) 147:3

3

3 (4) 89:24 93:13 151:20 156:4
3,000 (6) 75:8,12,15 76:16 79:8,10
3,200 (1) 75:1
3,300 (1) 78:13
3.00 (2) 45:18,20
3.06 (1) 155:6
30 (3) 40:1 42:2 60:24
300 (2) 58:2 59:5
31 (1) 83:5
310 (2) 48:24 49:20
33 (2) 97:6,13
34 (2) 86:3,10
342 (1) 52:12
35 (2) 86:10,12
38 (1) 93:1
39 (2) 93:2,12

4
4 (1) 151:20
46 (5) 128:2 149:15
149:21 151:18
152:8
4th (1) 148:12

5

5 (4) 3:22,25 4:3 17:5

50 (2) 17:7 150:8
50/50 (1) 98:16

6

6 (8) 3:22,25 10:25

12:23 16:23 17:10
93:18 151:20
6.55 (1) 100:5

61 (1) 11:20

7

71,000 (1) 17:15

73 (1) 34:2
74 (2) 34:2 93:23
75 (1) 93:23
76 (1) 93:23
77 (1) 93:23

8
81 (2) 95:11,12

9

9 (2) 91:22 92:8

9,900 (1) 90:5

9.45 (1) 1:2

90 (4) 7:21 14:18 15:21 72:9

91,000 (1) 17:15

950 (1) 83:10

97 (1) 138:6

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