Day 4

Bank St Petersburg v Vitaly Arkhangelsky [Master]

Day 4

Contents

Bank St Petersburg v Vitaly Day 4
Arkhangelsky [Master]

1 :1 Tuesday, 2 February 2016
2 (10.00 am)
3 Housekeeping

4 MR JUSTICE HILDYARD: Yes, good morning. I am sorry to have
5 kept you.

6 MR STROILOV: May it please your Lordship.

7 I wonder, my Lord, I think — let me start again.

8 I thought you wanted to say a few words to

9 Mr Arkhangelsky. As you can see, he is here via

10 videolink, but perhaps now is not the best time.

11 MR JUSTICE HILDYARD: Well, Mr Arkhangelsky, I’m pleased to

12 see you, and there are some words that I do want to

13 address to you, but I think in deference to

14 the cross-examination, I would prefer to do so once it

15 is concluded, and so let us carry on for the present.

16 Thank you, though.

17 MR ARKHANGELSKY: Okay, thank you. Good morning.

18 MR STROILOV: Also, my Lord, having looked at the

19 transcript, I have discovered two errors I would like to

20 correct now. I think in one place you will recall the

21 photographs of Western Terminal I have shown to

22 Mr Belykh yesterday. I think it is recorded that I said

23 they were contemporaneous. I don’t actually remember

24 saying that. It may have been my accent being misheard,

25 but I want to make it clear that these photographs are

2 :1 recent and not coming from 2009, or whenever, so
2 I apologise if it was my error or if it was my accent

3 which caused it.

4 Secondly, I think I said that I’m not going to

5 suggest that the Bank gave formal consent to cadastral

6 separation of Western Terminal. That’s not quite

7 correct. I am going to suggest that. I’m not

8 suggesting it was done by big credit committee or any

9 other body of which Mr Belykh was a member, but

10 I reserve the right to say that in due course.

11 My Lord, may I now continue with the questions?

12 MR JUSTICE HILDYARD: Yes, indeed.

13 MR ANDREI AKATOVICH BELYKH (Continued)

14 Cross-examination by MR STROILOV (Continued)

15 MR STROILOV: Mr Belykh, you will recall the point we

16 reached yesterday was discussing the decision of the big

17 credit committee not to extend the PetroLes — I beg

18 your pardon — to extend the PetroLes loan to whatever

19 date it was, we were trying to find out to what date; do

20 you recall that?

21 A. Sorry, could you please specify your question, whether

22 I recall our yesterday discussion or whether I recall

23 this decision of 2009?

24 Q. I mean yesterday’s cross-examination, you do remember

25 where we stopped?

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

3 :1 A. Well …
2 Q. I’m not talking about minor detail, but you remember the

3 subject matter?

4 A. The subject matter, yes, I remember.

5 Q. So what I am putting to you is that whatever was the

6 extension of capital repayment, interest was rolled up

7 to 28 June and not to 28 March. Do you accept that in

8 the light of the documents you have seen yesterday?

9 A. Well, as I have explained yesterday, if the main

10 principal is repaid as it should be according to this

11 decision before, then practically there is no difference

12 on the calculation of the interest, as long as the loan

13 is zero exposure, so that there might be some different

14 interpretation, but I don’t think that in essence this

15 decision was wrong.

16 Q. And the documents you have seen yesterday do not

17 persuade you that, actually, your decision was to extend

18 the loan until after, until 28 June or after?

19 A. No.

20 Q. Because I want to suggest to you, Mr Belykh, that there

21 was a special reason why the loan had to be extended to

22 28 June 2009 or later, but not before; and the reason

23 was that on 25 December 2008 there was a meeting between

24 Mr Savelyev and Mr Arkhangelsky where Mr Savelyev

25 promised a six-month moratorium on all payments. Do you

4 :1 agree with that?
2 A. Well, I was not present at that meeting and I was not

3 aware of the terms of moratorium, therefore it’s

4 difficult for me to make a judgment. What I’m saying is

5 that our decision was to extend the loan until 26 March

6 so that two loans would coincide in the time of

7 expiring, and then during this short period there might

8 be some additional information to be considered. That’s

9 all.

10 Q. I am suggesting that at the time you knew about the

11 moratorium, and that is where the date, 26 June, comes

12 from.

13 A. I didn’t know at that time.

14 Q. Could we now look at {D117/1763/1}, if we can call it on

15 one screen, and then perhaps the Russian version of that

16 will be the second page, but if we could have it on the

17 other screen, the next page in the same tab?

18 MR ARKHANGELSKY: Your Lordship, I’m sorry, may I just

19 intervene for the minute. Is it somehow possible to see

20 Mr Belykh, because I just see the lawyers of the Bank

21 and I want to see the face of Mr Belykh, if possible?

22 MR JUSTICE HILDYARD: I do not know whether that is possible

23 at the present time. I understand the request, but we

24 will see what we can do, if not for this witness, then

25 for subsequent witnesses. I don’t know how the cameras

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Arkhangelsky [Master]

5 :1 are struck.
2 MR LORD: We have been trying, my Lord, to see how we can

3 adjust the technology so that Mr Arkhangelsky can see

4 the witness. It is not proving to be terribly

5 straightforward and we are considering whether we are

6 going to have to relocate the witness to some other bit

7 of the court unless we can move the camera. I know it

8 is not terribly satisfactory, but, for example, another

9 witness may have to go back there (indicates). It is

10 not ideal but it may be what we have to do.

11 A. In any case, I’m not deliberately turning my back to

12 Mr Arkhangelsky. It is just a point of technology.

13 MR JUSTICE HILDYARD: Yes, it is, of course. Thank you.

14 Well, Mr Arkhangelsky, I am afraid there is nothing

15 we can do without a great delay and possible lack of

16 success at the end of that.

17 MR ARKHANGELSKY: Okay, thank you. Okay, thanks.

18 MR STROILOV: So if we could have the Russian version on

19 screen. {D117/1763/2}. So, Mr Belykh, you see this is

20 an e-mail exchange between you and Mr Arkhangelsky

21 dated — I beg your pardon. I think it is not quite

22 complete. Yes, that’s the e-mail exchange dated

23 7 April 2009.

24 Do you recall that e-mail exchange?

25 A. Yes.

6 :1 Q. Now, I think, and I don’t mean to criticise whoever has
2 translated it, but since we are both bilingual here and

3 nuance is important, perhaps you could confirm that what

4 you see on the Russian text, rather than — in a way,

5 Mr Arkhangelsky’s e-mail puts it in rather stronger

6 terms. He says:

7 «It is contrary to the agreements we’ve reached.»

8 He is suggesting the Bank has breached the

9 agreement, isn’t he?

10 A. Well, I’m not considering myself being bilingual, and

11 therefore I think that there might be different

12 interpretation how to translate the Russian word, but in

13 general terms, Mr Arkhangelsky says that, contrary to

14 certain agreements, or despite all agreements. For me

15 it is basically the same. Yes, he thinks that certain

16 agreements have been violated.

17 Q. That’s right. Well, I put it to you, Mr Belykh, that on

18 all the facts we know, the only agreement he may be

19 referring to is the agreement on the moratorium.

20 A. That I don’t know. I would tell you a bit of more

21 detail of the wrong translation here. In the Russian

22 text there is used the word «kalmar» which was

23 translated as «calamari», which is definitely not the

24 case. Calamari is a special equipment for the port and

25 it is forklifting equipment, therefore this means that

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Arkhangelsky [Master]

7 :1 we have had certain discussions with Mr Arkhangelsky
2 concerning potential development of his business and

3 I was, at that time, quite thinking of being possible to

4 help him in his businesses, and I didn’t know of any

5 breaches of any agreement at that time. It was quite

6 strange for me to receive that e-mail.

7 Q. What did you understand him to refer to if not

8 moratorium?

9 A. I understand that he has some emotional attitude to

10 the matter and that’s all. I didn’t understand that in

11 the way you interpret it.

12 Q. How did you understand the reference to breaching, or

13 violating the agreement, as you put it?

14 A. Well, as long as I didn’t know of any breach of any

15 agreement, for me that was not clear, but it seemed to

16 be not the most important point. The important point

17 was, for me, that Mr Arkhangelsky refuses to talk to me,

18 and that was sort of a strange thing, but okay, he is

19 a client, and that’s his right to refuse to talk with

20 a bank officer.

21 I was not considering it as an insult, but that was

22 not very pleasant for me. Okay, that was his point.

23 Q. Now, Mr Belykh, if you are accused of breaching

24 an agreement, surely you want at least to know what the

25 person means?

8 :1 A. Well, but he refused to talk to me and refused to
2 explain these things, so how could I know what he

3 thinks?

4 Q. Right, Mr Belykh.

5 MR JUSTICE HILDYARD: I have got lost in the sequence. The

6 second, or what appears to be the second mentioned

7 calamari exchange, does that precede or come after

8 the —

9 MR STROILOV: That’s after the alleged default and the Bank

10 started —

11 MR JUSTICE HILDYARD: I know, but which comes first,

12 the «and what is the point» e-mail, or «it would not be

13 bad to get together» e-mail?

14 MR STROILOV: The e-mail you see below is from Mr Belykh and

15 that comes first and then there is a response from

16 Mr Arkhangelsky, «What is the point …»

17 So you have the latest at the top.

18 MR JUSTICE HILDYARD: Thank you.

19 MR STROILOV: Right, if we could now — I am sorry slightly

20 to go around in subjects, but I have discovered I forgot

21 to put one document to Mr Belykh which I wanted to put

22 on something we discussed yesterday. If we could have

23 {D98/1256/1} on one screen, and then simultaneously on

24 the other, page {D98/1256/2}, the next page. I am

25 afraid, once again, it is a slightly inaccurate

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

9 :1 translation. The reference in the bottom line of this
2 e-mail, the reference to «surveying» is not quite

3 accurate. The Russian word is «mezhevaniye» Russian

4 word», and I think Mr Belykh will agree that this is

5 a reference to the cadastral separation we talked about;

6 is that correct, Mr Belykh?

7 A. Well, if we want to be absolutely correct, my Lord, this

8 means that there is a preparation for cadastral

9 separation.

10 Q. That’s right.

11 A. Just to be absolutely accurate.

12 Q. Thank you, Mr Belykh. Then you can see that Ms Mironova

13 is writing to you and says that the Bank has given its

14 consent for these actions in the same sentence. Do you

15 see that?

16 A. Yes, I see that.

17 Q. And do you now recall anything about the matter?

18 A. Well, as I have said yesterday, I do not remember these

19 details, but I have no reason to think that Ms Mironova

20 was not correct in her statement.

21 Q. Right. Thank you.

22 Now, just briefly to come back to the subject of

23 what you call your investigation into valuations.

24 I think you will accept that Lair is a well known and

25 reputable Russian valuer?

10 :1 A. It was considered to be reputable, yes.
2 Q. But it isn’t considered reputable anymore?

3 A. I don’t think so, as my opinion.

4 Q. Well, I understand you are disappointed with them, but

5 they are, nevertheless, generally considered to be among

6 the top Russian valuation providers; isn’t that right?

7 A. I don’t know.

8 Mr Stroilov yesterday I asked for a possibility to

9 explain briefly my attitude to this matter, if that

10 might be one point —

11 Q. Perhaps it will save time if I explain briefly. We

12 appreciate you have your opinion about these valuations,

13 however, unless I’m very mistaken, my Lord is not going

14 to take your opinion into account.

15 A. Okay.

16 Q. Because the Bank has chosen a different expert, rightly

17 or wrongly. So, don’t worry, the Bank’s point of view

18 will be presented to this court, but unfortunately, you

19 are here to tell about the facts.

20 MR LORD: Sorry, my Lord, he was asked to give an opinion

21 about Lair, and as he began to explain why he had

22 a view, Mr Stroilov wants to choke him off so he doesn’t

23 explain. That is impermissible, in my submission.

24 MR JUSTICE HILDYARD: Well, Mr Stroilov, as I explained, you

25 devalue the effect of your cross-examination if it

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

11 :1 appears that you choke off witnesses in answering
2 questions that you have asked, or for them to set their

3 answers in context within reason.

4 I want to emphasise that I do not, by saying this,

5 seek to encourage witnesses to give long context before

6 they answer the question, but it seems to me that

7 Mr Belykh has not, as a matter of fact, done that in

8 the course of his examination, hasn’t demonstrated

9 propensity to do that so far, and ought to be allowed to

10 give a short explanation of the context that he wished

11 to supply to his previous answer.

12 MR STROILOV: I’m grateful.

13 So, Mr Belykh, you have heard my Lord, so please go

14 ahead with it.

15 A. My Lord, I will try to be brief. The point of

16 a valuation is not as difficult or complicated as it is

17 considered sometimes, and the main point is that any

18 object is valued as the possibility to sell it or to

19 have a market price; and I believe that Mr Arkhangelsky,

20 and maybe some experts from Lair, were sincere in

21 the idea that if the business will be growing as fast as

22 they were thinking, then, of course, there might be some

23 more value in that land or in those buildings, or

24 whatever.

25 However, as long as the crisis existed, the value

12 :1 was definitely different, plus there were some
2 assumptions concerning the development of that plot,

3 assumptions related to my point briefly explained in

4 number 50 in my statement, that with a very small

5 investment, very briefly that would generate great

6 income, and that seemed to be not realistic from the

7 economic point of view.

8 Of course, our people who were checking the

9 existence of the plot and the existence of the objects

10 there, from the point of view of the existence of it,

11 were satisfied, but if you were thinking of economic

12 side, if you were thinking of the real value, that is

13 a bit different matter. That’s the main brief thing to

14 be done, and in Russia it is more complicated as long as

15 we do not have this long tradition, as was in

16 the Doomsday Book, for example, nearly 1,000 years in

17 England, so it is complicated, but it is not as

18 complicated as it could be viewed sometimes.

19 MR JUSTICE HILDYARD: I don’t wish to interrupt you,

20 Mr Stroilov, but I think what you are saying, as is

21 obvious, is that a valuation is only as good as the

22 assumptions on which it is based?

23 A. Yes.

24 MR JUSTICE HILDYARD: But those assumptions were known to,

25 or at least readable by, the Bank; yes, in the Lair

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

13 :1 valuation? You could see what assumptions they were
2 making?

3 A. They were — in that report, yes.

4 MR JUSTICE HILDYARD: Yes, and, second, Lair was, at that

5 time, one of the Bank’s approved valuers; is that right?

6 A. Right.

7 MR JUSTICE HILDYARD: Yes.

8 MR STROILOV: I am grateful, my Lord.

9 I think, Mr Belykh, I want you to look at

10 Mr Arkhangelsky’s 19th witness statement. That’s at

11 {C1/9/2} I will ask you to read a particular passage,

12 or, rather, I will — that doesn’t seem to be the right

13 page. Page 2 — I beg your pardon. You will see

14 paragraph 7 near the bottom. So what Mr Arkhangelsky

15 says is that in all the lists of the top valuers, Lair

16 was always very near the top, and first in

17 St Petersburg; do you agree with that?

18 A. I don’t remember this list, frankly.

19 Q. What about the company you used as part of your

20 investigation, ADK; is that a well known valuer?

21 A. Well, I think it’s well known.

22 Q. Mr Arkhangelsky says here, and gives a link to

23 the published lists, it is not within the first 100.

24 A. Well, I was not checking these lists.

25 Q. Now, do you agree that these notes by ADK which you

14 :1 exhibit with your statements, they are not actually
2 valuation reports, are they?

3 A. I think they are valuation reports.

4 Q. ADK reviews which you exhibit to your statements: Would

5 you describe them as valuation reports?

6 A. Well, it depends on what you consider as valuation

7 report. I have seen their comments but, again, in

8 different situation, in different crisis, all rates are

9 strange, sometimes, and are changed sometimes. I was

10 based in my attitude on my own calculations which I have

11 made, so I don’t think that it was important for me to

12 see or to go deeply in ADK report. That was the

13 position of the Bank to consider them, and I was only

14 partly involved in this matter.

15 Q. Perhaps it is easier if you look at the one for Western

16 Terminal. That’s at {D126/1991/3}. Just to be sure we

17 are talking about the same thing. Here is the note you

18 have exhibited, and I am not sure if you are in

19 a position to scroll down, Mr Belykh. Perhaps you can

20 be helped there. You will see if you — I am not

21 inviting a careful read of it, but if it can be scrolled

22 down a few seconds to page 4, then to page 5, and that’s

23 the end of it {D126/1991/4}, {D126/1991/5}.

24 So, Mr Belykh, what I am putting to you is that this

25 is not something anyone would call a valuation report,

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

15 :1 is it?
2 A. So what it is, then? This is a text concerning

3 a valuation of the plot, and it is signed by the person

4 whom I assume to be authorised to do these valuations,

5 so what’s wrong?

6 Q. I mean, I understand, Mr Belykh, that you told us

7 yesterday that you understand the valuations as such,

8 you have some knowledge of the subject.

9 A. Yes, I have some knowledge.

10 Q. So I think the valuation report is quite a clear

11 concept, and there are various requirements when you

12 have to submit a valuation report and when not, isn’t

13 it?

14 A. I do not understand what you are asking, sorry.

15 Q. Let me put it like that: if a client wants to pledge

16 something and brings you a piece of paper this long from

17 ADK, with these contents, would you accept it as

18 a valuation report?

19 A. I think that we are speaking now of certain

20 possibilities, and I don’t see the reason to discuss

21 them in such an abstract form. If a client comes to us

22 and brings us a valuation report, then we look at it and

23 consider whether it is acceptable or not, and that’s it.

24 And I’d like to mention that since that case,

25 exactly, we established our own department which makes

16 :1 checking of any valuation report.
2 Q. Yes, we have read that in your evidence. Thank you.

3 I understand that, be that as it may, after

4 receiving these ADK reviews and other matters you’ve

5 already discussed yesterday, for whatever reason, the

6 Bank became disappointed with Lair valuations?

7 A. Yes.

8 Q. Mr Belykh, I put it to you that what you call

9 an investigation into valuations wasn’t a genuine

10 investigation. The task you were given was to do what

11 you could — you were given certain conclusions and then

12 asked to try and find material to substantiate them.

13 Would that be a correct description of the work you have

14 done?

15 A. Of course not.

16 Q. Right. Anyway, was it your understanding that the Bank,

17 despite these disappointments, that you intended to sell

18 the pledge?

19 A. I don’t know.

20 Q. Was there any intention to obtain another full valuation

21 report for these assets?

22 A. I misheard: another?

23 Q. Another full valuation report —

24 A. Full? I mean not stupid, but complete, okay. I didn’t

25 understand what you are asking about.

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

17 :1 Well, look, I was involved in these discussions in
2 the capacity which I have described in my witness

3 statement, and that is what I know. Whether the Bank

4 might be interested in another report which would be

5 more complete than any other report, that I simply don’t

6 know.

7 Q. Now, if we could, perhaps —

8 MR JUSTICE HILDYARD: Can I, before we leave that page, take

9 advantage of your experience?

10 A. Yes, my Lord.

11 MR JUSTICE HILDYARD: It says, in English at any rate, in

12 the second sentence:

13 «The Reviewer finds the income capitalisation rate

14 of 13.3 per cent (indicated… [in what I take to be

15 the] Lair report page 78) extremely low. The

16 undercapitalisation results in the total overvalued

17 appraisal.»

18 Now, pausing there, that income capitalisation rate

19 appears to be one of the assumptions which form the

20 basis of the Lair report; is that right?

21 A. Well, I’m sorry, my Lord. Where are you reading on

22 this …?

23 MR JUSTICE HILDYARD: I’m sorry. Yes, would you like the

24 Russian version?

25 A. {D126/1991/5}?

18 :1 MR JUSTICE HILDYARD: Yes, page 5, I am sorry. I am reading
2 the actual second sentence.

3 A. The second:

4 «The Reviewer finds the income capitalisation

5 rate … extremely low.»

6 So your question, my Lord?

7 MR JUSTICE HILDYARD: That seems to be something which is

8 indicated in the Lair report. Is that an economic

9 analysis or is that a valuer’s analysis?

10 A. Yes.

11 MR JUSTICE HILDYARD: Economic?

12 A. Well, as you have said, correctly, that this indicator

13 is a part of the — is used in the calculation of

14 the final figure, and from this text I see that the

15 reviewer, or evaluator, if you wish, considers it as

16 being not correct; that there should be a different

17 figure and, as a result, the different final evaluation.

18 MR JUSTICE HILDYARD: Yes, but wouldn’t that income

19 capitalisation rate assumption be something that the

20 Bank would look very carefully at when deciding whether

21 to make a loan and on what terms?

22 A. Well, it should be.

23 MR JUSTICE HILDYARD: And, as a valuer, by your PhD

24 experience, you would expect the Bank to look very

25 carefully at that figure, wouldn’t you?

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

19 :1 A. My Lord, just to explain how the procedure was working,
2 I would like to mention that we were considering during

3 one meeting sometimes dozens of applications, and at

4 that time we were completely relying on the valuations

5 presented to us, and I am afraid that nobody, including

6 myself, was really trying to recalculate, and that was

7 one of the lessons of this Arkhangelsky loan story, that

8 we decided to establish a special team and we acquired

9 a team of, I’m not sure, four or five people from

10 another bank so they would do that as you have said, but

11 it was not done at that time and, therefore, we were

12 just taking it as a face value: that this is a report

13 and we agree on that.

14 There might be a point to recalculate these things

15 if there was a very tight coincidence between the amount

16 of a loan and the evaluation, but as long as here was

17 certain distance, I believe that the Bank considered it

18 as being secure enough.

19 MR JUSTICE HILDYARD: Were you one of the people who

20 considered the Lair valuation before extending the loan?

21 A. I was not reading it before. I was reading it only

22 after all these events, and that was quite a surprise to

23 me, frankly.

24 MR JUSTICE HILDYARD: Thank you.

25 MR STROILOV: Right. I am grateful to your Lordship for

20 :1 this intervention. Then I think I need to make it clear
2 that, on behalf of the defendants and OMG Ports, I don’t

3 accept that the old procedure for scrutiny of valuations

4 wasn’t rigorous enough, and I don’t think we need to

5 argue about that, I just want to make that clear,

6 I don’t accept that.

7 If we could now move on to the next subject, and the

8 document I would ask you to look at is at {D122/1935/1},

9 and then the Russian version is in the same tab, same

10 document, {D122/1935/3}.

11 Now, I am afraid it looks like a machine

12 translation, so perhaps first of all, towards the bottom

13 of the page between the name of Mrs Volodina and

14 Ms Alekseyev, you can confirm that your name, Mr Belykh,

15 was translated purportedly by the machine as «White»,

16 and actually —

17 A. Not bad. I think it’s a positive here.

18 Q. Yes, but you confirm it is your name?

19 A. I assume so.

20 Q. Well, if you look at the Russian version, I think you

21 don’t need to assume; you will just see your name.

22 A. Oh yes, that’s true.

23 Q. Yes. So this is the draft decision of big credit

24 committee, as you can see.

25 A. Yes.

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

21 :1 Q. And what is proposed is that the assets of
2 Scandinavia Insurance company would be transferred to

3 a company called Naziya Closed Joint Stock Company; do

4 you recall anything about that discussion?

5 A. No.

6 Q. Does the name Naziya Closed Joint Stock Company ring any

7 bells?

8 A. Well, I believe that that was one of the clients of

9 the Bank, but I don’t know about it.

10 Q. Right.

11 A. And, my Lord, I just want to comment that sometimes,

12 that these lists are naming all members of the credit

13 committee and sometimes in their absence or invitation,

14 names are not withdrawn, they are just typed as it is.

15 Therefore, I’m not sure whether I was present at that

16 meeting or not. I could, but I don’t remember.

17 Q. I accept that, and of course there is a space for

18 signature, and there should have been signatures, and we

19 could see that, and we haven’t located any document with

20 these signatures; it is just the draft that was meant to

21 be submitted to you.

22 A. Ah, so you are not saying that it was submitted?

23 Q. I am not positively saying that, I was asking you, but

24 you are not in a position to confirm or deny that you

25 participated in that discussion?

22 :1 A. Well, in any case I do not recollect this document,
2 whether that was because it was not submitted or whether

3 it was because I forget or whether it was because I was

4 not absent after submission, I cannot tell now.

5 Q. And you are not — you don’t recall, in more general

6 terms, any discussion about the proposed transfer of

7 real estate from Scandinavia Insurance to Naziya?

8 A. No.

9 MR JUSTICE HILDYARD: This translation is, by no means,

10 easy. Could you, without wanting to impose on you as

11 an expert translator, could you just give me a feel of

12 the thing? After the first break, which in English is

13 translated as «Essence of the question», could you just

14 read me what that says, in your view, reading it from

15 the Russian?

16 A. Sorry, on the top?

17 MR JUSTICE HILDYARD: Yes. There’s one underlining and then

18 there’s another underlining. Could you do the three

19 lines which are under the second underlining, please?

20 A. Well, second underlining «Essence of the question» in

21 fact is the content of the question, or just «to be

22 considered», or «to be discussed».

23 MR JUSTICE HILDYARD: Yes. Could you read me the rest of

24 that bit?

25 A. Well, if I may to make slight improvement of what is

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Arkhangelsky [Master]

23 :1 said here.
2 MR JUSTICE HILDYARD: Don’t read the English, because

3 I can’t make head nor tail of the English; just read me

4 what it says in its native language.

5 A. Native language says (Russian word).

6 MR JUSTICE HILDYARD: What does that mean? Give me the

7 translation in English.

8 MR STROILOV: My Lord, would it best, perhaps, if Mr Belykh

9 reads it in Russian and then the simultaneous

10 translators do that?

11 MR JUSTICE HILDYARD: All right, fine.

12 Mr Lord, I don’t want to interrupt this too much,

13 but this is sort of near nonsense.

14 MR LORD: Your Lordship will recollect we had the debate

15 about translations, and —

16 MR JUSTICE HILDYARD: Yes, I know, but this is a Bank

17 document of the large credit committee relating to

18 a matter which could be fairly central; surely this is

19 a document that should have been translated properly?

20 MR LORD: My Lord, there were lots of documents in

21 the bundle. We explained how many there were, and

22 a view had to be taken about how —

23 MR JUSTICE HILDYARD: Well, the view that has been taken in

24 the case of this document is very difficult to

25 understand. I don’t know how central this will be, it

24 :1 may not be, it is difficult for me to tell as we gather
2 in the documents, but I hope that there are not going to

3 be many documents which appear to record, in draft or in

4 final, the actual decision-making process of the Bank

5 which are, frankly, in gobbledygook. Now if there are

6 then I suggest that someone burns the midnight oil to

7 ensure that by the time we get to any relevant witness

8 that they have a proper document which the court is able

9 to understand.

10 The basis on which I have proceeded is that you have

11 taken a considered view, or those around you have taken

12 a considered view, and that documents for which poor

13 translations are required will not have to be studied in

14 any detail so that their subject matter will emerge from

15 a rather poor translation, but their content won’t be

16 important. If this is important, and if there are

17 others like it, this is deficient.

18 MR LORD: My Lord, I will …

19 MR JUSTICE HILDYARD: Thank you very much.

20 MR STROILOV: So, perhaps for the time being, as

21 an imperfect provisional solution, should we experiment

22 with — take advantage of simultaneous translation?

23 MR JUSTICE HILDYARD: Yes. Do I have to put on a headphone

24 or something?

25 MR STROILOV: Yes, I would suggest that, and then we just

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Arkhangelsky [Master]

25 :1 ask Mr Belykh to read it in Russian.
2 MR JUSTICE HILDYARD: Do I have to switch it on?

3 A. (Interpreted) «I am giving the consent to Scandinavia

4 Insurance with respect to the alienation to Naziya of

5 …»

6 MR JUSTICE HILDYARD: I am not hearing anything.

7 A. May I speak in English?

8 «The subject of the matter is to obtain agreement

9 from insurance company Scandinavia for transferring the

10 property rights to the company Naziya, property rights

11 for real estate and the rights to lease the land plot

12 which are pledged to the Bank.»

13 So something like that.

14 MR JUSTICE HILDYARD: Thank you. Yes.

15 MR STROILOV: I think, if Mr Belykh doesn’t remember, I just

16 move on.

17 MR JUSTICE HILDYARD: Yes.

18 MR STROILOV: You have noted the document now.

19 Now, I think there is another decision I would like

20 you to look at. Can we go to {D134/2202.1/0.1}.

21 I beg your pardon, I am actually trying to find it

22 myself, so as to go round the document. Sorry, my Lord.

23 (Pause).

24 I apologise, my Lord, this is again — that is

25 probably not quite necessary.

26 :1 On the other screen if we could have page 1 of
2 the same, as opposed to 0.1, if we could have page 1 of

3 the same tab, and that will be the Russian version.

4 {D134/2202.1/1}. You can see that, Mr Belykh, so that

5 is meant to be minutes of the meeting of the big credit

6 committee where you are recorded as being present, and

7 then if we scroll down — can you scroll down two pages

8 on each screen so that we go to the substantive bit, and

9 in the English version as well?

10 You will see that this is a decision to provide the

11 Bank’s consent to Western Terminal LLC to lease the real

12 estate pledge to the Bank to a company called Gunard

13 Enterprises Limited, from British Virgin Islands; you

14 can see that, can’t you, Mr Belykh?

15 A. I can see that, yes.

16 Q. Do you recall their decision?

17 A. No.

18 Q. You don’t recall any meeting where that was being

19 discussed?

20 A. Well, I don’t recall that decision and that discussion.

21 Q. Right, then perhaps we could look at the actual lease

22 agreement in case that —

23 A. Mr Stroilov, just a short remark. My Lord, I would like

24 to draw your attention that the person in question who

25 makes the presentation of that question is Ms Mironova,

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Arkhangelsky [Master]

27 :1 but the important point is that she has now a different
2 position. She is the head of the special department of

3 client monitoring, as it was called, maybe a bit

4 clumsily, but this means that we have officially

5 approved the structure when the company which has

6 problems with loans are considered more by specially

7 arranged department, and therefore, for good or for bad,

8 people who were involved, as myself, with the general

9 client relationship, were less involved in these

10 matters. Therefore, it might be a deficiency of my

11 memory, or by some chance that I was not paying enough

12 attention at that time, due to the fact that we trusted

13 other colleagues to deal with such matters.

14 Q. I see. So, essentially, at that point in time, and the

15 document, I think, is dated 23 November 2009, so by that

16 time you are saying that, essentially, you, as big

17 credit committee, whenever there was an Oslo Marine

18 issue, so to speak, you left it to the client monitoring

19 directorate; is that how you approached that?

20 A. I’m just explaining the possibility why I could not

21 recollect these details. I’m just explaining to

22 the court that situation has been changed, that there

23 was a special procedure dealing with these matters and,

24 therefore, I was not deeply involved in these matters,

25 and that’s all.

28 :1 Q. Yes, that’s right, but I would like to have a little
2 more detail on that.

3 So client monitoring directorate. Essentially all

4 these functions you have normally to exercise, in

5 relation to problem clients or this kind of situation,

6 as you had with OMG, that would be delegated by that

7 stage to client monitoring directorate, wouldn’t it?

8 A. More or less.

9 Q. Right, and I believe — yes, I see, thank you, that is

10 helpful.

11 So it would be possible for you, in big credit

12 committee, rather than scrutinise it in some detail,

13 simply to approve the decision of client monitoring

14 directorate?

15 A. I would say not the decision; the proposal.

16 Q. The proposal, but you wouldn’t — you trusted them, you

17 wouldn’t look at it too closely. You were confident —

18 A. Well, it depends. It’s not a rule, but I’m saying that

19 my personal point concerning this particular document

20 might be explained by this fact.

21 In general, of course, credit committee considers

22 seriously any proposal, but my memory here might be in

23 sort of default, due to certain reasons.

24 Q. Yes. Right, if we could — perhaps if we look at the

25 actual lease agreement it might remind you, and that

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

29 :1 would be helpful. If we could now go to {D128/2060/1}.
2 Helpfully that is bilingual, so we have the English

3 version here and then the Russian version, if you like

4 to look at it, Mr Belykh, that will be at {D128/2060/4}.

5 So you will see in section 1 that the lease actually

6 relates to, I think, all real estate of Western

7 Terminal, doesn’t it?

8 A. I don’t know.

9 Q. Right.

10 A. I am seeing this document, but I’m not sure I have seen

11 it before, so I don’t know.

12 Q. I want to take you through the terms, because some of

13 them are rather unusual and that might encourage some

14 recollections?

15 A. Unusual for whom?

16 Q. I beg your pardon?

17 A. Unusual for whom?

18 Q. Let’s go through the clauses and then perhaps one of

19 them might ring a bell, and if they are usual, you can

20 say so. If you look —

21 A. If I’ve mentioned that I have not seen it before, that

22 would not bring us further on? Okay, fine, sorry.

23 Sorry for —

24 Q. Are you sure you haven’t seen this document before?

25 A. I think so.

30 :1 Q. Are you sure, or you can’t recall?
2 A. I cannot recall.

3 Q. Right. Well if we look at clause 1.3, you will see that

4 the lease is for 49 years from the state registration of

5 the agreement.

6 Then you see in 2.1.1 that the property is to be

7 transferred:

8 «…into Lessee’s possession no later than in 3 days

9 from the date of this agreement…»

10 And at the top of the page you can see that brings

11 us to 23 August 2009.

12 A. 20 August.

13 Q. Now, if you could go down one page on both screens

14 {D128/2060/2}, you will see in clause 3.1 that the rent

15 was US $20,000 per month, including VAT, and the entire

16 rent, if you look at clause 3.3, you will see that the

17 rent for the entire period of the lease must be paid:

18 «…not later than the last day of the term under

19 this Agreement based on the invoice issued by the

20 Lessor.»

21 I think finally —

22 A. Is that a question?

23 Q. No, I am asking you to look at these clauses, I’m

24 drawing your attention to them in the hope that this

25 might trigger some recollections.

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Arkhangelsky [Master]

31 :1 A. No, it doesn’t.
2 Q. It doesn’t.

3 Finally, I think, for completeness, if you could

4 read clause 5.2:

5 «Given the Lessee continues using the property after

6 the lease term under this Agreement has expired …»

7 And so on. So it is, effectively, extendable, or

8 automatically extendable.

9 So that does not ring any bells, does it?

10 A. No.

11 Q. I think it would be likely, this kind of unusual lease

12 is likely to have — to stick in one’s memory, if you

13 considered it.

14 A. As I have said, I don’t remember this document, my Lord.

15 Q. Do you think that if you actually considered it at big

16 credit committee you would have remembered it?

17 A. Once again, I can just mention that I don’t remember it

18 and I don’t think that to think about what I would think

19 if I was reading that at a certain time then now I would

20 do something to recollect it, I think it is futile.

21 I just don’t remember, sorry.

22 MR JUSTICE HILDYARD: Have you ever seen a lease like this

23 before?

24 A. I don’t think so.

25 MR JUSTICE HILDYARD: No.

32 :1 MR STROILOV: Yes. Now …

2 MR JUSTICE HILDYARD: It seems quite a good deal to only pay
3 the rent on the last day of 49 years.

4 A. Well, the accrued interest would be quite good enough.

5 Sorry, I cannot comment on this document. First of

6 all, I am not a lawyer and, second, I do not recollect

7 that I was reading it before. So, sorry.

8 MR STROILOV: But you understand valuations, Mr Belykh.

9 I put it to you that the value of the assets was

10 artificially reduced by means of that lease.

11 A. Is that a question?

12 Q. Yes. Do you agree?

13 A. I don’t know. I need — to make a judgment, I need to

14 look carefully what was the status of the situation,

15 what was the document, and I cannot make any comments on

16 the document I see just now.

17 MR JUSTICE HILDYARD: I think the point that’s been put to

18 you is if you had land and you made a lease of that land

19 for 49 years, and made provision for the rent on that

20 land of 20,000 plus VAT, only to be paid in 49 years’

21 time, with a provision for that lease to be extended

22 indefinitely, subject to a notice provision, the value

23 in your hands of the land would be enormously reduced

24 because someone else would be entitled to use it for

25 49 years, and only then would you receive the rent;

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Arkhangelsky [Master]

33 :1 isn’t that the point that’s being put? You would agree
2 with that, wouldn’t you?

3 A. Well, that seems that this is a correct statement.

4 MR JUSTICE HILDYARD: Yes.

5 MR STROILOV: Well, let me take it a step further,

6 Mr Belykh. I put it to you that whoever has drafted

7 this lease realised there would be that effect.

8 A. I don’t know.

9 Q. Right. And I further put it to you that whoever —

10 well, it may have been big credit committee or client

11 monitoring directorate, but anyone who considered that

12 on behalf of the Bank would have realised that would be

13 its effect on the pledge.

14 A. Well, I can just repeat that I don’t think my comments

15 here are relevant.

16 Q. You don’t recall this effect being brought to your

17 attention at the time?

18 A. No, I don’t recall this document and, therefore,

19 I cannot recall any particular focusing on the

20 particular parts of that document as a result.

21 Q. Yes. Could we have document {D134/2202/1} on one of

22 the screens, and {D134/2202/2} on the other screen.

23 That is a memo addressed to the members of the big

24 credit committee, signed by Mrs — essentially

25 proposing — the proposal to grant consent to this

34 :1 lease. It is signed by Mrs Yashkina, Mrs Mironova,
2 Mr Kolpachkov and Mrs Talamakayeva, isn’t it?

3 A. Yes.

4 Q. And then I fear it is not translated, but there is

5 a handwritten note.

6 A. You mean the last point? No, it’s not translated.

7 Q. Yes, could you read the handwritten note at the bottom?

8 I don’t know, perhaps you could — I don’t know, should

9 we experiment with simultaneous translators, or should

10 we take it …

11 MR JUSTICE HILDYARD: Okay, I am anxious to get it to work.

12 MR STROILOV: So if you could read it in Russian, Mr Belykh.

13 THE INTERPRETER: One needs to take into consideration the

14 risks related to reduction of the sale price at the

15 auctions for the reason of encumbrance as long term

16 lease.

17 MR STROILOV: And do you recognise the signature?

18 A. I’m not sure.

19 Q. All right.

20 Right, I think for completeness if we could also

21 look at —

22 MR JUSTICE HILDYARD: Who is the prisoner? Again, this

23 translation, the middle of the page:

24 «Real estate, leased, they are located in

25 the guarantee in joint stock company

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

35 :1 ‘Bank St Petersburg’ in accordance with the prisoner by
2 the agreement about the mortgages… »

3 What’s all that about?

4 A. Instead of «guarantee», it should be «pledged», of

5 course, sorry. Instead of «guarantee that this real

6 estate is pledged to Bank St Petersburg», the normal

7 «guarantee» seems to be the wrong word here.

8 MR JUSTICE HILDYARD: Right. But in accordance with …

9 A. It just refers to the fact which I was reading about,

10 that the object already is pledged and, therefore, it

11 might be less value during sales.

12 MR STROILOV: I wonder, my Lord, if we should just to have

13 the benefit of the text in the transcript, should we ask

14 Mr Belykh to read this paragraph in Russian?

15 MR JUSTICE HILDYARD: Yes, all right, thank you.

16 MR STROILOV: Sorry to exploit you in this way, Mr Belykh,

17 but if you could read the paragraph starting from the

18 words «nedvizhimoye imuschestvo».

19 A. Maybe it will be quicker if I just read it in English.

20 Q. I think it is better, just so that everyone is sure the

21 translation is by sworn interpreters, so if you read in

22 Russian and we have —

23 A. I have sworn to tell the truth and not to be a best

24 translator.

25 MR JUSTICE HILDYARD: Don’t let’s argue about that. Just

36 :1 read it in Russian and we will get the English
2 translation.

3 THE INTERPRETER: «Leased real estate is pledged to OOO

4 Bank St Petersburg in accordance with the mortgage

5 agreement without number of 21 July 2008, registered by

6 the administration of the Federal Registration Service

7 for St Petersburg and Leningrad Region on

8 14 August 2008, in accordance with the mortgage

9 agreement, a land plot is taken as pledged with the

10 general area of 73,397 square metres, cadastral number

11 78 8226 23, located at St Petersburg Korabelnaya Street,

12 house number 6, letter AI and berth number CB 15,

13 cadastral number 78 8226 23 274, area 4,800 square

14 metres, located at St Petersburg, Korabelnaya Street,

15 house 6, letter IM. Total pledge value of the real

16 estate objects pledged is 1,286,805,920 roubles.»

17 MR STROILOV: Thank you very much, Mr Belykh, and really

18 sorry to …

19 MR JUSTICE HILDYARD: Thank you very much.

20 MR STROILOV: I think for completeness, before we leave that

21 subject, if we could look at {D134/2203/1}, and the

22 Russian version is on the next page. So if you have it

23 on the other screen. So Mr Belykh, just look at the

24 e-mail. Well, I think this e-mail is from Mrs Mironova

25 to Mrs Volodina, actually suggests several things.

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

37 :1 First, that this lease was being arranged by
2 Renord-Invest; secondly, I suggest to you that

3 Ms Mironova was closely involved in that and handled

4 this on the part of the Bank, and; thirdly, it appears

5 that at the actual meeting of the big credit committee

6 you decided to give consent to a 49-year lease, but

7 subsequently, for whatever reason, it was reduced to

8 30 years.

9 Now, if we could look again at the minutes, and I am

10 sorry to — if we could go back to {D134/2202.1/0.1}.

11 Then if you could scroll down one page, you will see

12 that the minutes refer to 30 years, Mr Belykh. So,

13 Mr Belykh, from the documents we have just considered,

14 it appears that whatever the big credit committee

15 actually decided, Ms Mironova and Mrs Volodina were then

16 in a position to write in the minutes whatever they

17 agreed with Renord-Invest, doesn’t it?

18 A. No.

19 My Lord, I would like to make a comment. There is

20 a practice that certain decisions might be amended, for

21 whatever reason, and these amendments are to be approved

22 by the majority of the credit committee, and that is

23 exactly the case which you have mentioned quite rightly

24 yesterday, that if there is a decision which doesn’t

25 coincide with the opinion of the client, then we should

38 :1 have certain additional discussions with him.
2 So it looks like, although I do not remember these

3 documents and I don’t remember these details, but it

4 looks like that certain decision has been discussed and

5 then suggested to be changed and then, I believe, was

6 duly approved by the majority of the credit committee,

7 and that does not mean that somebody can overrule this

8 joint decision but, of course, amendments are quite

9 possible because it is a normal life. It is normal

10 business.

11 Q. But you don’t recall participating in that process as

12 a member of the majority or minority, whatever; you

13 don’t recall that, do you?

14 A. I don’t remember that, yes.

15 Q. Thank you.

16 Are you aware that Gunard Enterprises Limited is

17 a Renord-Invest company?

18 A. No, I don’t know. I don’t know anything about Gunard

19 Investment Company, or at least I cannot recollect

20 anything.

21 Q. Right. Now, I think one — well, a couple more

22 questions about Renord, if I may. If we could look at

23 {D34/537/1}. Sorry, I’m not quite keeping it

24 chronological. That’s the English version, and you will

25 find the Russian version next page, so if that could be

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

39 :1 put on the other screen {D34/537/2}.
2 Sorry, I probably shouldn’t start from there. Yes,

3 well if we could — I am just — if we could briefly, on

4 whatever screen, if we could go to page 3 of the same

5 tab, so you see the attachment to that e-mail, and that

6 is a draft consultancy agreement apparently for

7 consultancy services offered by Renord-Invest. That was

8 the attachment to the e-mail we have seen on the other

9 screen.

10 Then Mr Arkhangelsky is writing to you and

11 Mrs Shabalina suggesting that this is too expensive;

12 does that ring any bells?

13 A. I don’t remember this.

14 Q. I think what — let’s see what —

15 A. I’m not questioning this document. I just don’t

16 remember.

17 Q. Sure, I just want to explain to you what is being said

18 about it and then perhaps you could comment or recall

19 something.

20 If we could go to —

21 A. It looks like Mr Arkhangelsky doesn’t agree with the

22 price of consultants. Well, that’s his right, so what

23 comment are you expecting from me?

24 Q. What I’m suggesting to you, that obviously he, for some

25 reason, after receiving this draft, he thought it

40 :1 appropriate to send that and to raise this with you and
2 Mrs Shabalina. I am suggesting that this means it was

3 the Bank who put him in touch with Renord-Invest,

4 suggesting he uses their consultancy services.

5 A. On that I cannot make any judgment. I don’t know.

6 Q. You don’t recall any such talks between the —

7 A. I don’t recall that and it’s not clear what the link

8 between this suggestion and the price.

9 Q. No, but what I’m suggesting — the question I’m trying

10 to understand is why would — if you had a problem with

11 the price, why would he ask you about it?

12 A. Well, we were dealing with him, we were his major bank.

13 Why shouldn’t a client consult his contact in the Bank

14 concerning his businesses? If he had questions of

15 importing equipment, then he speaks with us on the

16 proposals and the potential deals, so I don’t see

17 anything unusual in consulting with the Bank on certain

18 matters.

19 Q. But this suggests, and in real life the only realistic

20 scenario where he would ask you about a problem like

21 this, was if you, as a bank — I don’t mean necessarily

22 you personally, but perhaps — suggested that he uses

23 Renord as a consultancy; wouldn’t you agree?

24 A. It could be possible, could be not, I don’t know.

25 Q. Perhaps if we look at what Mr Arkhangelsky has to say

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

41 :1 about it. 16th witness statement, and that’s
2 paragraph 173 of his 16th witness statement, but before

3 I give the reference, I must find it. (Pause).

4 So that will be {C1/1/45}. Can you see there,

5 Mr Belykh?

6 A. Mm hmm.

7 Q. Right, and then if we could — no, perhaps on the other

8 screen, if we could look at Mr Arkhangelsky’s addition

9 to that, in the 19th witness statement. That’s

10 {C1/9/4}.

11 A. Mr Stroilov, I read what I see here that Mr Arkhangelsky

12 voluntarily decided to choose Lair and asks whether the

13 Bank would approve the business plan prepared by Lair,

14 which contradicts a bit your previous statement, but

15 sorry for that comment.

16 Q. Where are you looking, just for the record?

17 A. Page 45, point 173. She says that he decided to use

18 Lair and asks whether it is acceptable for the Bank, but

19 this means that the Bank was not pressing him to use

20 Lair’s services. Sorry. I’m sorry, it’s not my

21 judge — it’s not for me to make these comments, sorry.

22 Q. No, it’s all right. It’s quite all right, Mr Belykh.

23 But what I am suggesting to you is that before using

24 Lair, the Bank suggested that he uses Renord.

25 A. Well, that’s the saying of Mr Arkhangelsky. I cannot

42 :1 comment that. That I don’t know. I was not involved in
2 that matter.

3 Q. Can you categorically deny you were involved in that?

4 A. Well, I don’t understand legal meaning of

5 «categorically». I just don’t remember.

6 Q. It’s nothing legal, I mean just — you don’t remember?

7 A. I don’t remember. Yes.

8 Q. Now, I think I would like you to look very quickly, just

9 to slightly recap on the subject of Olimp office, if we

10 could quickly look at the witness statement of

11 Mr Smirnov, paragraph 13. I will give a reference in

12 a moment. {B2/12/3}. I am afraid my system is being

13 slow, for whatever reason. If you could scroll down to

14 paragraph 13, I don’t know if that is possible —

15 A. Maybe somebody would help me?

16 Q. I’m very grateful, my Lord.

17 Mr Belykh, if you could read through paragraph 13.

18 A. Yes, I can read paragraph 13.

19 Q. Just tell me when you have finished. (Pause)

20 Where are you looking, Mr Belykh? Can I help?

21 A. I just want to see the Russian version.

22 Q. We can call it on the screen.

23 A. Okay, it’s reasonably similar. Yes. I was a bit just

24 surprised by some formula but, yes, it is well

25 translated.

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

43 :1 Q. So which formula surprised you?
2 A. No, nothing, sorry.

3 Q. No, just will you please tell the court which bit

4 surprised you?

5 A. Well, it says «Renord-Invest trades …», and I was

6 interested what is in Russian. But in Russian it says

7 «operates», so it’s basically the same, I believe.

8 Q. Mr Belykh, I think —

9 A. Just only one word was the question.

10 Q. All right. Thank you.

11 Well, I just put it to you, would you agree that in

12 the light of the evidence you gave yesterday about Olimp

13 office, this assertion of Mr Smirnov is quite

14 misleading?

15 A. No. Why?

16 Q. Well, because yesterday you have said that the Bank had

17 an additional office in that building at that time.

18 Then subsequently you also admitted that a team from the

19 central office was based there, and Mr Smirnov denies

20 that and says it was just a cash desk and full stop. He

21 doesn’t explain the connection.

22 A. What Mr Smirnov denies? I haven’t seen this document

23 before, so I wonder what you really want me to agree or

24 disagree.

25 Q. Are you —

44 :1 A. I mean, the last point that — but it’s no longer in
2 operation, so what?

3 Q. No, Mr Belykh, I am just asking you, do you consider

4 that this is quite consistent with the evidence you gave

5 yesterday?

6 A. Well, look, Mr Smirnov says that some time ago, before

7 his statement has been made, there was a cash desk

8 operated by the Bank, the counter to draw cash and

9 cashing cheques located on the second floor, but it is

10 no longer in operation. It is no longer in operation,

11 that’s true, and if you recollect my discussion

12 yesterday, I was focusing exactly on these cash

13 operations dealing with the car purchases, so I don’t

14 see any contradiction with my yesterday statement.

15 Q. What you discussed yesterday was actually the cash desk,

16 wasn’t it?

17 A. I was a small additional office, primarily focused on

18 operations with private people, related to car

19 purchases.

20 Q. However, because it has been suggested here on behalf of

21 the Bank that, in fact, there was a mistake and the cash

22 desk was one thing, and Olimp office was another. Does

23 your recollection — do you agree with that?

24 A. What does mean «one thing and another thing»? Of course

25 if there are two different things, they are different.

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Arkhangelsky [Master]

45 :1 Sorry, I do not grasp the meaning of your question.
2 Q. Yes. What was suggested, Mr Belykh — I beg your

3 pardon, it is my fault — what was suggested was that

4 there was an additional office operating from that

5 address until 2010, and then separately there was a cash

6 desk unconnected to Olimp office, but which was operated

7 on a different floor in the …

8 A. My understanding of this statement is that Mr Smirnov

9 calls this additional office a cash desk, but that’s his

10 statement, not mine, and I think that you could — if he

11 is a member of this procedure, this might be asked from

12 him, what he meant there.

13 Q. Thank you. I beg your pardon, I think it won’t be long

14 now.

15 Yes, I think there is finally one matter I would

16 like to raise, where I — yes. Do I understand

17 correctly that throughout your work for the Bank you

18 were reporting directly to Mr Guz?

19 A. Well, during the time of these events we are discussing,

20 yes, I was reporting directly to Mr Guz, but now it is

21 different, and at a certain stage between that time and

22 the current time, there were also some changes.

23 Q. I am more interested in the early period, actually, and

24 from the time you joined the Bank, which was — let me

25 check your statement. I think was it in …

46 :1 A. 2004.
2 Q. 2004. From that time and until 2008/2009 and so on, you

3 were working under the supervision of Mr Guz?

4 A. Yes, sure.

5 Q. And I think you joined the Bank around the same time?

6 A. Around the same time with whom?

7 Q. Mr Guz and you both began working for the Bank in 2004.

8 A. No, I believe that Mr Guz joined the Bank earlier than

9 me, substantially earlier. I don’t know exactly his

10 time, but I believe that it was somewhere in the end of

11 2003. Therefore it could be merely a year of difference

12 between our working in the Bank of St Petersburg.

13 Q. But after joining you worked under his —

14 A. After joining the Bank I was working under his direct

15 control and supervision.

16 Q. Thanks. And prior to that, before 2004, I believe

17 Mr Guz and you were both working for Alfa Bank; is that

18 correct?

19 A. Yes, I was working in Alfa Bank for a certain time

20 period, and at that time Mr Guz was my superior in

21 Alfa Bank.

22 Q. In Alfa Bank, yes, thank you.

23 At what time did Mr Guz leave Alfa Bank; do you

24 recall?

25 A. Well, I’m not sure, but my feeling is that somewhere at

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Arkhangelsky [Master]

47 :1 the end of 2003, but the end might be one month or two
2 months or three months; I don’t remember exactly.

3 Q. And you stayed for about another year; is that the case?

4 A. I stayed — I’m not sure — maybe about half a year or

5 so, and then I joined another Bank and only then I came

6 to Bank of St Petersburg.

7 Q. And that was the St Petersburg branch of Alfa Bank,

8 wasn’t it?

9 A. Yes, that was the St Petersburg branch of Alfa Bank.

10 Q. Now, I understand that in 2003, shortly before the

11 departure of Mr Guz, there was a criminal investigation

12 into VAT fraud and money-laundering in that branch?

13 A. Quite so.

14 Q. Do you recall that?

15 A. I do remember that there was such a case, yes.

16 Q. And as a result of that, about ten senior employees of

17 the branch had to leave?

18 A. Well, I know that some people left the Bank. I wouldn’t

19 agree with the figure ten senior, because I think it is

20 questionable.

21 Q. Yes. Well, I have a media article about that. The

22 Russian version is in the bundle, and I can hand up the

23 translation, if I am given a moment, just so that …

24 Oh, I think there is a translation as well. So if

25 we could go to {D10/228.3/0.1}, and then I’m wondering

48 :1 is that — no, I think — well, if we could actually
2 scroll down to {D10/228.3/0.3} I think that is a better

3 translation, and then I think in parallel on the other

4 screen, if we could have the same tab, page 1

5 {D10/228.3/1}. Even if it was preserved on just some

6 website, that’s actually an article from Commersant,

7 a reputable Russian business newspaper, isn’t it?

8 A. Owned at that time by Mr Berezovsky. So what is your

9 question, please?

10 Q. On the first article, the bottom of it, the last

11 sentence suggests — the last two sentences suggest that

12 after various searches in September 2003, ten employees

13 of Alfa Bank, including Mr Guz, had to leave. Is that

14 correct?

15 A. Well, Mr Stroilov, there is a standard mistake, post hoc

16 ergo propter hoc. I mean, «after it» doesn’t mean

17 necessarily «because of it», therefore I would strongly

18 argue that these two events, the departure of Mr Guz and

19 this criminal procedure were connected, and I think that

20 there are official documents of Alfa Bank proving that

21 there is no connection whatsoever of these two events.

22 Q. So you can actually say that from your knowledge of —

23 A. I don’t have any news — or I have no information of any

24 involvement of Mr Guz to these matters, and I think that

25 this coincides with the official position of Alfa Bank.

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Arkhangelsky [Master]

49 :1 Q. You are saying it is just a coincidence in time, is that
2 what you are saying?

3 A. Sorry?

4 Q. So it just coincided in time —

5 A. I think Mr Guz decided to make his career in a different

6 way and, as time showed, this decision was quite good

7 for the Bank of St Petersburg.

8 Q. Yes.

9 There are a couple of matters, I think we are near

10 the end, really. I think we have to — yes, I think one

11 matter. Do you recall there being a lot of press

12 reports in 2007 about various raids on OMG offices and

13 various investigations against Mr Arkhangelsky?

14 A. Well, I don’t recollect these details. I don’t

15 remember. I’m not denying it, but I just don’t

16 remember.

17 Q. What Mr Arkhangelsky says is that in the summer of 2007,

18 you telephoned him because you were concerned about

19 those reports? Is that correct?

20 A. It could be the case. I don’t remember.

21 My Lord, I don’t remember that. But if, let’s put

22 it that way, there were some publications concerning

23 certain important client, then of course, as a Bank

24 officer, I might be interested to know his opinion

25 whether there are troubles or the absence of

50 :1 the troubles, but that’s a normal practice, of course.
2 But I do not recollect these discussions with him.

3 Q. Yes, and what is suggested is that you then suggested to

4 him that he should go to Mr Savelyev and ask for his

5 protection from the police.

6 A. No, I don’t remember that. I don’t think that that

7 could be the case.

8 Q. Do you recall organising a meeting between

9 Mr Arkhangelsky and Mr Savelyev in the end of summer

10 or — well, at any point in 2007?

11 A. That’s definitely not the case. I was not organising

12 such a meeting, and it seems strange that I would advise

13 a client to apply for the head of the board to resolve

14 some matters with the official police organisation.

15 That’s quite improbable.

16 Q. Well, Mr Belykh, you also, towards the end of 2008, you

17 also mentioned to Mr Arkhangelsky that the Bank had its

18 own difficulties and was receiving some support from the

19 Central Bank of Russia in the form of refinancing or

20 guarantees, or whatever support the state can give to

21 a bank; do you recall telling him that?

22 A. I don’t recall that and it seems to me quite improbable

23 that that was the wording of what I might mention.

24 Q. I am sure you put it much more elegantly than I do.

25 A. No, I just don’t think that I’ve put it in any form,

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Arkhangelsky [Master]

51 :1 elegantly or not elegantly. Just strange, you know,
2 that I ask a client something related to a relationship

3 of the Bank to the Central Bank. In this form, it is

4 quite strange.

5 Q. What is suggested, Mr Belykh, is that because of that,

6 the Bank felt more constrained in giving some latitude

7 to its own clients, if that makes sense; that is to say

8 if the State is helping the Bank, you wouldn’t be

9 inclined to forgive the debts or postpone the debts for

10 a long period for your own clients because, in a way,

11 you are responsible to the State for its part?

12 A. No, I’m saying that’s rather improbable, my Lord, just

13 because of the simple thing, that at that crisis time we

14 were all concerned with our clients, and that was not in

15 the interest of the Bank to declare immediate defaults

16 of our customers.

17 Here the support of the Bank, of the Central Bank in

18 2008, I do not recollect any substantial facts, as

19 compared to nowadays when there is a list of banks

20 supported by the Central Bank officially, and we are on

21 that list.

22 But at that time I don’t remember special support of

23 the Central Bank. We were not inclined to make these

24 default decisions because of the general situation. If

25 we make default, then we need immediately make

52 :1 100 per cent reserves, and reserves are deduction from
2 the profit, and the Bank should have profit at the end

3 of the year, otherwise shareholders would be quite

4 concerned.

5 So it’s much more simple matters than it is

6 constructed in the evidence of Mr Arkhangelsky.

7 Q. I think it actually comes to something quite simple.

8 What is suggested is that you told him that it might

9 help to obtain restructuring if he had some support from

10 state authorities, from some politicians, officials, if

11 he could bring some comfort letters from official

12 figures.

13 A. Well, I think that these types of letters are useful in

14 a way that they bring some better feeling, but

15 definitely they do not influence any decision of

16 the Bank.

17 Q. Perhaps not. What I’m suggesting was it was your idea

18 that such letters might help in terms of dealing or in

19 whatever terms —

20 A. I don’t think so.

21 Q. Okay.

22 A. I think that Mr Arkhangelsky had enough connections with

23 authorities to produce these things himself.

24 Q. That’s not — I’m sorry, it must be totally my fault,

25 I am formulating it badly.

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Arkhangelsky [Master]

53 :1 I’m not suggesting that you helped him obtain such
2 letters, what I’m suggesting is that you told him that

3 if he can bring such letters to the Bank, that would be

4 helpful for him.

5 A. Well, I don’t remember that, and I don’t think that that

6 could be my behaviour.

7 MR JUSTICE HILDYARD: Mr Stroilov, how much longer do you

8 have? I am just conscious of the fact that we have been

9 going for an hour and three-quarters now, and it may be

10 that it would be good to have a break?

11 MR STROILOV: Well, my Lord, I think that is a good moment,

12 and then if we could have ten minutes and I will think

13 during these ten minutes whether I need five minutes or

14 I am finished.

15 MR JUSTICE HILDYARD: Well, ten minutes then.

16 (11.45 am)
17 (A short break)
18 (11.55 am)

19 MR STROILOV: May it please your Lordship. I think I just

20 want to thank Mr Belykh for his answers, apologise for

21 keeping him that long in the box and apologise to

22 the court for doing this in this clumsy and prolonged

23 way.

24 MR JUSTICE HILDYARD: So that concludes your

25 cross-examination?

54 :1 MR STROILOV: It does.
2 MR JUSTICE HILDYARD: Yes, Mr Lord?

3 MR LORD: Does your Lordship have any questions for

4 Mr Belykh?

5 MR JUSTICE HILDYARD: Do you have any re-examination?

6 MR LORD: I don’t, no, my Lord, I don’t.
7 Questions by MR JUSTICE HILDYARD
8 MR JUSTICE HILDYARD: Mr Belykh, I do have one or two

9 questions. I am sorry to detain you.

10 A. Yes, my Lord.

11 MR JUSTICE HILDYARD: Really they are just so I have a

12 fuller picture on one or two things. I think, probably,

13 it is best if we have a look at the transcript of

14 yesterday, Day 3, and I will try and fit my questions

15 into what you have told me.

16 If you go to {Day3/27:1}, please, and you were

17 explaining that you are presently based — and I do

18 apologise for my pronunciation, at Malookhtinsky 64A,

19 which is where you moved from, is this right, from the

20 Nevskaya 178 office?

21 A. I’m sorry, my Lord, I don’t see for the moment.

22 MR JUSTICE HILDYARD: Page 27, Day 3.

23 A. 27, Day 3. Yes. I think now I see it. Yes, I see it

24 now.

25 MR JUSTICE HILDYARD: I don’t.

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Arkhangelsky [Master]

55 :1 MR LORD: Sorry, it’s the day of — yesterday.
2 MR JUSTICE HILDYARD: There we are, yes. You see in lines 3

3 and 4 you explained to me that you are based at

4 Malookhtinsky 64A, and I think I am right in thinking

5 that you came from Nevskaya 178, which is where you were

6 for most of the time during 2008 and 2009; is that

7 right?

8 A. I was on Nevskaya 178 during 2008. Definitely at the

9 end of November, but then I moved to another place,

10 although I do not recollect the exact date of

11 the transfer. That might be December, or might

12 be January of 2009. I do not remember exactly.

13 MR JUSTICE HILDYARD: Thank you. What was the other place,

14 was that the Moscow Hotel?

15 A. Moscow Hotel, it’s about maybe 200 or 300 metres from

16 Nevskaya 178. It’s not very far, but still it’s

17 a different place.

18 MR JUSTICE HILDYARD: Thank you. And how close is

19 Malookhtinsky 64A to Nevskaya 178?

20 A. Malookhtinsky is already on the other side of the river.

21 MR JUSTICE HILDYARD: Right. So it’s a bit of —

22 A. But that’s a quite different place. But there we moved

23 a lot later than these events which we are discussing

24 now.

25 MR JUSTICE HILDYARD: Right.

56 :1 A. But now it’s a quite different place.
2 MR JUSTICE HILDYARD: It was suggested to you that

3 Renord-Invest had offices in Malookhtinsky V or B, I’m

4 not sure which.

5 MR STROILOV: That’s V.

6 MR JUSTICE HILDYARD: V. V for very. Is it a single

7 apartment block? Is Malookhtinsky A and Malookhtinsky V

8 in the same block?

9 A. Well, it depends on what we consider as same block, but

10 there are separate buildings, for sure, separate

11 entrances, and I think that our colleagues might produce

12 a picture of that building. It’s not so difficult.

13 The Malookhtinsky A is a big building of 22 storeys,

14 and to the left side and to the right side there are

15 smaller buildings, but they are separated by, say, 20 or

16 30 metres between them, and they have different

17 entrances.

18 And I’m not denying that Renord has there office,

19 I just don’t know. I have not visited them at that

20 building.

21 MR JUSTICE HILDYARD: Were you aware in 2008/2009 of them

22 having offices there?

23 A. At that time those buildings did not exist. That was

24 the reason of our movement: that the Bank was preparing

25 and then starting constructing these buildings.

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Arkhangelsky [Master]

57 :1 MR JUSTICE HILDYARD: To move to Malookhtinsky?
2 A. To move there, and therefore in the stage of preparation

3 there was some constant movement of different branches.

4 MR JUSTICE HILDYARD: Right, thank you. Just help me

5 understand how clear your recollection is in respect of

6 various events. I think you told us as to your visit

7 with Ms Mironova to the Western Terminal when it was

8 snowing some time early in 2009, I think it was —

9 A. Yes.

10 MR JUSTICE HILDYARD: — spring or summer, you thought

11 spring because of the snow, you didn’t keep a diary as

12 to events such as that?

13 A. No, unfortunately not.

14 MR JUSTICE HILDYARD: It is not your habit to keep a diary

15 for such events?

16 A. No.

17 MR JUSTICE HILDYARD: Another point on which I want to try

18 and work out whether your evidence is that you remember

19 or that you simply don’t quite remember, or that your

20 memory is clear, just about the personal loan.

21 Now, I think the burden of your evidence was that

22 you hadn’t really been clear in your own mind whether it

23 was on 28 November or not, but when you came to study

24 the papers, your recollection became firmer, since that

25 seemed logical because that was the last day of

58 :1 the business month, it being a Friday, and therefore you
2 think it was logical that the meeting was on that day.

3 A. My Lord, yes, that was a substantial part informing my

4 recollections, but that was not the only one.

5 Additional point, I would say that what cleared my

6 mind was exactly this case with the letter of Mr Berezin

7 that was sent to me early in the morning so that

8 Mr Arkhangelsky could bring to Mr Savelyev the final

9 copy, and in case that I was considering that something

10 is completely wrong or completely — that something

11 should be scratched or substantially added, that

12 Mr Arkhangelsky would be in a position to amend this

13 letter before he comes to Mr Savelyev; and I read them

14 early in the morning, and then there was a telephone

15 exchange with me and Mr Arkhangelsky that nothing should

16 be changed, the letter is good enough for the discussion

17 and the result of the discussion, of course, would not

18 depend on the concrete amendments of that particular

19 letter.

20 So these several points confirmed to me that that

21 was exactly the 28th.

22 MR JUSTICE HILDYARD: I think, and if you want to remind

23 yourself, if you go to {Day3/98:1}, which confirms what

24 you said with respect to at least part of

25 the explanation, not the letter part, but the logic

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Arkhangelsky [Master]

59 :1 part, do you see, line 19 on page 98:
2 «But after my work with documents and trying to find

3 out other details, it seems to me that it is really

4 clear, because if you look on the calendar, 28 November

5 was the last day of the month, and the Bank needs to

6 close its account of the month and, therefore, it was

7 really necessary to do something on 28 November so

8 that November reporting would be clear …»

9 Now, I think you also accepted that whatever may

10 have been agreed in principle between Mr Savelyev and

11 Mr Arkhangelsky at that meeting, if on 28 November, it

12 would be still subject to final approval before it could

13 take effect as an agreement to lend money personally to

14 Mr Arkhangelsky; is that right?

15 A. Well, as I — I think I have said that approval of

16 the board was necessary for the files, and I believe

17 that this approval was quickly arranged on the same day.

18 MR JUSTICE HILDYARD: On the same day?

19 A. I think so.

20 MR JUSTICE HILDYARD: Right, so there should be some record,

21 should there, on 28 November of that personal loan

22 having been approved by the relevant committee?

23 A. I think so.

24 MR JUSTICE HILDYARD: Yes. Which committee would that have

25 been?

60 :1 A. That might be board committee.
2 MR JUSTICE HILDYARD: Right. Well maybe that could be

3 identified for me in the files in due course because,

4 am I right in thinking that you wouldn’t be able to

5 close the account in the manner you have described at

6 page 98 until you had had any requisite approvals by

7 whatever was the relevant body or committee?

8 A. Normally, yes.

9 MR JUSTICE HILDYARD: You wouldn’t allow a client to drawn

10 down, for example, on a loan until it has been properly

11 approved?

12 A. My Lord, until the loan is properly approved, it is not

13 disbursed to the client’s account.

14 MR JUSTICE HILDYARD: No.

15 A. And, therefore, by the simple fact that there is no

16 money, he cannot draw.

17 MR JUSTICE HILDYARD: Right. What’s the point of closing

18 the account? At what moment in time is the Bank able to

19 close the account for the month?

20 A. Close the account — you mean the report — how the

21 reporting is done? Sorry for my …

22 MR JUSTICE HILDYARD: I’m sorry, I haven’t put it very well.

23 A. It is my misunderstanding.

24 MR JUSTICE HILDYARD: What you said is that the Bank needed

25 to close its account on 28 November.

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Arkhangelsky [Master]

61 :1 A. Ah, right, okay. Maybe my spelling — wording was not
2 clear enough.

3 MR JUSTICE HILDYARD: Yes.

4 A. I mean that the Bank needs to make reports for its own

5 internal use and for the Central Bank for the month, but

6 if the last day of the month falls on Sunday or

7 Saturday, then the last date for the report would be

8 Friday.

9 MR JUSTICE HILDYARD: Yes.

10 A. And, therefore, that was necessary that transactions —

11 the necessary transactions would be recorded with the

12 same day.

13 MR JUSTICE HILDYARD: I appreciate that, but when can you

14 record a transaction for those purposes? Can you record

15 it when there is an agreement in principle, or can you

16 only record it when there is an approval by the

17 requisite committee?

18 A. Normally there should be an approval by the responsible

19 authority, which —

20 MR JUSTICE HILDYARD: So you couldn’t really close the

21 account off unless and until you had the approval?

22 A. Again, well closing an account and disbursing money,

23 maybe I’m not getting you properly right. There are two

24 things: the first thing is relationship with client and

25 disbursing money and withdrawing money.

62 :1 MR JUSTICE HILDYARD: Leave that aside. Just focus on what
2 you have to do at the end of the month to close off the

3 Bank’s account for that year. Just focus on that.

4 A. For that — well, only those transactions which has

5 taken place would then go to the overall reporting, and

6 the overall reporting includes, of course, the total

7 amount and the amounts of loans disbursed during that

8 particular period.

9 MR JUSTICE HILDYARD: So until you had the approval of

10 the relevant committee or board in respect of the

11 agreement in principle to make a personal loan, you

12 couldn’t enter that loan in the Bank’s account for that

13 month?

14 A. Yes.

15 MR JUSTICE HILDYARD: Yes. Thank you.

16 ADK, the valuers, as to which there was a debate

17 between you as to whether they are recognised or not.

18 Are they on the Bank’s list of approved valuers now?

19 A. I was not checking this list for some time. I know that

20 for some time they were, and I have recommended — well,

21 I mean, I have recommended to some of my clients the

22 list and I do remember that at that time they were

23 there. Whether they are there now, I simply don’t know.

24 MR JUSTICE HILDYARD: That’s perfectly fair. Can you

25 remember at what time?

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Arkhangelsky [Master]

63 :1 A. That was definitely some time ago, maybe two years or
2 three years. I do not recollect.

3 MR JUSTICE HILDYARD: Thank you. Another completely

4 different area. Did you ever recommend or suggest

5 Renord-Invest as consultants to any client of the Bank?

6 A. I don’t — don’t remember that exactly. It might be one

7 client some time ago, but I don’t remember details, I am

8 afraid, to be confused.

9 MR JUSTICE HILDYARD: You might have done, but you can’t

10 remember doing so?

11 A. Yes, I might have done for a client or two, but I don’t

12 remember that.

13 MR JUSTICE HILDYARD: Did the Bank have any list of such

14 consultants as it does appear to have had a list of

15 approved valuers?

16 A. Not that I know, my Lord.

17 MR JUSTICE HILDYARD: Thank you very much.

18 Are there any questions arising from those

19 questions?

20 MR LORD: Yes, there are, my Lord.
21 Re-examination by MR LORD
22 MR LORD: I wonder, could you be shown {D98/1251/1}, please.

23 Do you see that, Mr Belykh?

24 A. Yes.

25 Q. In answer to your Lordship’s question, I think that is

64 :1 the extract from the management board minutes.
2 MR JUSTICE HILDYARD: That’s 26 November, is it?

3 MR LORD: It is, my Lord.

4 MR JUSTICE HILDYARD: Had I got the date wrong?

5 MR LORD: You hadn’t, my Lord, but there is evidence on the

6 timing point that other witnesses give.

7 MR JUSTICE HILDYARD: Thank you very much.

8 MR LORD: I think the evidence, my Lord, is these were

9 backdated, I think, to that date.

10 MR JUSTICE HILDYARD: Thank you very much.

11 A. My Lord, if I may, a very brief comment? The point is

12 that regular meetings of the board are taking place on

13 Wednesdays and 26 was exactly Wednesday, so if whatever

14 decisions are made between those meetings, normally they

15 are included in the protocol of the relevant meeting

16 before that decision. If that would be, say, next week,

17 then, of course, normally if it is a Tuesday decision,

18 then it would normally be postponed and say: okay, wait

19 until Wednesday for tomorrow it’s only one day.

20 But if that was sort of a Friday decision, then

21 normally, and this is common practice, it is included in

22 the minutes of the last board meeting which took place

23 on Wednesday the 26th, which again brings us better

24 confirmation of the dates I was speaking about.

25 MR JUSTICE HILDYARD: Thank you, yes.

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65 :1 MR LORD: And just one more document. I wonder if you could
2 be shown, please, {D98/1253.1/0.1}. Once that is on

3 screen, if you could please follow the scrolling down,

4 if you don’t mind. If you could try and scroll down, if

5 that is possible, and you can see, Mr Belykh, what?

6 A. This is the text prepared by Investrbank related to this

7 private loan, to be presented to the members of

8 the board for their decision.

9 Q. And if one scrolls down, please, if you could just go

10 page on page {D98/1253.1/1}. Does that look like a set

11 of signatures from board members?

12 A. Well, I definitely cannot recollect all signatures but

13 I know for sure the signature of Mr Guz, the signature

14 of Mr Savelyev, so I’m quite sure that these signatures

15 are authentic, or at least the majority of them.

16 Q. For your Lordship’s note, I wonder if I could give

17 your Lordship some other witness references, just so

18 this point doesn’t fester?

19 MR JUSTICE HILDYARD: Yes.

20 MR LORD: Ms Yashkina at {B1/7/13}, paragraph 65.

21 Ms Mironova at {B1/4/8}, paragraph 39.

22 Ms Volodina at {B1/5/8}, paragraphs 38 and 39.

23 MR JUSTICE HILDYARD: Thank you very much.

24 MR LORD: Your Lordship is not wrong: there is

25 a discrepancy, that’s absolutely right. The 26th is

66 :1 a Wednesday, the 28th is a Friday. There was a walking
2 around of a minute to get the approval of the management

3 board after the Friday meeting, in accordance with what

4 had been anticipated earlier.

5 MR JUSTICE HILDYARD: And then it related back to the —

6 I see.

7 MR LORD: Yes. It looks, perhaps, rather worse than perhaps

8 it is.

9 Unless your Lordship has any questions from that?

10 MR JUSTICE HILDYARD: No, I don’t.

11 MR STROILOV: I don’t think I do.

12 MR JUSTICE HILDYARD: Nothing emerging from what I asked.

13 Thank you very much indeed. I am so sorry that it

14 has taken much longer than you might have anticipated,

15 or possibly even I did.

16 A. Thank you.

17 MR JUSTICE HILDYARD: But thank you very much for your

18 evidence.
19 (The witness withdrew)
20 MR LORD: My Lord, I’m going to call Ms Blinova now, please.

21 I don’t know if your Lordship wants to interject?
22 Housekeeping

23 MR JUSTICE HILDYARD: Yes, just before, Mr Arkhangelsky, as
24 I hope has been pointed out to you by Mr Stroilov, and

25 as I hope you have seen in yesterday’s transcript right

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67 :1 at the beginning, I was very disappointed to read of
2 your Facebook, or other Twitter chattering with respect

3 to these proceedings. Did you read what I said in that

4 regard in the transcript, if you received it, yesterday?

5 MR ARKHANGELSKY: Yes, your Lordship, I am sorry for such

6 accident, but I also want to confirm that I would be

7 very careful commenting on that, if any comments, and

8 I want just for you to know that these proceedings are

9 going on for seven years already, and there are

10 thousands of people who are really interested in what is

11 going on.

12 You know that in Russia it is not allowed to publish

13 anything about this because of the weight of the persons

14 involved, and I assumed that my strong comments on

15 everything was not because in confidence to the English

16 proceedings, but because of two facts: that these

17 people — you probably already noticed their

18 dishonesty — these people, they are placing me and my

19 family —

20 MR JUSTICE HILDYARD: I do not wish you to compound the

21 problem, Mr Arkhangelsky.

22 MR ARKHANGELSKY: Yes, sure, sure.

23 MR JUSTICE HILDYARD: I take it that you understand — your

24 comments on the honesty or not of the witnesses are not

25 going to help you or me. The point I am on is the

68 :1 behaviour, in rather than lurid descriptions, which you
2 caused to be made on Facebook.

3 Now, I understand that you are emotional about this

4 case and I understand that these cases do encourage

5 emotions, both amongst the parties and amongst people

6 who may share a general view about the way business is

7 conducted, or even politics are conducted in the Russian

8 Federation, but I do not want to read this sort of thing

9 about these proceedings in this court again, and it is

10 far better and safer for you —

11 MR ARKHANGELSKY: Yes, I understand you.

12 MR JUSTICE HILDYARD: Yes. Well that is my main message.

13 MR ARKHANGELSKY: Yes, I understand you, and I’m sorry,

14 again.

15 MR JUSTICE HILDYARD: Thank you. Well, I shall not enjoy

16 reading any such thing in the future, and I take it to

17 be your assurance that it won’t come from you or anyone

18 connected with you, and we will leave it at that.

19 MR ARKHANGELSKY: Yes, I do.

20 MR STROILOV: Perhaps I might add, I think that I understand

21 Mr Arkhangelsky has deleted that message as soon as your

22 message was conveyed to him yesterday.

23 MR JUSTICE HILDYARD: Thank you.

24 MR LORD: My Lord, just one other document. In answer to

25 your Lordship’s point about the relevant entries for the

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69 :1 personal loan, I should have added {D99/1282/1}, it is
2 just there was a point about the closing of accounts and

3 dates, and I just need to identify this for

4 your Lordship’s note, if you don’t mind, your Lordship

5 can see that that’s a translation. If you scroll down

6 to the next page, please, you will see the Russian

7 version.

8 MR JUSTICE HILDYARD: Thank you.

9 MR LORD: I think this is one of the potentially disputed

10 signatures by Mr Arkhangelsky on the Russian page, and

11 if one goes back to the English, please, this, on the

12 face of it, looks like it is an application made by

13 Mr Arkhangelsky for the transfer of the personal loan

14 amount, which was 130 million roubles, to one of his

15 companies, Re-Gata.

16 MR JUSTICE HILDYARD: I have read about this in

17 the evidence.

18 MR LORD: In terms of questions about timing and accounts

19 and so on, and obviously it has the date it has on it.

20 MR JUSTICE HILDYARD: I am obliged.

21 MR LORD: I should have drawn that to your Lordship’s

22 attention. I do apologise.

23 I wonder if I could call Ms Blinova, please.

24 MR STROILOV: Perhaps if I may intervene, I think I would

25 like to flag a couple of housekeeping concerns.

70 :1 Basically, I think honestly I do desperately need
2 a break before Mr Guz. I am comfortable proceeding with

3 Mrs Blinova, but I do feel I am not really prepared for

4 Mr Guz, and my experience — and you have seen that the

5 time estimate was monstrously exceeded, and as I think

6 one of the lessons I draw from this is that inadequate

7 preparation, actually far from shortening it, actually

8 lengthens the time I take in court, so it may be wise,

9 perhaps, if we complete Mrs Blinova and then

10 Mrs Patrakova is fixed, then perhaps we could look at

11 the timetable at that stage, but I would very much

12 appreciate a break after Mrs Patrakova.

13 MR JUSTICE HILDYARD: Well, Mr Lord, there is a warning for

14 you.

15 MR LORD: Yes, I will have to address your Lordship, because

16 Mr Guz — yes, I will have to just see how we go,

17 I think, at lunchtime and see how much progress we are

18 making. It may be that he has to be stood out from the

19 order of witnesses because he has to go back to Russia

20 for an important meeting. He has an important role at

21 the Bank.

22 MR JUSTICE HILDYARD: Of course.

23 MR LORD: Obviously there is flexibility, but we thought he

24 would be done at some stage by the end of tomorrow.

25 I think he has to fly back to Russia. I will obviously

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71 :1 check whether that can be adjusted in any way.
2 MR JUSTICE HILDYARD: Perhaps you could discuss over the

3 short adjournment, between you, how long you need?

4 MR LORD: Yes. Of course.

5 MR JUSTICE HILDYARD: Mr Stroilov, cross-examining is

6 undoubtedly the most exhausting and onerous part of any

7 case, because you have to know not only what you want

8 the witness to answer, but also where you find the

9 documents with which to confront them, and that is

10 a very wearing process, I understand that. But thank

11 you for the warning. Let us proceed for the moment and

12 then perhaps over the short adjournment, lunch, in other

13 words, you can discuss with Mr Lord how long you

14 presently feel you might need, because it is only right

15 that Mr Guz should have an opportunity to rearrange his

16 diary, if that is truly necessary. We can’t have him

17 just hanging around, however interesting the proceedings

18 are.

19 MR STROILOV: Of course. I don’t really know how keen my

20 learned friend is on his order of witnesses, but we will

21 discuss that.

22 MR JUSTICE HILDYARD: Yes.

23 MR LORD: And again, my Lord, with Ms Blinova again —

24 MR ARKHANGELSKY: Your Lordship, may I just ask a technical

25 question?

72 :1 MR JUSTICE HILDYARD: Well, you may, but it is not — if you
2 were in court here, as would ordinarily be the case

3 where you were being represented as I have permitted,

4 I wouldn’t normally allow it, Mr Arkhangelsky, but by

5 all means, if you have something which is going to

6 assist the swift disposal of the proceedings, do ask.

7 What is it you want to ask?

8 MR ARKHANGELSKY: Yes, I have one technical question about

9 Paris, because it depends on my travelling and my wife’s

10 travelling, depends our stays in Paris. So I just want

11 to ask, and that’s actually RPC who suggested me to

12 speak to you directly, just to ask at which time you are

13 planning to start hearings in Paris on the first day,

14 and at which time are you planning to finish these on,

15 let’s say, the last days?

16 MR JUSTICE HILDYARD: Well, the latter is more difficult to

17 answer than the former. The former, we can, I hope,

18 Mr Stroilov and Mr Lord and yourself can determine what

19 would be a convenient time. I had imagined that we

20 would start broadly at the same time as we would start

21 in England, although, of course, Paris is one hour

22 ahead, there will be a slight difference, but I would

23 imagine we will start 10.30 am Paris time, but if that

24 is inconvenient —

25 MR ARKHANGELSKY: Okay, thanks.

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Arkhangelsky [Master]

73 :1 MR JUSTICE HILDYARD: — if there are flight problems or
2 other, then I will sit earlier or later to try and cause

3 minimum inconvenience to you. Does that answer your

4 question for the moment?

5 MR ARKHANGELSKY: Yes, thank you. So that’s the only

6 question for the moment. Thanks.

7 MR JUSTICE HILDYARD: Very good, thank you very much. Let

8 us defer that. You can all agree between you and

9 otherwise I shall simply pluck out of a hat a time at

10 which we are to start which I hope will not be

11 inconvenient.

12 MR STROILOV: If I may just very briefly, another

13 housekeeping, or technical point. I think, as

14 your Lordship rightly said, normally only one person

15 speaks on behalf of a party, but of course normally

16 Mr Arkhangelsky would be in a position to sit behind me

17 and pass me a note.

18 MR JUSTICE HILDYARD: That is right, I don’t mean to be

19 harsh on him, but just — we have an awful lot to do and

20 so when you are the mouthpiece, I would prefer it to

21 come through your mouth, and when he is, through him,

22 and for you to take any instructions that you need to

23 behind the scenes rather than waste time in court.

24 MR STROILOV: Right, my Lord. Noted.

25 MR JUSTICE HILDYARD: Thank you very much.

74 :1 MR LORD: My Lord, as far as Ms Blinova is concerned, she
2 has small children, two and three years old, in Russia

3 at the moment. She was obviously originally going to

4 give her evidence yesterday and today. The timetable

5 was half a day for Mr Belykh, and I think even on

6 Mr Stroilov’s larger estimate for the time it was a day

7 and a half for Ms Blinova, so she could reasonably have

8 been thought to be finished today. Now, we will

9 obviously see what we can do, but I do ask your Lordship

10 to bear that in mind: that witnesses have come a long

11 way, and that whatever the appropriate latitude, given

12 the circumstances, appropriate consideration must be

13 given to timing and witness availability, because

14 obviously there are lots of practical and personal

15 arrangements that do turn on this. So I won’t take it

16 any further, obviously, at the moment.

17 MR JUSTICE HILDYARD: Let us see how we go. It may be that

18 we should, if there is to be a break after — well,

19 there will be one more witness in any event, but it is

20 possible that we should start earlier tomorrow in order

21 to finish Ms Blinova, then Ms Patrakova, who needs to be

22 away after an hour’s cross-examination, and then we may

23 have to have a break for Mr Guz.

24 MR LORD: Yes, and we may have to consider sitting a bit

25 later, if it is possible, to get a witness finished.

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Arkhangelsky [Master]

75 :1 I know your Lordship doesn’t favour that, I am not
2 suggesting that would be the norm —

3 MR JUSTICE HILDYARD: We shall see. I do not wish, for the

4 sake of neatness, to have examination when everyone is

5 too tired for it to be worthwhile.

6 MR LORD: I understand, my Lord.

7 Before Ms Blinova comes into the witness box, I am

8 helpfully reminded that the interpreter should probably

9 be sworn in, my Lord.

10 MR JUSTICE HILDYARD: Oh dear. Yes. You are absolutely

11 right.

12 MR LORD: I don’t think they have done much. Well luckily

13 I have been very helpfully reminded. Thank you very

14 much.

15 MR JUSTICE HILDYARD: Thank you, yes. We ought to swear

16 them in, and at some point we need to discuss a request

17 which I still don’t fully understand as to the release

18 of the live stream of the Russian. Anyway, I won’t …

19 MR LORD: Yes, we are not — Mr Stroilov wasn’t sure. We

20 are not entirely sure where that has come from.

21 MR JUSTICE HILDYARD: I think it has come from you, from

22 your side.

23 Anyway, you formulate what you want, then ask for

24 it. If I can give some guidance, I think that anything

25 which goes to one party has to be available to

76 :1 the other, and anything which is intended as a record of
2 the proceedings must be on the court transcription.

3 MR LORD: Right.

4 MR JUSTICE HILDYARD: Thank you very much for reminding me.

5 Yes, we must swear in the interpreters.

6 MR VICTOR PROKOFIEV, Interpreter (Affirmed)

7 MR JUSTICE HILDYARD: Thank you very much. I am sorry not

8 to have brought you to the floor earlier.

9 MR LORD: Thank you, could I call Ms Blinova, please.

10 My Lord, Ms Blinova’s witness statement is in Russian.

11 It is behind divider 9 and it starts at {B2/9/22}, and

12 there is a correction which is in the Russian at

13 {B2/9/45}, and your Lordship will have seen the English

14 translations of both of those documents at the beginning

15 of that tab.

16 ELENA SERGEYEVNA BLINOVA (Affirmed)

17 (All questions and answers interpreted except where
18 otherwise indicated)
19 MR JUSTICE HILDYARD: Ms Blinova, do sit down if you would

20 be more comfortable, as I suspect you would, and if you

21 need water or anything, or a break at any time, you must

22 tell me. I hope you will be provided with water anyway.

23 Examination-in-chief by MR LORD

24 MR LORD: Ms Blinova, could you please give his Lordship

25 your full name and address.

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77 :1 A. My name is Elena Sergeyevna Blinova and I reside in
2 Russia, St Petersburg, Krzizhanovsky Street, number 3/5,

3 flat 131.

4 Q. Ms Blinova, could you please be shown the witness bundle

5 and go to divider 9, please, and if page {B2/9/22} could

6 be opened, please. Do you have that, Ms Blinova? You

7 can see that looks to be the first page of your witness

8 statement.

9 A. Yes, I can see that.

10 Q. And could you please turn in that bundle to {B2/9/43},

11 which looks to be your signature of this statement on

12 26 August 2015.

13 A. That is correct, yes.

14 Q. And have you read that witness statement recently?

15 A. Yes, I have.

16 Q. Ms Blinova, could you please turn to {B2/9/45} in that

17 bundle, so if you could turn on, please, or be shown the

18 next page. You ought to see, I think, a correction

19 which you would like to make to your witness statement;

20 is that right?

21 A. Yes, there is a small amendment.

22 Q. Ms Blinova, can you confirm on oath to his Lordship that

23 the contents of your witness statement, as corrected by

24 this correction, are true to the best of your knowledge

25 and belief today?

78 :1 A. Yes, I can confirm that my witness statement is true to
2 the best of my knowledge and belief.

3 MR LORD: If you wait there, Ms Blinova, there will be some

4 more questions for you.
5 Cross-examination by MR STROILOV
6 MR STROILOV: May it please your Lordship.

7 Mrs Blinova, if we could have on the screen

8 {D93/1166/1}. Then if we could have page 3 of that.

9 I beg your pardon, if we could have page — it doesn’t

10 seem to match. {D93/1166/1}. Then if we could have

11 page 2 of the same document on the other screen

12 {D93/1166/2}. So the Russian version, as you will see,

13 is on one of the screens before you, and then there is

14 an English version for his Lordship.

15 So, Mrs Blinova, this seems to be an e-mail,

16 an internal e-mail from you sent on 24 October 2008.

17 A. Yes, I can see that this is my e-mail.

18 Q. Then there was an attachment to this e-mail. So if we

19 could scroll down on one screen to page {D93/1166/3} of

20 that document, and on the other on page {D93/1166/4} of

21 the same document.

22 So, Mrs Blinova, if you could look at this document

23 and tell his Lordship whether you recollect it.

24 A. I do not recall the details of this document, even

25 though I can see that I did send this document to

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Arkhangelsky [Master]

79 :1 members of the credit committee of the branch, but I do
2 not recall any details.

3 Q. Can you help the court in any way in relation — let me

4 start again, sorry.

5 Do you recall there being the pledge of

6 Western Terminal to secure a loan?

7 A. Yes, of course I do recall that.

8 Q. And do you recall that it was intended that subsequently

9 the land plot would be redesigned, or split into several

10 plots for cadastral purposes?

11 A. No, I have no recollection of that.

12 Q. The Russian term is mezhevaniye or pere mezhevaniye.

13 These are the Russian terms for this kind of thing; do

14 you recall any discussions in relation to that?

15 A. Well, the way I understand it, mezhevaniye means

16 «partition», «separation», «changing cadastral numbers»,

17 or at least this is the way I understand this term.

18 Q. If you could scroll down to {D93/1166/5} and

19 {D93/1166/6} in the same tab. I think, again, it is

20 an issue of unsatisfactory translation, but if you

21 could — so that’s a memo, and I think you can confirm

22 that it purports to be signed — the Russian version

23 purports to be signed by you, well, the first signature

24 is your signature. We don’t see that in the English

25 version.

80 :1 A. Yes, I can see my surname here. That’s correct.
2 Q. So, simply if you could quickly look through the

3 document and see if it triggers any recollections on

4 your part.

5 A. No. I am afraid I do not recollect the details of this

6 document.

7 Q. But are you saying that you haven’t seen this document?

8 A. No, I believe that if this document does contain my

9 signature, most likely I actually drafted this, but

10 because this has been a lot of time since then and I do

11 not recall the details.

12 Q. Right. Thank you. Let me move on.

13 Now, I understand, Mrs Blinova, that there is

14 a certain procedure, essentially, which is followed

15 whenever someone is to give a personal guarantee for

16 a loan.

17 A. Could you clarify your question? I’m not sure

18 I understand exactly what you mean by saying «process»

19 or «procedure».

20 Q. I mean procedure within the Bank so that a number of

21 steps have to be taken before the Bank agrees to advance

22 a loan secured by a personal guarantee, among other

23 things.

24 A. Of course. When reviewing a loan application the Bank

25 looks into various securities that are being offered by

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81 :1 the borrower. Those may include properties, pieces of
2 equipment, and/or suretyships. It can be a guarantee or

3 a personal suretyship. This is the standard procedure

4 and later on the authorised body within the Bank decides

5 what the structure of the deal is going to be. It comes

6 up with certain terms and conditions for that

7 transaction. This is a very brief thumbnail sketch of

8 the procedure.

9 Q. What I am suggesting is one of the things the Bank would

10 do before advancing a loan secured by a personal

11 guarantee, one of the things you would do would be to

12 carry out an assessment of the financial position of

13 the guarantor.

14 A. Well, as a rule, the main security — speaking from my

15 personal experience, the main security is

16 a collateral — in rem collateral, things, risk, things

17 that play the role of the main security. Now, personal

18 guarantee is usually a back-up security, as it were.

19 This is more by way of a moral obligation, rather than

20 an in rem obligation. Quite often the Bank does not

21 look into the financial position or status of

22 the guarantor because this is usually issued by the

23 owner or the ultimate beneficial owner of the business

24 and, consequently, the understanding is, or

25 the intention is, that their financial position is

82 :1 satisfactory.
2 Q. Yes, thank you. Actually this is an interesting

3 subject, and I will come to that. If you could try and

4 focus on exactly on the question as put to you, I think

5 it will be quicker.

6 So, generally speaking, is it a practice of the Bank

7 to assess the financial position of the guarantor before

8 the loan is advanced?

9 A. No, I did not say that.

10 Q. Is it a fact?

11 A. No. No, this is not a fact.

12 Q. Is it normal to ask the potential guarantor to provide

13 life insurance?

14 A. It really depends on the decision made by the specific

15 body with respect to every specific contract, or

16 proposed contract.

17 Q. So there is no general practice to require life

18 insurance?

19 A. No, this is not the general practice.

20 Q. Then I would suggest that — well, it would be normal

21 practice, whenever a guarantee is given, to arrange for

22 a direct debit agreement between three parties: your

23 Bank, the guarantor, and other banks respectively with

24 which the guarantor has accounts, if that makes sense;

25 so that in case of default you would be able to write

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83 :1 off money directly from the bank accounts of
2 the guarantor. Does that make sense?

3 A. I really have no comment to offer on this.

4 Q. Are you saying you don’t understand me because I have

5 put the question poorly, or … shall I try again?

6 A. No, no, I do understand you. It is simply that this is

7 not something within my remit, or within my field of

8 competence.

9 Q. But I thought you were actually doing the administrative

10 work for putting all the papers together for the

11 guarantee contracts, weren’t you?

12 A. That is correct, yes. I am in charge of all the

13 documentation as per the decision that has been made.

14 Q. And I understand that Mr Arkhangelsky was not the only

15 client for whom you would be putting together these

16 documents.

17 A. Of course not. We had quite a few clients like that.

18 Q. So generally, as part of your job, do you recall

19 preparing, among other things, a tripartite agreement on

20 direct debit charging bank accounts of the guarantor in

21 another bank?

22 A. I have no recollection of that.

23 Q. Right. Now, that evidence related to the practice in

24 relation to personal guarantees, didn’t it? Your

25 answers?

84 :1 A. That is correct, yes.
2 Q. What about any corporate guarantees? Does that include

3 any assessment of the corporation’s financial position?

4 A. Well, again, it’s very application-specific. Different

5 decisions may apply to different applications. For some

6 corporations we do look into the financial position of

7 the guarantor; for others we do not. Therefore, the

8 terms and conditions for such tripartite contracts would

9 be a matter to be looked at specifically with respect to

10 each specific instance, or contract.

11 Q. And in this case, do you recall there being any

12 tripartite direct debit agreements in relation to any of

13 OMG loans?

14 A. Sorry, could you be more specific, please, sir?

15 Q. I am sorry, my fault. What I mean is, do you understand

16 the kind of agreement I am talking about, a tripartite

17 agreement with the guarantor, or the lender, for this

18 matter, so that if there is a default,

19 Bank of St Petersburg can write off money of the account

20 of Mr Arkhangelsky, or whoever it is, in another bank?

21 Do you know this type of contract?

22 A. Are you — well, my Lord, may I just ask Mr Stroilov to

23 be more specific?

24 Sir, are you referring to the suretyship, the

25 guarantee contract whereby you described this as

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85 :1 a trilateral contract, or a full loan agreement entered
2 into based on this?

3 Q. (In Russian) Soglasheniye o bezaktseptnam spisaniyi so

4 scheta poruchitelya. Does that ring a bell?

5 Q. Standing order or direct debit agreement; does that make

6 any sense?

7 A. Yes, that type of contract could have been entered into,

8 yes.

9 Q. But do you recall any such contracts being made for OMG

10 loans?

11 A. I cannot recall at this point in time.

12 Q. For any associated guarantees?

13 A. My apologies, are you referring to the direct debit

14 contract or the suretyship guarantee contract?

15 Q. What I mean is that the guarantee is accompanied with

16 this direct debit agreement for the guarantor, and

17 another bank.

18 A. Well, as I have already mentioned, in certain instances,

19 that kind of contract was entered into; in other

20 instances, they were not.

21 In other words, whether or not people enter into

22 that kind of contract is something that is decided by

23 the authorised body of the Bank when a decision is made

24 as to whether a loan should be extended or not.

25 Q. Do you know on what basis this may be required or not

86 :1 required?
2 A. No, I’m not aware of that.

3 MR JUSTICE HILDYARD: Can I just clarify: your evidence is

4 that it is not invariable to require a personal

5 guarantee, and it is not invariable if a personal

6 guarantee is required, to require an ancillary direct

7 debit arrangement so that the guarantee can be enforced;

8 is that your evidence?

9 A. My apologies, my Lord. The last thing that Mr Stroilov

10 said was with respect to direct debit contracts. Now,

11 a DD contract is something which is put in place by the

12 Bank, or sometimes by the client of the Bank, building

13 upon a suretyship contract or a guarantee contract; in

14 other words, it is a tripartite contract between the

15 lender, the Bank, the client and a third party bank

16 where he has third party clients. Therefore, in case of

17 default or arrears, the Bank has the right to write

18 money off third party accounts.

19 Now, with respect to personal suretyship contracts,

20 whether or not they are or are not entered into, as

21 I think I clarified in my witness statement, and again,

22 speaking from my personal experience, every time a large

23 loan was required, or a borrower was branching out into

24 a new field of activity or it was a new client, the Bank

25 did seek to obtain personal guarantees. That is true.

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87 :1 MR STROILOV: Right. Well, could we please have on the
2 screen {D1/2/1}, and in parallel {D1/2/10} of the same

3 document. I beg your pardon, {D1/2/11}.

4 Mrs Blinova, this seems to be quite a detailed

5 opinion prepared by you, apparently, on the proposal to

6 open a credit line for a company called Vyborg Shipping

7 Company; do you recall preparing that document?

8 A. I can see that this is an opinion that I drafted. By

9 and large in the process of preparing for these

10 proceedings, I did read this document. Mind you, it has

11 been many years and I had to refresh my recollection,

12 just to make sure that I remember this.

13 Q. Now, well it is quite a —

14 A. Yes, I did read this.

15 Q. In a way, it is quite a substantive document. You have

16 to analyse the business project, don’t you?

17 A. Yes.

18 Q. And, essentially, you conclude by making recommendations

19 to the Bank what to do and how to do it, don’t you?

20 Don’t bother looking at it at the moment, I am just

21 asking you a general question.

22 A. Yes, at the end of this document there is a clause,

23 terms and conditions offered by the loan officer, and

24 these are drafted, usually by myself, sometimes they may

25 be adjusted, they may be changed by the various

88 :1 signatories, ie the persons who actually sign off on
2 this loan officer’s opinion.

3 Q. And then if we could scroll down to pages 9 and 19

4 respectively. {D1/2/9}, {D1/2/19} «General

5 Conclusions», this is section IX there. Then in

6 the bottom box you see «lending terms proposed by the

7 loan officer», as you have helpfully identified,

8 Mrs Blinova. Then you propose to accept as collateral

9 for each loan:

10 «Mortgage over real estate.»

11 Then:

12 «Guarantee by [Mr] Arkhangelsky without analysis of

13 the Guarantor’s financial condition at the time of

14 the opinion and at the time of monitoring the loan

15 agreements, and without life insurance and accident

16 insurance.»

17 Also:

18 «Guarantee by Scandinavia Insurance Company …

19 without analysis of the Guarantor’s financial conditions

20 at the time of issue of the opinion and at the time of

21 monitoring of the loan agreements.»

22 You do seem to take a view on these matters, don’t

23 you?

24 A. Yes.

25 Q. And then if you look at point 6 in the same box, you

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89 :1 propose not to arrange for any of the tripartite
2 agreements we discussed, bezaktseptnam spisaniyi.

3 A. Yes, I can see this clause here.

4 Q. So what do you think were your reasons for recommending

5 this?

6 A. I have no recollection of this, not sitting here today.

7 Q. But presumably you prepare these kind of reports as part

8 of your job from time to time. This is not something

9 extraordinary for you, is it?

10 A. Well, obviously I do look into the application. I come

11 up with an opinion, I do financial analysis and, based

12 on that, I come to certain conclusions.

13 But, sitting here today, I simply do not recall why

14 I made this recommendation.

15 Q. In principle, what might be the possible reason for,

16 say, dispensing with the requirement of that tripartite

17 direct debit agreement. Is there any possible reason

18 you can think of?

19 A. Are you inviting me to think in abstract, or in relation

20 to this specific agreement? This is very complicated,

21 because every deal is individual and that’s why

22 consideration has to be given to a loan. For every

23 transaction there could have been some special, specific

24 terms. Now I do not recall why, in this specific deal,

25 I did not state, or stated these provisions, I cannot

90 :1 recall. Basically eight years has gone by.
2 Q. Correct me if I am wrong: I suppose that your starting

3 point is that it is safer for the Bank to carry out

4 an assessment of the guarantor’s financial position.

5 A. With regard to a specific guarantor,

6 Scandinavia Insurance company, as I have seen from the

7 documents in the preparation process and from my

8 recollection, contemporaneous recollection, I recall

9 that the company itself was the Bank’s client, I mean

10 the Scandinavia Insurance Company, and an agreement was

11 concluded with it with regard to promissory notes —

12 I do not recall the details because another Bank’s

13 employee was dealing with that — but the financial

14 analysis of that company was done by the Bank

15 nevertheless.

16 Q. Is there any — again, I suppose it is, generally

17 speaking, in the Bank’s interest to be able to use

18 direct debit, soglasheniye o bezaktseptnam spisaniyi, to

19 recover the money directly from the guarantor’s account

20 in another bank. Your starting point would be that this

21 is in the Bank’s interest.

22 A. Could you please specify your question? I didn’t quite

23 get it.

24 Q. I mean when you make your decision what to recommend to

25 your superiors, you think along these lines: there

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91 :1 should be a direct debit agreement, soglasheniye o
2 bezaktseptnam spisaniyi, unless there is a good reason

3 why there shouldn’t be; isn’t that your approach?

4 A. With regard to the reasons why there could have been no

5 direct debit agreement, we, the Bank, has considered the

6 level of turnover on the settlement account on

7 a specific client’s settlement account in our Bank and

8 other banks, and if the cash flow in other banks, for

9 the moment of consideration were insignificant, then the

10 Bank had the right, and as far as I recall that was

11 standard practice, the Bank had the rights not to demand

12 a direct debit from the banks where the cash flow was

13 insignificant.

14 I described a general situation as to in what cases

15 the Bank might not necessarily seek a direct debit

16 agreement.

17 Q. Of course.

18 MR JUSTICE HILDYARD: Is that a good moment to pause?

19 MR STROILOV: I think it is, my Lord, yes.

20 MR JUSTICE HILDYARD: I noticed that, quite understandably,

21 the interpreters work in relay and I suppose we need to

22 swear in the other interpreter as a matter of form now

23 that the matter has been raised.

24 MR LORD: We will arrange for that, my Lord, yes.

25 MR JUSTICE HILDYARD: 2.00 pm.

92 :1 Now, Ms Blinova, you mustn’t discuss this case with
2 anybody else. You must find other, more enjoyable

3 topics.

4 A. Thank you, certainly, my Lord.

5 MR JUSTICE HILDYARD: 2.00 pm.

6 (1.04 pm)
7 (The Luncheon Adjournment)
8 (2.05 pm)

9 MR STROILOV: May it please your Lordship, and I apologise

10 for the late start, I had to make some logistical

11 arrangements.

12 MR JUSTICE HILDYARD: Can we swear in the interpreter so

13 that we have completed the necessary?

14 MR ARKHANGELSKY: Your Lordship, I’m so sorry, I have one

15 small question. Here in the room we don’t have any

16 translations, so it means that my wife, she is eager to

17 participate, but only when it would be possible to

18 have a translation here, and I would also prefer to

19 have, when the Russian witnesses are speaking, that

20 I hear them in original voice and not in

21 the translation, if possible. So we would need,

22 theoretically, both languages here, but I have been told

23 by the organisers that it is not technically possible.

24 It has not been ordered in advance.

25 MR LORD: The true position is it can be provided, a dual

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93 :1 language, an English and a Russian. The Russian is
2 going to need some sort of mobile phone connection to be

3 set up, and we’ve inquired when Mrs Arkhangelskaya is

4 going to be there so we know when to make these

5 arrangements, and we have not been told when that is to

6 be. We had not understood we had to go for these

7 lengths for Mr Arkhangelsky, including, for example, on

8 days when he is not there at all, like yesterday. All

9 these things, as your Lordship will appreciate, cost

10 an awful lot of money. This trial a costing a lot of

11 money and so, therefore, the answer is that it is

12 technologically possible, it will cost money, and we are

13 waiting to be told — we had understood it was

14 Mrs Arkhangelskaya who might need a Russian feed into

15 Nice and we have waited to be told and are invited to be

16 told if and when that facility should be put into

17 effect.

18 MR JUSTICE HILDYARD: When Mr Arkhangelsky is reading his

19 laptop, is that the Russian version or is it the English

20 version?

21 MR LORD: It is the English version, I think.

22 MR JUSTICE HILDYARD: Yes.

23 MR ARKHANGELSKY: Yes, it’s only the English version,

24 I think there is no possibility for Russian version. My

25 wife will be here as soon as it is possible to organise

94 :1 a proper hearing. I suggest that by Thursday morning we
2 want to have it in place and tested, just to avoid

3 wasting of court’s time.

4 MR JUSTICE HILDYARD: I shall think about this,

5 Mr Arkhangelsky, and I shall inquire as to the cost, and

6 whether the only funders are prepared to fund it and

7 exactly how, technically, it would work.

8 Whilst I am anxious, of course, that you should be

9 able to participate, the technical difficulties and

10 expenses are considerable, as I am led to believe, and

11 my understanding was that it was extremely difficult for

12 your wife to attend more than occasionally, because she

13 has the children to look after and your house to

14 maintain whilst you are holding the fort in the room in

15 Nice.

16 I think that I am prepared to assist you, but not to

17 indulge you, and I think I must consider carefully what

18 truly is involved and whether it is proportionate to

19 require a daily feed of the Russian evidence as well as

20 the arrangements which are already in place.

21 There we are.

22 MR ARKHANGELSKY: Okay, thank you, but —

23 MR JUSTICE HILDYARD: I think I must ask for the interpreter

24 to be sworn in, as I had asked, and then we must

25 continue without further ado with the cross-examination,

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95 :1 because we do want to press on with these matters.
2 MS ELENA EDWARDS, Interpreter (Affirmed)

3 MR JUSTICE HILDYARD: Thank you very much, and thank you

4 both for the work you are doing, which is very

5 impressive.

6 Yes, Mr Stroilov.

7 MR STROILOV: May it please your Lordship.

8 Can we please have on the screen {D37/621/0.1}.

9 I apologise, it is not a great translation, but apart

10 from one bit, there isn’t much substance in it, and

11 simultaneously could we have on the other screen from

12 the same tab {D37/621/1}.

13 Mrs Blinova, can you see the document in Russian

14 before you on the screen?

15 A. Yes, I do.

16 Q. So this is one of the reports which are prepared

17 periodically at Investrbank. The purpose of this report

18 is to set out the work done to date, at whatever date it

19 is, to recover an outstanding problem debt that is

20 discovered.

21 A. Yes, overall these reports are reports on the work with

22 the problem debts.

23 Q. So this particular one relates, I think, to the loan to

24 Vyborg Shipping, the first Vyborg Shipping loan; is that

25 correct?

96 :1 A. Yes.
2 Q. If you could now scroll down one page on each screen?

3 You will see near the bottom of the first page,

4 there starts a section called «Accomplished work». Have

5 you seen that?

6 A. Yes, I can see that.

7 Q. If you could scroll down another page on both screens.

8 You see it continues, you see the dates on the left

9 and then one more page at the bottom. And on the other

10 screen as well, if we may. {D37/621/4}, {D37/621/0.4}.

11 It will be 0.4, won’t it. I see, sorry, I am afraid it

12 is pretty much confused translation.

13 But let’s look at the Russian version. There isn’t

14 much substance I want to discuss.

15 So that’s your signature, isn’t it?

16 A. Yes, it is. As far as I can see.

17 Q. There are really dozens, perhaps hundreds, of such

18 reports, isn’t that the case?

19 A. I didn’t count them. I wouldn’t be able to evaluate the

20 numbers.

21 Q. What I’m trying to understand is how, exactly, they are

22 compiled. That is to say, well my understanding is,

23 that whenever you see various — in this chronology

24 section, which is the longest section, you see various

25 steps the Bank has taken, you see them recorded, don’t

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97 :1 you?
2 A. Yes.

3 Q. And I understand that these reports are produced

4 periodically, approximately every few days.

5 A. As far as I can see, approximately once a week they are

6 being drafted.

7 Q. And is that your recollection, that they are being

8 compiled approximately once a week?

9 A. Judging by the dates I can see, thereabouts, about once

10 a week or once every two weeks.

11 Q. So what happens, each report is similar to the previous

12 one, except then one or two entries are added in the end

13 of the chronology?

14 A. Apparently at the moment of drafting each of such

15 reports, new information is added, should there be any

16 new information. Should there be no changes, we state

17 that there were no changes.

18 Q. And, Mrs Blinova, you are using the word «apparently»,

19 but surely you have been working on this report, so you

20 must have your own recollection how this is done?

21 A. The report was drafted, one could put it this way, by

22 a method of accretion, accumulation. Initially if the

23 debt is overdue, it becomes overdue, a report is

24 drafted, and henceforth, on a weekly basis, or maybe

25 once every ten days, the report would be updated by

98 :1 introducing additional information, and what we have
2 learned as of one of the dates, for example, as of

3 1 October 2009, and this describes what work has been

4 performed.

5 Q. Yes. Most of these reports which we have seen are

6 either signed by you or they are signed by the lady

7 called Mrs Borisova, and you are identified as the

8 responsible executor, that’s otvetstvennyi ispolnitel.

9 A. Yes, this is correct.

10 Q. So can you explain what is the difference between

11 actually being someone who signs the report and being

12 a otvetstvennyi ispolnitel, responsible executive.

13 A. The responsible executive drafts the actual report

14 directly, and head of the section, Mrs Borisova in this

15 case, would check it, would get familiar with the

16 information I have entered, analyses the reports and can

17 introduce some amendments or additions should that be

18 necessary.

19 Q. Thanks. And that is something that is done in relation

20 to each problem debt?

21 A. Yes. With regard to each problem credit agreement.

22 Q. So presumably there is some internal rule in the Bank

23 whereby the Investrbank branch has to put together these

24 reports?

25 A. As far as I recall, at that period of time there was

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99 :1 a set of rules of how to work with problem debts, and
2 drafting such reports was one of the items stated in

3 the rules.

4 Q. So what happens, supposing we have a report where you

5 are the responsible executor and Mrs Borisova is the

6 signatory, just by way of example. So you sit at your

7 computer, open the previous report, add one or two

8 entries, print it out and bring it to Mrs Borisova to

9 check. Is this how it works?

10 A. As far as I recall, yes, about this way.

11 Q. Is there any point where I’m wrong?

12 A. Sometimes I send these reports to Mrs Borisova by e-mail

13 to be familiar with. Overall, you have described

14 everything correctly.

15 Q. Then, presumably, she would have to print it out and

16 sign it?

17 A. She could have printed it, I could have printed it. We

18 were in the same room on the same premises, and just

19 solved these matters on an ongoing daily basis.

20 Q. Once the report is completed, what happens to it?

21 A. Mrs Borisova would read it, would initial it if she has

22 no remarks, and then — now I do not recall exactly all

23 the details, perhaps she would have sent it to someone

24 from the head office of the Bank, to the person

25 responsible for work with problem debts. This is the

100 :1 way we report it to the head bank about the branch’s
2 operations, and, overall, on the work done by the Bank,

3 because in working with problem debts, we had both the

4 branch employees and the legal department was involved,

5 and they reported to the head office and other services

6 could have been involved — now I do not recall exactly

7 the full list.

8 Q. Right. So would they also be kept on the loan file,

9 these reports?

10 A. As a rule I reflected in the file all the information

11 available to me that I received at a specific point in

12 time from the various bank departments, services.

13 Q. No, what I mean is there is a file permanently kept

14 called — I think it is called kreditnoye dossier in

15 Russian, and in these proceedings that has been

16 translated as «loan file», in relation to each loan.

17 A. Yes, for each credit agreement the so-called set of

18 documents is formed, or a pack of documents, and all the

19 documents related with working on a specific loan are

20 added there, collated there.

21 Q. And would these reports, of the kind we are looking at,

22 would they go into that file?

23 A. As a rule, this is correct.

24 Q. So what I mean is that normally the loan file would

25 contain a chronological set of these reports. The first

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101 :1 ones will be fairly short and then you will see
2 something more like what we see on the screen where you

3 have entries for a substantial period of time. You

4 would have that?

5 A. Yes, overall you are correct. Each of the reports is

6 added to the credit file, to the loan file.

7 Q. And would you expect a similar chronological set of all

8 the reports to be kept in some other department of

9 the Bank as well?

10 A. Sir, could you please specify your question: do you mean

11 with regard to these credit agreements, or in general,

12 or the general practice?

13 Q. Let me split it into two, actually. What is the general

14 practice?

15 A. At that point in time, talking about 2009, I think it is

16 important to note the credit files were kept at the

17 Investrbank branch, and the reports were added there.

18 However, as far as I know, but I cannot assert for sure,

19 because starting from 2011 I already was on my first

20 maternity leave, and then I came back briefly to work

21 and then I left again on maternity leave. As far as

22 I know, subsequently some restructuring of the Bank’s

23 operations has been carried out and the credit files, or

24 the loan files, were transferred to the head office, to

25 the client monitoring department, and with regard to

102 :1 problem debts, I’m not quite sure to what departments
2 these were sent. Maybe there was a separate department

3 working with problem debtors. Unfortunately I cannot

4 state at what time period that happened and, speaking

5 for 2009, the files were kept at Investrbank and, as

6 I have already mentioned, such reports were collated in

7 a specific section called the loan file.

8 Q. Right. And obviously this work, you and Mrs Borisova,

9 those were the only ones who were doing that work,

10 compiling these reports, as I understand it. Basically,

11 let me reformulate it. Basically, it is not possible

12 that two people would be doing the same work in

13 parallel; it would be just someone producing that

14 report — it is not a large work — and adding it to

15 the file; is that how it works?

16 A. If I was the responsible executive at that point in

17 time, working with Vyborg Shipping Company, then I was

18 the executive for that report, I was producing the

19 report, as I said, and Mrs Borisova controlled, checked

20 me, and initialled these reports.

21 Q. Yes. Now, if, perhaps, we could on both screens scroll

22 down one page. Can we go to {D37/621/0.4}. Sorry, this

23 is very — sorry, I was wrong. Can we have page 3 on

24 one screen and page 0.3 on the other. {D37/621/3},

25 {D37/621/0.3}

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103 :1 What I am looking at is the entry of 26 June 2009.
2 I think the translation for it is not quite

3 satisfactory, so for convenience I can hand up my own

4 translation, but then we will ask Mrs Blinova to read it

5 out in Russian so that we have a sworn translation as

6 well. (Handed).

7 Mrs Blinova may not need it. I understand that her

8 English is limited.

9 There is one for his Lordship, and it has been

10 indicated to me that the translators may need both

11 versions of documents. (Handed).

12 So you do recall putting that entry into these

13 reports, don’t you?

14 A. Sorry, can you specify, can you repeat the date one more

15 time, please?

16 Q. That’s 17/06/2009. 17 June. That refers to

17 the decision of the management board to provide the

18 Bank’s consent for the transfer of the pledged assets to

19 SKIF LLC from Western Terminal LLC, preserving the

20 pledge to the Bank; do you recall anything about that?

21 A. No, not really. I do not recall this. I have no

22 recollection of this.

23 Q. But do you recall this entry being put into the report?

24 A. Well, I can only speculate that as I have already

25 mentioned, I was drafting this report based on the

104 :1 feedback that I received from the various departments of
2 the Bank that had something to do with their problem

3 loans.

4 So, for all I know, they may have given me this

5 information with respect to the management board

6 decision, but so far as the gist of the matter is

7 concerned, I am afraid I cannot offer any comment.

8 Q. Yes, of course, I am not asking you to, don’t worry

9 about that.

10 In 2013 the defendants in these proceedings were

11 given disclosure by the Bank, and conveniently we have

12 something like 170 of such reports relating to all four

13 Vyborg Shipping loans, put together in two neat files

14 like this, and I will hand them around in a moment.

15 So that means that we didn’t have to look for these

16 reports scattered across individual loan files, which

17 were marked, respectively, A, B, C and D. We would only

18 look in file F and find all the reports neatly in one

19 place.

20 However, most of these reports would also be

21 duplicated in files A, B, C and D. So we will have, in

22 theory, two chronological sets — more or less similar

23 chronological sets of these reports; do you follow that?

24 A. Well, not altogether, not entirely.

25 Q. We have — what you see on the screen, and you can see

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105 :1 there are 55 pages, so that is taken from one of
2 the loan files. That’s a set of — I’m not sure just

3 quite how many, but probably something in the region of

4 20 reports, one following another, the reports which you

5 have prepared at the Bank, and that comes from the loan

6 file as disclosed to us; do you understand that?

7 A. My Lord, with your permission, do I understand

8 Mr Stroilov as saying that for every one of the four

9 loan contracts, the reports were quite similar, they may

10 have been quite similar to each other, because we had to

11 include that kind of opinion into every loan file,

12 because on the very first page you have reference to

13 the number of the contract. So there may have been some

14 overlap here, but that was the procedure, that was the

15 process.

16 Q. Now, we have — what you see on the screen, we had that

17 in file A, which was the file on the first

18 Vyborg Shipping loan, and therefore here we have

19 a chronological set of these reports for the first

20 Vyborg Shipping loan. I just want you to follow this,

21 because in the end of it there may be a rather important

22 question.

23 So do you understand how it works? We have file A

24 on the first Vyborg Shipping loan, we have file B on the

25 second Vyborg Shipping loan, we have file C on the third

106 :1 Vyborg Shipping loan, we have file D on the fourth
2 Vyborg Shipping loan; do you understand that?

3 A. I do understand.

4 Q. Yes, all of them contain lots of documents which you

5 would find in the loan file, and that includes certain

6 chronological sets of bad debt reports, of problematic

7 debt reports. You do follow that, don’t you?

8 A. Well, I understand that you are now describing the files

9 that have been disclosed for the purposes of these

10 proceedings. Now, I do not know whether they were filed

11 in a chronological order or not.

12 Q. Of course, you cannot, I am not asking you about that,

13 I just want you to understand — that’s a very long

14 question, in a way.

15 But separately from that, we have something called

16 file F, where we have 170 reports for all four

17 Vyborg Shipping loans arranged chronologically. Let me

18 give you a copy, so that you see what I mean. (Handed).

19 I beg your pardon, it must be my fault. Both

20 volumes should go to the witness and another two volumes

21 have to go to the judge. (Handed)

22 MR JUSTICE HILDYARD: I’m not sure I fully understand. Are

23 these files copies of files which, in this state, were

24 in the Bank’s records, or are these files of documents

25 which you have assembled and put into the files?

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107 :1 MR STROILOV: My Lord, this is an exact copy of what was
2 provided to us for inspection as part of the disclosure

3 process.

4 MR JUSTICE HILDYARD: Thank you very much.

5 MR STROILOV: So apart from the loan files, A, B, C and D,

6 we have this file F.

7 Now, if we look, again, at this — I am sorry,

8 I think we need to scroll down on both screens, if we

9 can. {D37/621/0.4}, {D37/621/4}. The report we are

10 looking at is first Vyborg Shipping loan report, it is

11 the last entry, 1 October 2010. Let me try and find it

12 in this file too, it should be duplicated here.

13 I’m sorry, my Lord, it is taking some time.

14 So that will be in tab 88 of the paper bundle.

15 That’s F1/88, and if you could kindly go to the last

16 page.

17 So, Ms Blinova, this should be identical to

18 the report we see on the screen. Obviously that’s the

19 report compiled shortly, or on 1 October, shortly after

20 1 October, isn’t that correct?

21 A. Is this a question?

22 Q. Yes, it should be identical, shouldn’t it?

23 A. I really don’t know. Not necessarily.

24 Q. From the process you have described, Mrs Blinova, there

25 is — it’s only once that you compile a report ending on

108 :1 the first Vyborg Shipping loan which ends on 1 October,
2 isn’t that right?

3 A. I drew it up once, and of course it’s usually drawn up

4 within one day, ie on the day when I actually write it,

5 when I actually write it up.

6 Q. Yes. Well, using the paper file you have in hand, if

7 you go back one page, and simultaneously if you could

8 scroll up on both screens, one page up, {D37/621/0.3},

9 {D37/621/3}, can you find in the paper version the entry

10 of 17 June 2009?

11 A. No, I do not see it in hard copy.

12 Q. Then if you look at the screen, you do find it, don’t

13 you?

14 A. Yes, I can see that.

15 Q. And other entries around it, they match, they are

16 identical; it’s the same report.

17 A. I can see that the date of both reports is 2 October.

18 Q. And that is — I won’t say that’s — I think there is

19 another entry which is missing, but there are only two

20 entries which are missing.

21 If you look at, just for completeness, that’s not

22 something I am inviting any inferences from, but if you

23 go one page up as well, on everywhere, in the paper

24 version, on one screen and on the other screen

25 {D37/621/0.2}, {D37/621/2}, you will see another entry

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Arkhangelsky [Master]

109 :1 of 2 April 2009, which is also missing from the paper
2 version but is there in the electronic version.

3 A. Could we scroll one page up on the screen?

4 Q. Yes, I am sorry, yes, if we could. Yes, that is the

5 translation problem, I am afraid. If we could, then,

6 scroll down on the Russian screen, could we scroll down

7 one page. {D37/621/3} — no, I don’t think so. That

8 will be the second entry in the Russian version, the

9 second entry on the page you see. Yes, in the English

10 version I think it is also — if you can scroll down as

11 well, I’m terribly sorry to … {D37/621/0.3} so there

12 is another entry which is there in the electronic

13 version and comes from the loan files, but not in

14 the paper version which was given to us in this

15 admirably neat form.

16 Now, Mrs Blinova, which of them is genuine?

17 A. I really have no comment to offer on this. I simply do

18 not recall, sitting here today, any of those details,

19 any of those things and acts that we did with respect to

20 this particular loan. I just do not recall. I would

21 love to assist the court, but I cannot.

22 Q. Mrs Blinova, we have two documents which purport to be

23 the same document, both have your signature under them,

24 but they are different. I am asking you: which one is

25 a forgery?

110 :1 A. I don’t think that either of them is a forgery and I am
2 afraid I cannot answer your question because I simply do

3 not recollect what happened at that time.

4 Q. Now, would you like — well, take volume 2 of the paper

5 file. Would you mind opening any of the reports at

6 random, and just tell us the number.

7 A. Tab 102.

8 Q. 102. Now, can you try to find the entry of 17 June

9 here?

10 A. My Lord, with your Lordship’s permission, I would like

11 to clarify — I would like to explain — and, again,

12 this is pure speculation on my part because I do not

13 recall all these entries, there have been quite a few of

14 those every single week — as I have already mentioned,

15 the information with respect to problem loans kept

16 coming to us from different sources, from different

17 people who were employed by the Bank, and that

18 information could have come to us via telephone, via

19 e-mail — I mean for the purposes of this particular

20 report — and sometimes recalling our work with other

21 problem borrowers, we sometimes made adjustments.

22 Just to give an example, for instance, a lawyer says

23 to us that the hearing of the court should happen on

24 1 June, so I make an entry to that effect, but then the

25 hearing is postponed, so I sometimes had to adjust that

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111 :1 information.
2 My Lord, just because something is missing does not

3 mean that this is a mistake. Again, I am speculating

4 because I do not recall exactly what happened at that

5 particular time with respect to this particular matter.

6 Q. Mrs Blinova, I think that what you are talking about,

7 what would happen, you have compiled a report with

8 slightly inaccurate information, then you make

9 a correction. So what we would have, so in the next

10 report, on the same loan, there might be a slight

11 change, there might be something deleted. I have no

12 problem with that. But what we have here is a complete

13 chronological set of documents which purport to be

14 identical sets, more or less. Now, you see there are

15 duplicates, there are dozens of duplicates, dozens of

16 pairs of documents which purport to be the same, in most

17 cases with one difference, and that’s the entry of

18 17 June, about the transfer of the assets to SKIF.

19 In some cases there is something with ships on which

20 I don’t rely, but in relation to each of the four loan

21 files, we have many pairs of documents which are

22 supposed to have been compiled chronologically, and one

23 of these chronological sets or the other has been

24 fabricated.

25 A. I really have no comment to offer. I simply do not

112 :1 recall what happened and/or what changes were made.
2 I simply don’t recall.

3 Q. The trouble is we see your signature on both versions.

4 A. As I already mentioned, if someone tells me, including

5 someone who was supervising me, with respect to

6 the drawing up of these reports, someone tells me that

7 there is a mistake in one of the reports, then logically

8 I have to remedy the mistake. I have to make

9 a correction.

10 Q. That makes a lot of sense, Mrs Blinova, that makes a lot

11 of sense, but someone in the Bank has done a huge work.

12 Just at one point prior to the moment when disclosure

13 was given, someone recovered the old files from the

14 computers, deleted one entry, in some cases two entries,

15 printed out all the new reports and compiled these two

16 very elegant files. Isn’t that an inevitable inference?

17 A. Again, I have no comment to offer. I have nothing to

18 say.

19 Q. Well, do you know anything about this?

20 A. What do you mean by «anything»?

21 Q. About the fabrication of just under 170 — because

22 earlier ones don’t count — about the fabrication of

23 these reports. Two arch lever files of documents have

24 been fabricated. What do you know about this?

25 A. I do not know anything about this. There is no comment

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113 :1 I can offer on this.
2 Q. What about your signature?

3 A. Well, again, my only explanation, the only explanation

4 I can come up with is that I may have been making

5 changes by hand if it came to my attention that there

6 was a mistake somewhere. Now, apart from this, there is

7 nothing I can add.

8 Q. Of course you could have changed it, that’s not the

9 point, but it didn’t happen 170 times, so this means it

10 happened once, and you have changed 170 documents, or

11 just under 170.

12 A. I did not compare, nor am I in a position to compare

13 those sets of documents. Once again, I have no comment

14 to offer with respect to this disconnect, apart from

15 what I have already said.

16 Q. Ms Blinova, you can take your time on it and we can

17 compare each of these duplicated documents. There will

18 be dozens, but we can go through them all if necessary.

19 Are you disputing that this is the case? That in one of

20 these chronological sets, in each document one entry is

21 missing?

22 A. I’m not sure I understand the gist of your question,

23 sir.

24 Q. But do you —

25 A. Within the framework of these proceedings, I was shown

114 :1 some documents. They are all attached to my witness
2 statement, and I am afraid, apart from that, there is

3 not much that I can think of, or I can recollect.

4 Q. So even though these documents bear your signature, but

5 you say you can only give evidence about documents

6 attached to your own witness statement, is that what you

7 are saying?

8 A. Those documents were shown to me. I read those

9 documents, I perused them and I went by those documents

10 in preparing my witness statement. I cannot offer any

11 comment with respect to your question.

12 Q. Mrs Blinova, Mrs Blinova, I appreciate you have been

13 very well prepared. I give you all the credit for it,

14 and now you have sworn to tell the truth; will you

15 please do so.

16 A. I am telling the truth. What I am saying is there are

17 certain things that I’m aware of, including the fact

18 that I was in charge of drawing up those reports. I do

19 not remember with respect to every single date what was

20 or was not written there. I really have nothing to say

21 about this.

22 Q. Mrs Blinova — Mrs Blinova, I have spent several

23 months —

24 A. I left the Bank some time ago.

25 Q. — thinking about this and trying to find an innocent

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115 :1 explanation. If you have one, now is the time to give
2 it. Take your time, think about it, give us

3 an explanation.

4 A. There is no explanation to offer, apart from what I have

5 already said. I have nothing to add.

6 MR STROILOV: Thank you, I will move on.

7 MR LORD: My Lord, I think Mr Stroilov needs to make it

8 clear exactly what is being put to this witness. There

9 are a whole series of documents in this file that he has

10 now put to the court, seemingly signed by this witness.

11 I don’t know if he is suggesting that she has fabricated

12 every one of these documents. I’m just tracking down

13 when the document on the screen that has «the entry» in,

14 when that was disclosed, in what file that was. Does

15 your Lordship follow the point?

16 MR JUSTICE HILDYARD: This witness appears to have signed,

17 or Ms Borisova appears to have signed, versions of the

18 same reports which, in one series contained, for

19 example, this entry on 17 June, and another entry on

20 2 April, I think it is; and in another sequence did not,

21 and either this witness or Ms Borisova, in each case,

22 appears to have signed both sequences.

23 MR LORD: And, so your Lordship understands, the document

24 with the entry in was — my understanding is —

25 disclosed at the same time in the A file. So my

116 :1 understanding is that in the A file, for the specific
2 loan, the document with the June entry was in.

3 MR JUSTICE HILDYARD: Yes.

4 MR LORD: And it is in this F file for disclosure that there

5 is another long run where this isn’t in.

6 So it’s not the case that what we see on screen was

7 not disclosed at the same time.

8 MR JUSTICE HILDYARD: I think what’s being suggested —

9 I don’t know quite what is suggested, I think you had

10 better clarify it and put it straight to the witness,

11 but I’m beginning to feel that what you are suggesting

12 is that there was a sort of system of double entry, in

13 a sense, that on one file there was disclosed and on

14 another file there wasn’t disclosed.

15 MR STROILOV: No, both files were disclosed, I do

16 apologise —

17 MR JUSTICE HILDYARD: No, no, I am so sorry, I have used the

18 wrong word. Leave aside the proceedings, that the Bank

19 appears to have a file which did have these dates and

20 a file which didn’t have these dates, and I think you

21 are suggesting that there is some kind of dishonesty or

22 otherwise in having a double entry, twin sets of books

23 which don’t match up; is that what you are suggesting?

24 MR STROILOV: Not really. Let me then take it a little

25 further with Mrs Blinova.

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117 :1 MR JUSTICE HILDYARD: What I think you can say at the
moment
2 is, in the new files, I dare say, you know, it isn’t

3 a sort of conjuring trick, if I may say so, I dare say,

4 as you say, whichever tab after a certain date will be

5 disclosed documents in these files which do not contain

6 the relevant entries for June and April, and in

7 the other files there do.

8 MR STROILOV: Yes, quite.

9 MR JUSTICE HILDYARD: Now, you don’t need the witness,

10 I will take it from you that that is the case, but what

11 is the punch line?

12 MR STROILOV: Let me take it a little further.

13 MR JUSTICE HILDYARD: Yes.

14 MR STROILOV: So, Mrs Blinova, I put it to you that over 150

15 documents have been fabricated in the Bank in order to

16 conceal a particular one transaction.

17 MR JUSTICE HILDYARD: Conceal from whom? They haven’t been

18 concealed from you because you have both versions. But

19 what are you putting to the witness is the purpose of

20 this?

21 MR STROILOV: I don’t know. I’m trying to make

22 her ascertain this.

23 MR JUSTICE HILDYARD: Right, well ask her what the

24 purpose — whether she can think of any other

25 explanation.

118 :1 MR STROILOV: I’m trying to think. Well, obviously it may
2 be that the genuine documents were overlooked, they were

3 scattered around the loan files. They were not in one

4 place, and this file F was kind of — well, the first

5 thing you see if you are looking for the bad debt

6 reports. So that’s what I’m saying. I don’t have

7 an explanation. I’m trying to get one, really.

8 But what I am suggesting to this witness is that if

9 one — that the purpose of fabrication — it appears

10 that there has been a fabrication; do you accept that?

11 MR LORD: Sorry, my Lord, it is fair to put to this witness

12 that there are signatures, on each of these disclosed F

13 file reports that are said to be fabrications, there are

14 signatures on them and because entries are added as time

15 goes by, the formatting is not exactly the same. So it

16 seems to be the suggestion that there has been

17 a fabrication of the whole document, in other words, not

18 just a single page could have come out, but the whole

19 file has been fabricated. But it must follow, I think,

20 that this signature, which appears to be this witness’s

21 signature on many of these reports has also, somehow,

22 been part of the fabrication. So I do think this needs

23 to be put very clearly, so we understand what

24 the alleged fabrication is, and also, what, if any, is

25 this witness’s alleged implication in that dishonesty?

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119 :1 MR STROILOV: I thought I made that clear enough. Obviously
2 I can’t know the exact purpose.
3 A. I’m very sorry, I’m very sorry, but you are saying that
4 you — that all F1 reports are having this entry
5 missing. I opened 46. With regard to a loan agreement,
6 number 3500-081279, there is a date there of 17 June,
7 and the information is the relevant information.
8 Q. Yes. Well, can we look a little further? Can we look
9 at 47, then. I think we will take it in stages. This
10 relates to the loan agreement with the number ending
11 1279. Let’s find the next one, that will be at 53.
12 A. I would like to draw my Lord’s attention that there is
13 a signature of the branch’s director in these tabs.
14 Q. Yes, Mr Platonov, that’s right. Oh yes, well spotted,
15 Mrs Blinova. So if you see the — so the document 46,
16 that’s one where you were not involved; is that right?
17 It is signed by Mr Platonov and the responsible executor
18 was some lady called Smolska(?) but not you.
19 A. Possibly.
20 Q. And then the next report at tab 53, if you look towards
21 the end, there you will see your name as the responsible
22 executor, and the entry is not there. There are four
23 sequences, I am afraid. That’s why we go there, just to
24 be sure.
25 So if we look at 47, there again we have you,
120 :1 Mrs Blinova, as the responsible executor, and then is
2 that entry there? It isn’t.
3 Mrs Blinova, I’m genuinely asking you — and I think
4 I made that clear before — to shed some light on this.
5 What I’m suggesting is that this is a clear evidence of
6 fabrication of documents.
7 MR JUSTICE HILDYARD: Mr Stroilov, I for one, and I am so
8 sorry that I may well be the slow coach in court here,
9 but I just want to try and unravel this and try and
10 understand, without putting labels, which may be
11 justified, may not be justified, but which will obscure
12 until we have found out what the facts are.
13 Ms Blinova, my understanding of the facts are that
14 these documents produced once a week or once every ten
15 days, in a sense were iterative documents; that’s to say
16 they were added to as time went on. And they may
17 also —
18 A. Yes, my Lord.
19 MR JUSTICE HILDYARD: — have been revised as time went
on,
20 according to information received by whatever manner.
21 A. Yes, my Lord.
22 MR JUSTICE HILDYARD: But there was only one version.
There
23 was only — from week to week, you didn’t have two
24 versions of the same report, just the one, which you,
25 when you were the executive officer, you signed; is that

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Arkhangelsky [Master]

121 :1 right?
2 A. Absolutely, I was drafting the report and the

3 information I knew as of a specific point in time was

4 reflected by myself in the reports, and if I would

5 receive different information from one of the Bank

6 employees at the next point in time, it was logical, as

7 to not to mislead anyone, that I would come back and

8 correct the report.

9 If, for example, I’ve made ten incorrect reports,

10 let us suppose, and that would be found out, I had the

11 duty to correct my error in all the previous reports

12 because, and I shall repeat myself, the loan file in

13 Russia with the part in working with problem debts was

14 extremely important at that point in time for the Bank,

15 and the Bank had to report to the Central Bank about

16 this work being done.

17 So I had to enter information known to me at that

18 point in time.

19 MR JUSTICE HILDYARD: Yes.

20 A. Which is what I did.

21 MR JUSTICE HILDYARD: Yes, but what is odd — and this is

22 what I need your help about — is that in one of

23 the sequences of signed reports there is the inclusion

24 of a date, and you sign it, and in another sequence

25 there isn’t, and you sign that; and, according to

122 :1 whether one sequence did contain that entry, all
2 subsequent documents within the same sequence contain

3 that entry, if signed by you, and in the other sequence,

4 where it wasn’t contained, all subsequent documents do

5 not contain that entry as signed by you.

6 What you are being asked, given your evidence that

7 there was only one report ever signed by you, is how

8 a rival report, a rival sequence of reports, also

9 apparently signed by you, came to be. I think that’s

10 what’s being asked.

11 MR STROILOV: Indeed.

12 MR JUSTICE HILDYARD: Can you help us on that?

13 A. Unfortunately I cannot recall at what point in time, if

14 that, indeed, was the information that I received, that

15 this phrase should not be part of the report, that it

16 was not true. I do not recall at what point in time

17 I found out about it and how many reports were already

18 prepared by myself at that point.

19 So, depending on that, it depends how many reports

20 I had to correct, should such correction be needed, and

21 I would like to say that such reports were continuing,

22 as far as I recall, in 2010 as well, and then I believe

23 I wasn’t the executive for the reports, another employee

24 was dealing with that.

25 But all I can say in this regard is that I, of

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123 :1 course, do not recall the date of 17 June, but I had no
2 purpose of maliciously forging anything or amending

3 something. I certainly didn’t have such purpose. If

4 I would do anything within my work duties with regard to

5 that particular borrower, or within my work duties

6 overall, that was only to do with the Bank documents

7 showing the true facts.

8 MR JUSTICE HILDYARD: I’m sure you are — it is very

9 understandable, if I may say so, you wouldn’t be able to

10 remember when first things were corrected but, as

11 I said, the curiosity is that you find these two

12 sequences and they go on from the moment there is

13 change, repeating themselves in their different form

14 down the line from that time, and what is odd is that

15 your signature is on both versions.

16 Now, I think you are telling us you only ever signed

17 one version of each week’s report; is that right?

18 A. As far as I understand. For example, on 17 June,

19 I could have signed one of the versions of the reports.

20 I also signed it on the 24th and 31st, et cetera.

21 MR JUSTICE HILDYARD: Yes.

22 A. However, when it became known that some amendments, some

23 changes had taken place, there is a likelihood of me

24 thinking it would be proper and correct to come back and

25 correct the previous report with the incorrect

124 :1 information as of each previous date, but now I am
2 simply stating my assumptions, my guesses as to

3 the situation, because I cannot recall. I do not recall

4 all the circumstances.

5 MR JUSTICE HILDYARD: I understand that, and you may not be

6 able to provide an explanation, but I don’t think that

7 can be the explanation, because you kept on signing

8 a sequence with the inclusion and a sequence without the

9 inclusion if you signed both documents, and I’m just

10 wondering whether you did or not.

11 A. I definitely do not recall — I did not sign two

12 documents in the same day. I absolutely recall that it

13 only could have been if such error would have crept in,

14 I could have corrected the previous reports and,

15 consequently, re-sent them to the responsible person,

16 the person responsible for monitoring the problem debts.

17 MR JUSTICE HILDYARD: Then in the original sequence you

18 would not see the error, if it was that, being repeated

19 after that time. That’s what’s so odd. Still, this may

20 remain a mystery. It is some time ago.

21 A. To be honest, I also cannot proffer any explanation to

22 the fact, because I do not recall how it happened, how

23 it all happened.

24 MR JUSTICE HILDYARD: Mr Stroilov, are you putting to

25 the witness that there is a sequence which forever

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Arkhangelsky [Master]

125 :1 includes these entries and a sequence which, at
2 a certain time, does not, and that both are signed; is

3 that what you are putting?

4 MR STROILOV: That is what I am putting.

5 MR JUSTICE HILDYARD: Yes, that is what you are putting, and

6 this witness cannot remember signing or being asked to

7 sign, rival sequences.

8 MR STROILOV: If I can take it a little further, I do

9 appreciate if you think —

10 MR JUSTICE HILDYARD: Yes, all I would ask you to do is let

11 us try and get to the explanation as best as this

12 witness can assist us without accusations, at this

13 point, of fabrication or forgeries or anything, because

14 I think that that will simply muddy the waters. We need

15 to establish what the witness’s explanation is, and you

16 can then make submissions and put to this witness what

17 your ultimate conclusion is, but we must go steadily

18 rather than leap to the conclusion without quite knowing

19 how we get there; do you see what I mean?

20 MR STROILOV: Right, well. Yes, I am grateful.

21 A. My Lord, I am very sorry, is it possible to have a break

22 for literally five minutes?

23 MR JUSTICE HILDYARD: Yes, of course. It is a good time

24 anyway. We will have a ten-minute break.

25 (3.19 pm)

126 :1 (A short break)
2 (3.29 pm)

3 MR STROILOV: May it please your Lordship.

4 A. My Lord, may I ask Mr Stroilov to clarify a specific

5 moment? Until what date there is a fact of having

6 doubled-up reports, I would like to use the term

7 «doubled-up».

8 Q. Yes, let me check my notes. I think I have looked into

9 this at some point. I’m not sure you have everything in

10 the bundle, actually, but perhaps if you are able to

11 stay overnight, I can prepare this by tomorrow.

12 Let me check, in relation to the — and perhaps my

13 learned friends will want to take a note of, as much as

14 they can assist — I think the fullest reports we have

15 on the first Vyborg loan go to 1 October 2009, and

16 that’s what we were looking at. Then I — then I am not

17 sure. I have marked the claimant’s document B114 as

18 containing the fullest version in relation to the second

19 Vyborg Shipping loan.

20 Then —

21 A. Sir, would it be possible to have a look at the

22 document?

23 Q. Let me try and find it on Magnum. It is my fault.

24 I should have prepared that, but everything has been

25 done —

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127 :1 MR LORD: It is {D130/2111/0.1}.
2 MR STROILOV: I’m very grateful. I suppose we need to go to

3 the — well, yes. And the Russian version will be at —

4 again, I think they all follow the same system: the

5 English version would be numbered 0.1, the first page,

6 and the Russian version is numbered 1, and respectively

7 0.2. So if you go to page 3, just so that we see that,

8 it goes to September. Then {D130/2111/0.3} will be the

9 English version, and that goes to 4 September. That

10 corresponds to tab 160 in file F, I believe. Let me

11 check, but that’s what I have recorded.

12 A. My Lord, if I may, I would endeavour to clarify the

13 discrepancies?

14 MR JUSTICE HILDYARD: Yes, please. Thank you.

15 A. I would like to clarify one more time the system of

16 preparing these reports, who did we prepare them for.

17 As far as I recall, as far as I recollect the events of

18 2009, thereabouts the directorate for client monitoring

19 was formed and it was headed by Mrs Mironova, and we

20 were preparing these reports for them, as far as I can

21 recall.

22 Accordingly, once a week, or once every day, I would

23 prepare the reports, I would sign them with my manager,

24 and I would send the reports to the directorate.

25 Obviously, over some period of time — I do not

128 :1 recall when, exactly — some information might have been
2 received that an error has been made in these reports,

3 and by that point in time, each report was sent on

4 a weekly basis, they were saved up, accumulated, there

5 were already several reports. When the error has been

6 made, it looks like I have corrected the entry,

7 corrected the error, and re-signed these reports,

8 accordingly having sent them one more time to

9 the directorate for client monitoring, and it looks like

10 this is the way the doubling-up happens, and I came to

11 that thought because, indeed, I must have re-signed

12 them, and after September, this is why I asked the

13 question of Mr Stroilov about the date.

14 For example, the report dated by 3 July is signed by

15 Mrs Borisova in the first version where there is

16 an entry by 17 June, and with the reports, as we can see

17 in these folders — sorry, I already closed the

18 folder — dated the same date but without such entry for

19 17 June is already signed by Mr Platonov. If I recall

20 correctly, as I am saying now, around autumn 2009

21 Mrs Borisova left the Bank and, accordingly, I was not

22 able to re-sign the document with her, because she

23 wasn’t with the Bank anymore. The only person that

24 could have re-signed it was the branch director, and

25 accordingly, all these corrected reports were sent by us

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129 :1 in exactly the same way to the client monitoring
2 directorate.

3 I cannot explain it. I do not have information as

4 to why the additional reports were not destroyed, that

5 would have been logical if they contained an error, but

6 unfortunately I cannot comment or clarify the situation

7 any more, apart from the fact, indeed, I might have

8 corrected them and my director’s signature has brought

9 me to this conclusion.

10 MR STROILOV: All right, so what you are saying,

11 Mrs Blinova, I’m just trying to understand, that at some

12 point towards the end of 2009, you were told that this

13 entry was inserted by mistake and asked to produce

14 another version without that entry, and provide it to

15 the client monitoring directorate. Is that your

16 recollection?

17 A. Let me repeat myself, sir. Unfortunately I do not have

18 a clear recollection of that, but this may well have

19 been the case, is what I’m trying to say. If changes

20 were being made then I had to change all the reports if

21 someone had brought to my attention that a mistake had

22 been made, something had never actually happened. So it

23 would be wrong to, it would be inappropriate to leave

24 that intact in the previous versions, so therefore

25 I asked my boss to re-sign this and then I sent this on

130 :1 to the monitoring directorate.
2 Q. Right, so the reports would be sent to client monitoring

3 directorate as they were produced, initially?

4 A. Well, they may have gone to the directorate. Mind you,

5 when a borrower became a problem borrower, we had to

6 centralise his file. The file — a number of bundles

7 like this had to go to the client monitoring department

8 so that they could start working them.

9 Q. The whole loan file would be passed to client monitoring

10 directorate?

11 A. Correct. Exactly.

12 Q. So that would happen at some point in March/April —

13 well, just after the so-called default?

14 A. No. Speaking from memory, and I refreshed my memory by

15 reading the various documents when I was writing my

16 witness statement, the directorate was set up some time

17 in April or May. However, the centralisation does not

18 take place before some time later on because we were

19 sitting on those files for a few months.

20 I remember at the end of summer or in the early

21 autumn, the internal audit department ran a number of

22 checks on us and so we still had those in files in

23 the branch. But as of the autumn, they started asking

24 us to send those documents onto them and that’s what we

25 began doing.

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131 :1 Q. At some point you believe that a message came back from
2 the client monitoring directorate saying: you’ve made

3 a mistake, you must correct that mistake in these 170

4 documents and send them back to us?

5 A. Well, if my memory serves me right, then I believe that

6 this was actually the case. We did not cite any

7 specific numbers, and I don’t think I would have been

8 able to adjust all those documents in one day.

9 But had this been brought to my attention, that

10 I had made a mistake, just to repeat myself once again,

11 I would have made those corrections in all those

12 documents across the board, and that was the appropriate

13 thing to do, rather than leave some incorrect reports in

14 place.

15 Q. It was your understanding —

16 MR JUSTICE HILDYARD: Mr Stroilov, I’m so sorry, it is

17 because, I suspect, that you are not wearing your

18 headphones, you are coming accustomed to asking

19 a question before the translation of the witness’s

20 evidence has been completed, and you are going to have

21 a whole series of overspeaking, which will undermine the

22 examination, but also make it very difficult for all of

23 us to follow.

24 So if you could try and leave a gap so as to ensure

25 that the translation of the witness’s answer is complete

132 :1 before you ask another question.
2 MR STROILOV: I’m terribly sorry.

3 MR JUSTICE HILDYARD: You may be assisted by that in having

4 your headphones on, I don’t wish to inconvenience you,

5 I will leave it to you what you do, but it is becoming

6 a problem.

7 MR STROILOV: I’m very sorry, my Lord.

8 MR JUSTICE HILDYARD: It is not your fault. I can

9 understand how it has arisen, but just we need to

10 correct it.

11 MR STROILOV: The interpreters told me, but I forgot again,

12 I’m sorry.

13 It was your understanding, was it not, Mrs Blinova,

14 that following this correction the old versions of

15 reports should have been destroyed?

16 A. Well, I did not focus my attention on this particular

17 point, but most likely they would have been destroyed.

18 Having said that, there is no way I can know where

19 those reports went afterwards. Well, maybe they were

20 e-mailed to someone else, therefore I do not know

21 whether they were destroyed or not, or whether it made

22 any sense to destroy those.

23 For all I know, they may have gone to the Central

24 Bank or some references had been made to those

25 documents, and if that information was recorded

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133 :1 somewhere, so for all I know a corrected version may
2 have been attached to the old incorrect version, just to

3 make sure that whoever reads the document understands

4 that there is the old document with the mistake in it,

5 and then there was the follow-on document with the

6 mistake corrected.

7 To be honest, I did not pay much attention to this.

8 It was, you know, par for the course. It was one of

9 those things that we kept doing on a daily basis.

10 Q. Yes, Mrs Blinova, I agree with that. Fabricating

11 documents to conceal various suspicious transactions is

12 something that happens in the Bank as a matter of

13 course.

14 A. Is this a question?

15 Q. Do you accept that?

16 A. Could you reformulate the question? I beg to differ.

17 I do not agree with this.

18 Q. Well, I suggest to you —

19 A. My apologies. Now if there was a mistake in a document

20 and if I then corrected that mistake, then this is not

21 a fabrication, this is not an offence. I made

22 a mistake, I corrected the mistake, whichever way was

23 available to me, and so I drew my lessons. Lessons

24 learned, as we call it.

25 Q. Yes, Mrs Blinova, well, the trouble is — I’m not

134 :1 suggesting that you were personally dishonest, and it
2 was your personal fabrication, but whoever told you that

3 you made a mistake told you a lie. There was a decision

4 of the management board on 17 June, and it is as stated

5 in the version of reports which you have corrected.

6 A. Now, with respect to this particular entry, I have no

7 comment to offer. I really don’t know what this all is

8 about. I simply do not recall all those events.

9 Q. Mrs Blinova, I think I need to make it clear, and that’s

10 what my learned friend quite rightly said: I’m not

11 suggesting that in any way you had any personal interest

12 in this fabrication; what I am suggesting is that you

13 did what you were told by your superiors.

14 A. Obviously, as I have already mentioned, I was going by

15 the information that I received from my direct

16 supervisor, from other departments within the Bank. So

17 that was part of my work. I received information, there

18 was some input, I collected that information, I put it

19 into this report, then there were other documents that

20 I also drafted and then I passed it on to whoever needed

21 those documents.

22 In other words, what I added here was only the loans

23 in arrears, the debt in arrears, the debt outstanding.

24 This is what I was in charge of: security, interests and

25 so on and so forth.

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Arkhangelsky [Master]

135 :1 But all the procedures that had to be complied with
2 in terms of problem debt was something that we just

3 accumulated and then sent on.

4 Q. I’m not for the moment suggesting that you personally

5 were part of the fraud, but I am saying that some of

6 your superiors from whom this instruction came were

7 dishonest.

8 A. I have nothing to say about that. I know nothing about

9 it.

10 MR JUSTICE HILDYARD: I’m so sorry, Mr Stroilov. Can you

11 remember whether any explanation was given to you by

12 whoever asked you to make this alteration, why the

13 alteration was required to be made?

14 A. With respect to the 17 June entry — is this what you

15 are referring to, my Lord?

16 MR JUSTICE HILDYARD: Yes, or any other of the emendations.

17 A. I do not recall this particular entry but I believe that

18 had I known a little bit more about this, I would have

19 remembered this, but most likely someone called me and

20 said that the 17 June information is wrong, please

21 delete it. So I think this is what happened. I presume

22 that this is what happened.

23 I mean, no one told me about the details

24 underpinning what was taking place here. Most likely

25 people just got on the phone to me and said that this

136 :1 needs to be deleted.
2 MR JUSTICE HILDYARD: Thank you.

3 MR STROILOV: Yes, thank you. I will just — I don’t think

4 I want to spend a lot longer on this. I have simply one

5 more point I want to make and see if Mrs Blinova wants

6 anything to say.

7 I’m not alleging you did it and I am not alleging it

8 was in any way your own initiative, but I’m saying that

9 for the Bank and for the dishonest people with whom this

10 order originated, 170 fabrications to conceal just one

11 transaction suggests a rather worrying erasure.

12 A. I have nothing to offer by way of comment. Once again,

13 I simply do not know what it’s all about.

14 Q. Yes. If, perhaps, I think because I regret to say

15 I anticipate that I will have to spend some time

16 tomorrow morning with Mrs Blinova.

17 If this may assist, I think I should complete

18 answering Mrs Blinova’s question and identify what are

19 the fullest versions of bad debt reports in the loan

20 files and in file F, just so that my learned friend can

21 take a note and perhaps, overnight, could make some of

22 their own investigations.

23 So just for the record, document C159 in

24 the claimants’ disclosure is purportedly identical with

25 F/162.

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Arkhangelsky [Master]

137 :1 I’m not sure about file D, I am afraid, but that’s
2 as much as I can say to assist.

3 Now, if we can, then —

4 MR JUSTICE HILDYARD: Can I just ask, it must have been

5 a very tedious, time-consuming thing to have to go over

6 documents and re-sign things you had already signed once

7 when you got this command to change them. Do you

8 remember the process of re-signing, or is it something

9 you think you must have done? Do you remember doing it

10 or are you just rationalising that that’s what must have

11 happened?

12 A. May I clarify, my Lord, that if what Mr Stroilov is

13 saying is that he has information that those documents

14 existed until some time in autumn, then it would appear,

15 if we look at 17 June — 2, 3, 5, 6, 7, 8, 9, 10, 11,

16 12 — all together 12 reports for one of the contracts,

17 well, it doesn’t work out at more than 100. Again,

18 I may be wrong in my calculations. To answer your

19 question, sir, I do not recall physically having those

20 re-signed.

21 This may not have all happened in one day. This may

22 have happened over a series of days between September,

23 or maybe November, I became first acting director of

24 the department then. I spent some time until my first

25 maternity leave as director of the department, and so

138 :1 I had some people reporting to me. I may have asked
2 some people to prepare those documents, have them

3 printed off and have them re-signed. This would not

4 have taken much time.

5 A credit officer sometimes has to sign lots of

6 different documents, therefore this did not leave any

7 imprint in my memory. I mean, the gist was clear, and

8 the reason why they were being changed was clear. Just

9 one entry was being deleted.

10 MR JUSTICE HILDYARD: Yes.

11 MR STROILOV: Well I think I have said all there is to say

12 on —

13 A. My apologies, if I may add, some of the documents were

14 re-signed by my boss, the director of Investrbank, and

15 that was Mr Platonov, and we just drafted those.

16 Q. Yes, quite. No, I think I am sorry, Mrs Blinova, if

17 I was, shall I say, too brutal with you. It is not

18 an allegation against you personally; it is

19 an allegation against whoever made that order. There

20 is — no allegation of personal dishonesty is made

21 against you.

22 Now, if we could have a look at {D38/641/1}; and

23 then if we could have on one screen page 1, and on the

24 other page 2, {D38/641/2}.

25 So, Mrs Blinova, I think the English version says

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139 :1 the signature is illegible, but if you look at the
2 Russian version, it appears that the signature is yours,

3 isn’t it?

4 A. Yes, it looks like it is my signature.

5 Q. Yes. Now, as I understand it, correct me if I am wrong,

6 the purpose of this document is to comply with certain

7 legal requirements; is that your understanding?

8 A. Yes. If and when an individual gives a guarantee, then

9 the spouse has to signify their agreement to the other

10 person giving that guarantee, yes.

11 Q. And is it your understanding that without this

12 guarantee, it wouldn’t be effective?

13 A. I am not qualified to tell you what the legal

14 requirements are, but I know that there was

15 a requirement in the Bank for that consent to be

16 signified, yes.

17 Q. Of course not, but what was your understanding of

18 the purpose of this requirement? Did you understand

19 that it is there to make sure the guarantee is enforced,

20 if necessary? Or can be enforced, if necessary?

21 A. I really gave this no thought at all. I was acting as

22 per the regulations of the Bank, which said that if

23 an individual gives a guarantee, then his or her spouse

24 has to signify their consent. That was it. I had

25 really no further thoughts about this, apart from what

140 :1 the guidelines, with respect to Bank loans, provided
2 for.

3 Q. Now, would you agree, well, it is common sense, the

4 purpose of this declaration is to protect the rights of

5 the spouse — well, supposing Mr Arkhangelsky pledges

6 all his personal property, but that’s family property,

7 and so if he does that, obviously the spouse must

8 consent. I think it is just common sense, that’s how it

9 must be; would you agree?

10 A. Well, you know I am not a qualified lawyer, and logic

11 has very little to do with this: I cannot assess the

12 risks or otherwise of a guarantee being extended by one

13 spouse and the lack of consent on the part of the other

14 spouse.

15 Q. Yes. So if you could read the text in the stamp. So

16 you certified by your signature the declaration was made

17 in your presence, passport details indicated in

18 the declaration checked against the details in

19 the declarant’s passport. There is a date, and there is

20 your signature. So what did you understand you were

21 signing to?

22 A. It was a declaration made by the spouse, by the wife, to

23 the effect that she agrees to her husband,

24 Vitaly Arkhangelsky, entering into a guarantee by way of

25 security for one of the loan agreements. That’s how

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Arkhangelsky [Master]

141 :1 I understand it.
2 Q. Yes, sorry, I must have formulated the question badly.

3 What is your signature meant to certify?

4 A. It certified the fact that the declaration was signed in

5 my presence and this is what it actually says here, and

6 that was the purpose of my signature. That was what it

7 was supposed to certify.

8 Q. Quite, but was it actually signed in your presence?

9 A. As I have already mentioned in my witness statement, if

10 need be I can refer you to a clause in my witness

11 statement, when I started working with

12 Mr Vitaly Arkhangelsky’s group I knew that he was one of

13 the top VIP borrowers for the Bank. I also knew that at

14 that time his family had several small children and my

15 bosses told me that Mrs Arkhangelskaya may not always be

16 able to come to the Bank physically on her own to sign

17 those declarations, for obvious reasons, and at that

18 time I had absolutely no reason not to trust this

19 particular client. So one of my bosses, one of my

20 supervisors, told me that if Mrs Arkhangelskaya was not

21 able to come herself, then there was a way, there was

22 a procedure whereby we could send this, we could e-mail

23 this and at that time my contact person was

24 Elena Krygina from the finance department and the

25 financial director at that time was Igor Suzanov(?),

142 :1 then Alexey Berezin, and it was then their
2 responsibility to have those declarations signed and

3 forwarded on to the Bank.

4 So I compared the signature with the sample

5 signatures that we had available to us at the Bank at

6 that time, and I then affixed my signature to certify

7 that I had actually compared the details, the contact

8 details, and a signature as — I did say that it was

9 signed in my presence. I simply do not recall the exact

10 dates, but there was an instance I remember, and this

11 may have been this particular loan or maybe some other

12 loan, where Julia Arkhangelskaya actually did come to

13 the Bank with a view to signing a declaration that may

14 not have been this particular consent form, it may have

15 been a different consent form for a different loan

16 agreement.

17 Q. Or it may have been something different than the consent

18 form. She may have just wanted to, I don’t know,

19 transfer money from one bank account to another; isn’t

20 that a possibility?

21 A. You see, the loan department was not in charge of bank

22 transfers. If she came to me then she would only have

23 come to me for the purposes of signing that kind of

24 form.

25 Q. All right. So, essentially, your evidence is you didn’t

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

143 :1 think about why these forms are necessary. You were
2 told by your superiors not to worry about it and to put

3 your signature to this statement without thinking about

4 it, because that was what …?

5 A. Not at all. Not quite the case.

6 You asked me to evaluate the legal meaning of this

7 declaration, and this is not something I can do.

8 However, I knew, based on the Bank’s internal

9 requirements, that this declaration has to be made

10 whether there are any risks or not from the legal

11 standpoint, or to be evaluated by a lawyer that was also

12 looking through and monitoring the contracts to be in

13 conformity, and with regard to my signature, I wanted to

14 say that every time via the finance department I was

15 offering to arrive for Mrs Arkhangelskaya’s arrival to

16 the Bank and signed it, but sometimes for objective

17 reasons she couldn’t do so.

18 Then these consents were usually brought back on the

19 same day, sometimes on the next day to the Bank and they

20 were already signed. I would compare the signatures and

21 I would countersign at the bottom of the document, one

22 of such documents.

23 Q. But Ms Blinova, the point is you have put your signature

24 to a statement which you admit you knew to be false.

25 A. Why?

144 :1 Q. Because you said the declaration was made in your
2 presence, passport details were checked, and you signed

3 to it, and that wasn’t true: it wasn’t in your presence.

4 A. I shall reiterate that I do not remember exactly whether

5 Mrs Arkhangelskaya arrived to sign this particular

6 declaration. I cannot recall all the dates, whether she

7 arrived specifically or not. That was a routine

8 practice to require such consent from all spouses of

9 guarantors, and apart from Mr Arkhangelsky I have 10 or

10 15 clients at that point in time, many of them were

11 providing personal guarantees. I do not recall every

12 spouse. I cannot recall them. I simply report the

13 recommendation and the instruction of my management not

14 to insist too much on Mrs Arkhangelskaya coming

15 physically to the Bank, because she had young children

16 and that was difficult to do on the same day.

17 Sometimes, but not always, we would meet the client

18 halfways and accommodate the clients, and I had no

19 reasons to think that by affixing my signature I would

20 breach something, and these declarations would be

21 returned to us from the clients by a courier from the

22 Oslo Marine Group, and I had no reason to think that

23 I was breaching something in this particular case.

24 Q. Ms Blinova, isn’t it clear to you, just looking at this

25 declaration, that the purpose of this document, and

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

145 :1 especially of your signature, is to be sure that
2 Mr Arkhangelsky does not sign — doesn’t enter

3 guarantees or personal loans without agreeing that with

4 his wife? Isn’t that evident to you?

5 A. I am sorry, could you please repeat the question?

6 Q. I put it to you —

7 MR JUSTICE HILDYARD: Mr Stroilov, can I just ask this. My

8 understanding is that in her witness statement this

9 witness has accepted that there were occasions when she

10 did not have in her presence Mrs Arkhangelskaya, nor did

11 she check her passport, but she trusted Mr Arkhangelsky

12 and Mrs Arkhangelskaya and she proceeded on that basis.

13 You are putting to her that on those occasions it was

14 incorrect for her to sign that she had, and I think that

15 she probably accepts that, although I think she would

16 also say that she was acting with the encouragement of

17 her superiors.

18 Now, there we are. She has sometimes said something

19 incorrect. She may not be the first person who has done

20 that sort of thing. How much more do you want to get

21 from this?

22 MR STROILOV: Well, my Lord, I need to think about it,

23 whether I want to say this in the presence of

24 Mrs Blinova.

25 MR JUSTICE HILDYARD: All right, don’t say any more, but the

146 :1 thing is, I don’t want to spoil any cross-examination of
2 this witness or of any other witness, but it is,

3 I think, although regrettable, not a wholly unknown

4 circumstance that people do, in order to accommodate

5 others, treat as in their presence people who are not,

6 and sign accordingly.

7 Now, that may be a bigger thing in this case for

8 reasons I don’t understand, but I am just wondering how

9 much more you can ask of this witness in this regard.

10 I know we have a lot to do and therefore I don’t want

11 you to waste time on things which may, ultimately, not

12 be absolutely crucial.

13 MR STROILOV: I’m grateful, my Lord. I hope to finish this

14 line in a few minutes.

15 MR JUSTICE HILDYARD: Yes.

16 MR STROILOV: Mrs Blinova, what I’m suggesting to you — you

17 say in your statement that this was a general practice,

18 to do these kind of things for a certain category of

19 clients, don’t you say that?

20 Don’t bother looking at the statement. Just tell me

21 whether it was or it wasn’t. I think you say this

22 wasn’t —

23 A. May I just get familiar with the document, if I may?

24 (Pause).

25 In paragraph 29 of my witness statement I say that

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Bank St Petersburg v Vitaly Day 4

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147 :1 within the internal rules the Bank did require the
2 spousal consent if a person was proffering a personal

3 guarantee. Such consent was supposed to be drawn up

4 strictly in the presence of a member of staff of

5 the Bank, however, in the case of Mrs Arkhangelskaya it

6 might have not been the case. I remember that she was

7 one of the most important — sorry, not her, but her

8 spouse and his companies at that point in time were some

9 of the priority borrowers with the Bank, and the Bank,

10 to an extent, was making concessions based on objective

11 reasons, and was the easing of the existing practice.

12 Of course, we did not provide such concessions for lay

13 clients.

14 Q. I beg your pardon, Mrs Blinova. I think I put the

15 question incorrectly.

16 A. I’m very sorry. Maybe I will add something which might

17 be important.

18 I, personally, did not have any doubts with regard

19 to signing by Mrs Arkhangelskaya or that she would be in

20 any way against signing. I remember when she visited my

21 colleague Viktoria Yashkina to sign a similar

22 declaration, I recall that very well because Viktoria

23 has warned me, in good time — and let’s put it this

24 way, I was quite curious to see the spouse of our most

25 important client, one of them — and I remember that she

148 :1 arrived and I didn’t get any association of feelings
2 that she would be against signing these declarations and

3 consents.

4 Q. Yes, I see. What I am putting to you — I have made

5 a mistake, I don’t think you actually say it was the

6 general practice. What I’m putting to you was that it

7 was actually widespread practice in Investrbank to

8 certify the signature of a spouse without their actually

9 being there; is that the case; do you accept that?

10 A. Sir, do you mean — which clients do you mean? Do you

11 mean Oslo Marine Group or across the board, all the

12 clients of the branch?

13 Q. Some of the clients.

14 A. I should reiterate that I wouldn’t be able to speak for

15 other employees of the credit department, but

16 I personally — well, Mr Arkhangelsky’s group, apart

17 from them I had another 10 or 15 clients. I do not

18 recall whether they were VIP clients or standard clients

19 but, as a rule, the spouses would always visit the Bank

20 to sign the consent. So usually there were no doubts.

21 Possibly there were some exceptions to that, some

22 extreme circumstances, but overall — overall they

23 usually would come to visit me personally and sign such

24 consents. I remembered very well because

25 Mrs Arkhangelskaya had a weighty reason: she had young

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Arkhangelsky [Master]

149 :1 children.
2 MR STROILOV: Yes. My Lord, I am rather concerned that —

3 in a way, it is not a criticism of Mrs Blinova, but

4 basically that it is taking a lot longer, and I think

5 the answers are unusually long for cross-examination,

6 and I don’t — and some of them are helpful, but I don’t

7 want to interrupt on the one hand, and it is not very

8 practical for the translation reasons, but, on the other

9 hand, well, we haven’t got unlimited time and, of

10 course, we all have Mrs Blinova’s statement and

11 cross-examination normally progresses much quicker. I’m

12 not quite sure how I deal with it.

13 MR JUSTICE HILDYARD: Deal with what? I mean, take this

14 last point. I don’t know whether there is any Russian

15 evidence that unless the spousal consent has been signed

16 in the presence of a witness for the Bank it’s

17 unenforceable or void, but there hasn’t seemed to be so.

18 It may be that this was not a correct thing for

19 Mrs Blinova to have done, and it may be that she rather

20 wishes she hadn’t followed the command of her superiors,

21 but it has been done. Are you suggesting that it’s

22 unenforceable because that was the case? No. Are you

23 suggesting that it’s regrettable? She accepts it is.

24 I mean, why have we spent so long on this, really,

25 Mr Stroilov? It is quite a detail, isn’t it?

150 :1 MR STROILOV: That’s my point, my Lord, that’s my worry
2 which I am sharing with you.

3 MR JUSTICE HILDYARD: Yes.

4 MR STROILOV: And normally cross-examination involves me

5 asking the question and the witness answering more or

6 less yes or no.

7 MR JUSTICE HILDYARD: Witnesses are always surprising. They

8 always say things you don’t expect them to do and go

9 longer at some points and shorter on others, that is

10 absolutely true, it is a very difficult job,

11 cross-examining. I remember being driven to distraction

12 by my own inability to control the witness, if it is any

13 comfort to you.

14 What you are really saying is that you need more

15 time?

16 MR STROILOV: Yes, I need more time, but also I wonder if,

17 perhaps, you could give guidance, because I — because

18 my guidance doesn’t carry any weight.

19 MR JUSTICE HILDYARD: Guidance to the witness?

20 MR STROILOV: That essentially Mrs Blinova doesn’t need to

21 repeat what she has said in the witness statement. She

22 really needs to answer the question and sometimes, with

23 no disrespect, I will just ask for a yes or no answer

24 and then we will get somewhere, because I am not really

25 getting to my point because Mrs Blinova has a lot of

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151 :1 points to make.
2 MR JUSTICE HILDYARD: Yes, Mrs Blinova, together we will try

3 and focus on — perhaps if you can give a yes or no

4 answer, give it; if you think it important to give

5 context, say you do, and try and keep it as short as

6 possible. If Mr Stroilov wants you to give context, he

7 will ask you, but the bottom line is try and be more

8 concise, is what you are being invited to do.

9 A. Yes, my Lord, I shall endeavour to do my best.

10 MR JUSTICE HILDYARD: I’m not saying whether you are or

11 haven’t been, I’m just saying that this is going to be,

12 between us, our joint endeavour.

13 MR LORD: It is fair in this context, my Lord, to say that

14 some of these most recent answers are in the context of

15 a question that said: you said in your statement that

16 your general practice was … and that wasn’t her

17 evidence and then she had to correct it. So it is

18 entirely —

19 MR JUSTICE HILDYARD: I’m not going to say the extent to

20 which it is the witness’s fault or perhaps excessive

21 questioning on a particular point. I don’t mean to be

22 critical of either of you. It is a difficult job, both

23 sides of the equation, a difficult job.

24 Here we are, 4.15, how much longer do you feel you

25 need with Mrs Blinova, who was expecting to be free

152 :1 today?
2 MR STROILOV: Yes, I indicated to my learned friends that

3 I hope to be finished by lunchtime tomorrow and I still

4 hope to finish by lunchtime tomorrow. I am not sure

5 what the plan is in relation to Mrs Patrakova, whom we

6 have to finish tomorrow, well, within an hour, as

7 I indicated, but I don’t think there is — if it can be

8 the afternoon tomorrow, then I think that I can finish

9 with Mrs Blinova, cross-examine Mrs Patrakova, it really

10 won’t be nearly as excessive as with witnesses who dealt

11 with OMG in one role or another.

12 MR JUSTICE HILDYARD: Well, you have promised — well,

13 «promise» may be too strong. Ms Patrakova is a very

14 short witness. She is coming here and she expects to be

15 here for an hour. The only subject matter is whether

16 she did or didn’t see Mr Arkhangelsky signing a couple

17 of documents. We don’t need more than an hour with her,

18 do we?

19 MR STROILOV: Quite. Quite, my Lord.

20 MR JUSTICE HILDYARD: No.

21 Ms Blinova, you did say that you would be up to

22 a full day. You have been slightly less than a day, so

23 I suppose it is to be expected that you would go on

24 tomorrow a little bit.

25 I do apologise, Mrs Blinova. I am sorry if it

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153 :1 causes you domestic problems, it is obviously
2 disappointing, I know it is. But —

3 MR LORD: My Lord, can we just raise timetabling? It may be

4 this witness should be allowed —

5 MR JUSTICE HILDYARD: Yes, I’m sorry, Mrs Blinova, we are

6 going to chat among ourselves about some timetabling

7 issues. For the moment all I can do is apologise to you

8 for the fact you will be detained in this country

9 overnight. I am very much hoping that it won’t be too

10 long before you can get back to your family and travel

11 back, I do apologise for it.

12 Thank you. Now, what I suggest is you go and think

13 about other things. Please do not discuss this case

14 overnight, whilst you are being cross-examined, have

15 a better time than that, please, and if you wish to

16 leave the witness box now while we are discussing issues

17 of timetabling, so far as I am concerned that is fine.

18 Is that all right with you two, in case this takes time?

19 MR STROILOV: Yes, thank you, my Lord.

20 MR JUSTICE HILDYARD: So your job is over for today.

21 A. Thank you, my Lord, many thanks.

22 MR JUSTICE HILDYARD: Yes.

23 (The witness withdrew)
24 Housekeeping
25 MR LORD: Does your Lordship have the revised trial
154 :1 timetable?
2 MR JUSTICE HILDYARD: I think I have it, yes. Mr Guz was

3 next, we were meant to be having him this afternoon.

4 MR LORD: Yes, endeavouring to finish him tomorrow. There

5 was flexible built into this because Mr Belykh was meant

6 to be half a day and Ms Blinova up to one and a half

7 days, so I think it was a reasonable expectation that

8 they would have been finished on the first two days in

9 total, with a one-hour witness the next day and then

10 Mr Guz would have a chance of being finished then.

11 My Lord, Mr Guz is the chairman of the management

12 board —

13 MR JUSTICE HILDYARD: Yes.

14 MR LORD: — and he has very important meetings back in

15 Russia on Thursday. So he is now going to have to,

16 I think, probably, he is going to have to fly back. He

17 was going to fly back as late as he could tomorrow night

18 in the hope that we had got through him. Now, that

19 obviously doesn’t look as if it is going to prove

20 possible.

21 But we are concerned, my Lord, that whilst it is

22 right that there should be flexibility, and we

23 understand why there would need to be flexibility, at

24 the same time, this can’t be a completely elastic

25 timetable with Mr Stroilov taking however long he likes

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155 :1 with every witness he likes, because we are going to
2 move not just to his aspirational timetable as

3 previously advanced, but actually to a good 50 per cent

4 more than that. So far he is 50 per cent over after two

5 days, so that looks to be, on his estimate, he is up to

6 some 45 days.

7 MR JUSTICE HILDYARD: Mr Lord, given the peculiar

8 circumstances of this case, and without binding myself

9 for the future, I do not propose to guillotine

10 Mr Stroilov at the present moment.

11 MR LORD: Yes.

12 MR JUSTICE HILDYARD: I don’t think that that would be fair

13 to do so, having regard to all the circumstances under

14 which he is labouring. So, with apologies to Mr Guz,

15 who has many other important things to do, I think

16 Mr Stroilov has already indicated to me that he needs

17 time to draw breath before cross-examining Mr Guz in any

18 event and was going to, in any event, ask for that day

19 not to be tomorrow.

20 Now, when is an appropriate time, having regard to

21 Mr Guz’s timetable and the rest of the witnesses, to

22 slot him in?

23 MR LORD: Well I am going to have to take instructions

24 witnesses, my Lord, and I think I need to work with your

25 Lordship through this timetable to see which witnesses

156 :1 we might complete this week, and I must raise the
2 prospect that we may have to use overspill days in order

3 to be able to finish off a witness, because otherwise we

4 are going to get into a position where we can’t call

5 a witness because of the risk of it taking an extra hour

6 or two. Your Lordship did say originally that

7 your Lordship would be flexible about that, because if

8 we are going to have to have guaranteed slots to finish

9 witnesses before weekends, it is going to start to

10 diminish the weeks.

11 If we take Mr Guz out of this timetable,

12 Mrs Patrakova — her evidence must be heard tomorrow.

13 With respect, Ms Blinova really should be finished

14 tomorrow, she should be finished by lunchtime tomorrow,

15 if we have to start early, so be it, she should be

16 finished by lunchtime and Ms Patrakova, in my

17 submission, should be heard immediately thereafter. So

18 there is no risk that Ms Patrakova, who starts at 2.00,

19 will not finish tomorrow.

20 Then there is a question, my Lord, of what other

21 witnesses we are allowed to call this week, bearing in

22 mind how many days are left.

23 MR JUSTICE HILDYARD: What about Mrs Yashkina?

24 MR LORD: We would like to call her. These are witnesses,

25 my Lord, who have all flown over from Russia to give

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157 :1 evidence this week.
2 MR JUSTICE HILDYARD: I know, Mr Lord. Can I just say this:

3 of course I will be flexible within reason by allowing

4 overspill into the overspill days in order to clear

5 witnesses.

6 MR LORD: Yes.

7 MR JUSTICE HILDYARD: But I explained to you that, actually,

8 it is of concern to me personally to have too long a day

9 or not have a rest at the end of the week, and the

10 danger is that if you push too hard, you may, in the

11 end, find that I simply can’t do it. So be aware of

12 that fact, please.

13 MR LORD: I understand that, my Lord, and obviously we

14 wouldn’t dream of seeking any unreasonable extension of

15 the sitting hours here, but I am just trying — you

16 understand from my point of view, my Lord, I have

17 Russian clients who want — my ear is being chewed off

18 ceaselessly, understandably, as to when various

19 people — some of whom don’t work for the Bank, have got

20 day jobs and small children — I’m sorry, my Lord, I am

21 caught between a rock and a hard place —

22 MR JUSTICE HILDYARD: You are caught, and I remember the

23 days of it, and it is particularly — and one of

24 the supposed benefits of fixed trials is we will at

25 least have this ancillary advantage, it is a great,

158 :1 great pity, but it is, to some extent, a force of
2 circumstance. This is by no means a standard case.

3 Now, Mr Stroilov has indicated that perhaps, as he

4 becomes more settled and experienced, that subsequent

5 witnesses will take less time. That may or may not be,

6 but what has been shown is that we have to be pretty

7 realistic, and that realism is not going to be

8 comfortable.

9 So what are we going to do? I’m in your hands.

10 Mr Guz is first, he has other calls on his time. This

11 is an important case for the Bank, and therefore he will

12 want to be flexible, I know, but when?

13 MR LORD: I would need to check, my Lord, because it depends

14 on other witnesses. I have to shuffle witnesses around.

15 Certain witnesses can and can’t come in later slots.

16 I’m going to have to consider that, and it is important,

17 in my respectful submission, that next week we do call,

18 dare I say it, some of the higher up witnesses in

19 the Bank, and I am very anxious to do that so that

20 your Lordship can hear from some of the more senior

21 people in this case, and therefore I am considering how

22 to re-work this timetable. There won’t be witnesses

23 coming in week two who are not down to come in week two,

24 but the practical effect of what has happened this week

25 is I am going to have to stand out certain witnesses.

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159 :1 The difficulty is, without having any sort of
2 reliable estimate for timing from Mr Stroilov, I don’t

3 criticise, but I don’t have any such reliability, it is

4 almost impossible for me to advise my clients as to

5 which witness can come at which time in these slots.

6 Almost impossible.

7 MR JUSTICE HILDYARD: That’s understood. Now, I’ve always

8 worried about Mr Savelyev in week two, and I do wonder

9 whether we are going to get to Mr Savelyev in week two.

10 MR LORD: My Lord, coming at it from a different way, it may

11 be essential for Mr Savelyev to come in week two. It

12 may be that we have to bend our efforts to ensure that

13 that happens so that your Lordship hears from one of

14 the most important figures in the defendants’ claim.

15 MR JUSTICE HILDYARD: Yes.

16 MR LORD: Because at the moment, in my respectful

17 submission, there are an awful lot of points being taken

18 which, in my respectful submission, are really

19 peripheral, and there are some very, very big and

20 central points here which need to be addressed, and

21 I reserve the right in conducting this case on behalf of

22 my clients to cut to that chase, I am afraid, my Lord;

23 and if I have to move this timetable around and bring

24 Mr Savelyev forward, then I would reserve the right to

25 do that.

160 :1 MR JUSTICE HILDYARD: Let’s try and talk, away from
2 generality, to the particular.

3 Mr Stroilov, Ms Blinova, I’m not going to guillotine

4 you in the sense of simply turning my back and walking

5 out when you have exceeded your time limit, but

6 Ms Blinova must be finished by lunchtime tomorrow, no

7 later than that.

8 Therefore, in order to give us maximum chance, would

9 you like to start at 10.00 am?

10 MR STROILOV: Really, actually I wouldn’t, my Lord, because

11 it’s — in a way, I also need time to prepare for things

12 and actually I hope that preparation time shortens time

13 in court.

14 MR JUSTICE HILDYARD: Well, here’s the deal: We can start

15 whenever you want to start, but in all ordinary

16 circumstances, we are going to finish at 1.00. Now,

17 when do you want to start?

18 MR STROILOV: Well, I am content to start at 10.30 am,

19 finish at 1.00, and I finish at 1.00, I don’t know

20 whether a lengthy re-examination is anticipated, and I’m

21 not sure what is the plan for Mrs Patrakova, because

22 I understand that really it is tomorrow or never, so, of

23 course …

24 MR JUSTICE HILDYARD: My feeling is that you should finish

25 at 12.50, and we will sit until she is completed, even

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161 :1 if that means eating into eating time a little bit, and
2 we will then have — because this is what she has come

3 over for, as I understand it — Ms Patrakova, who is

4 going to be here for an hour.

5 On that footing, would we be right to get started on

6 Ms Yashkina?

7 MR LORD: Yes, my Lord.

8 MR STROILOV: My Lord, I am sorry to have put it like that,

9 but I appreciate I am quite irritating to everyone the

10 way I am doing it, but it is really very hard and I need

11 some breaks.

12 MR JUSTICE HILDYARD: I don’t mean to sound irritated. I am

13 appreciative it is difficult for every side. I am not

14 meaning to sound irritated, but we have to work out what

15 we are doing.

16 Now, when I asked you about the first week on

17 Thursday or Friday, you were quite calm about the first

18 week; it was the second week that you were really

19 concerned about, and I rather took your lead from that.

20 I can see the question of Mr Savelyev, you need time

21 for that. He is right at the — he is a party and he is

22 right in the middle of everything.

23 MR STROILOV: My Lord, this has to be put in context.

24 I think we very much rely on what you have said at

25 pre-trial review, that guesstimates are no good, you

162 :1 will look how it goes and decide on the timetable in
2 the first week. Well, we always said that four weeks

3 are not going to be enough for us. We’ve asked for six

4 weeks. If I’m given six weeks, I’m prepared even to be

5 guillotined, with six weeks with reasonable breaks. I’m

6 prepared to have that, but now to hold me to

7 the four-week timetable after I have expressly said it

8 is not going to be enough, and you expressly said you

9 are going to look how it goes and decide —

10 MR JUSTICE HILDYARD: I am already. I just don’t wish to

11 have an unseemly argument. The following will happen

12 tomorrow: Ms Blinova will have finished your

13 cross-examination by 12.50 pm. That’s not a guillotine,

14 but I shall be extremely disappointed if it doesn’t

15 finish by 12.50 pm, particularly as I have given you the

16 option, which you have declined, to start earlier.

17 Because you have declined it, we will start at 10.30 am.

18 MR STROILOV: Yes.

19 MR JUSTICE HILDYARD: Right. We will then move on after

20 re-examination and any questions that I may have to

21 Ms Patrakova, hopefully at 2.00, or if we eat into the

22 hour, 2.15, we will see, for an hour and no more. You

23 have always indicated that it would be done within

24 an hour and, again, whilst not a formal guillotine,

25 I shall be extremely disappointed if we are not finished

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163 :1 within the hour. That should take us to, at latest, to
2 3.15, we may need a break. I would have thought that we

3 should, then, if you are able to do this, go straight to

4 Ms Yashkina, but if you are not able to do that, then we

5 will have an early start on the 4th, at, say, 9.30 am,

6 in order to try and get Ms Yashkina done by midday, by

7 1.00 on that day.

8 MR LORD: We have Ms Shabalina as well, my Lord. So

9 Ms Shabalina doesn’t work for the Bank.

10 MR JUSTICE HILDYARD: Ms Shabalina, is she travelling from

11 Russia?

12 MR LORD: She’s arrived. So, my Lord, we are standing out

13 Mr Guz and we would very much hope to get Ms Yashkina

14 and Shabalina through this week. I accept we are going

15 to have to review next week, I accept that, and

16 obviously something is going to have to give next week,

17 unfortunately, but I accept that, we will do our best.

18 We can’t lose too many witnesses from the first week, in

19 my submission.

20 MR JUSTICE HILDYARD: It seems to me in the second week, and

21 I said this, I believe, that Ms Mironova, it seems to

22 me, is an important witness, and Mr Savelyev a very

23 important witness.

24 MR STROILOV: I dare say Mrs Volodina is quite important as

25 well. As you start preparing you can see that a witness

164 :1 is more important than you thought initially, so I would
2 say all of them are important.

3 MR LORD: My Lord, in that second week we have at the moment

4 three witnesses coming, it may well be we have to go

5 down to two witnesses.

6 MR JUSTICE HILDYARD: Will you try and see what the least

7 bad solution is. I quite understand your predicament,

8 Mr Lord. I quite understand the stresses on

9 Mr Stroilov, and I have just to be a little bit wary of

10 not biting off more than I can chew for fear of then not

11 being available.

12 So I think you are right that you need to slim down

13 the second week and try and work out what best, and tell

14 Mr Stroilov as early as you can.

15 MR LORD: For example, my Lord, Mr Stroilov has indicated on

16 his estimates, he said he needs, he thinks, three days

17 with Ms Mironova and up to four days with Mr Savelyev.

18 With the greatest of respect, we just don’t accept that

19 those are really realistic estimates.

20 MR JUSTICE HILDYARD: Three days with Ms Mironova?

21 MR LORD: Three days with her and four days with

22 Mr Savelyev. Four full court days. That makes it

23 difficult to plan, my Lord, because if we had a more

24 realistic estimate, in my submission, I could then build

25 in a bit of overspill, privately, and I could be sure

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165 :1 that I wasn’t calling a witness who wouldn’t be able to
2 be overspilt or come on a Monday, for example, in

3 extremis, or so on, that is what I am trying to juggle,

4 really. But I am not being helped by, in my submission,

5 what are really unrealistic estimates and estimates that

6 really — proportionate and fair cross-examination, does

7 not involve, for example, four days, in my submission of

8 Mr Savelyev.

9 So, my Lord, I don’t expect your Lordship to be

10 drawn now. I need to take stock, but it is important to

11 say that we think that, having lost a bit of ground this

12 week, and understanding we are going to have to slim

13 down the second week, the quid pro quo may be, really,

14 that there has to be a little bit of assessment as to

15 how long your Lordship thinks would be a reasonable time

16 for Mr Stroilov, and we have a more — even if it is

17 only aspirational, even if it is only a flexible target,

18 we start to think a bit more about splitting up the time

19 so that a little bit of fixity starts to come in.

20 MR JUSTICE HILDYARD: Right.

21 MR STROILOV: Perhaps I will say, actually there is a lot,

22 with what I agree in the submission of my learned

23 friend, in the sense that if we are given a timetable we

24 asked for in the first place, perhaps I will need to

25 revise it slightly, but not enormously, we are given

166 :1 breaks, because we are — really our preparations are in
2 a terrible state, and that actually lengthens the

3 process, because I am looking for documents while in

4 court.

5 But if we are given the six weeks for witnesses,

6 then I wouldn’t mind being held to the timetable,

7 I wouldn’t object to that.

8 But it has to be not the timetable which was, you

9 will recall, which was compiled on the assumptions that

10 my cross-examinations are going to take a lot less than

11 their estimates for them, let alone my estimates, and

12 I am afraid that is not the case. Well, it is certainly

13 my fault, but that’s the best I can do.

14 MR JUSTICE HILDYARD: I don’t think —

15 MR STROILOV: And I still need breaks, I do need breaks.

16 MR JUSTICE HILDYARD: I think experience so far has shown

17 that my hope that cross-examination would actually be,

18 as often it is in these circumstances, shorter, has not

19 been realised, and you are quite right that I was wrong

20 in that, or have been so far.

21 It may be that a gloomier, if you like, view as to

22 the time needed has to be taken in order to achieve

23 greater certainty. I will think about Mr Savelyev and

24 as to whether four days is a proportionate time.

25 I quite understand, Mr Stroilov, that it is not your

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167 :1 profession, although you are doing a remarkable job, and
2 that it is inevitable that you may take more time than

3 if you had, as Mr Lord has, however many years’

4 experience it is. I understand that, and I won’t be too

5 harsh about it, as I have constantly reassured you. But

6 four days on a single witness is a lot. It is really,

7 you know, more than 20 hours. That’s a lot of time.

8 MR LORD: My Lord, so it is not misunderstood, I’m not

9 trying to shield this witness. I am thinking, really,

10 about how many of the events he seems to be involved in,

11 how many bits of the story should fairly be put to him.

12 I’m not trying to limit that at all, I’m trying to

13 think: well, testing the conspiracy, what could be put

14 to the witness. I’m assuming that things that he won’t

15 know about are not going to be put to him, and time

16 won’t be taken with things that really he can’t be

17 expected to know about.

18 MR JUSTICE HILDYARD: On the whole Mr Stroilov has confined

19 himself, so far as documents, to documents which either

20 were sent to a witness or in which he or she was

21 involved which is, actually, refreshing, because very

22 often with litigants in person the questions come from

23 all angles to all witnesses, so I don’t think you should

24 be too critical in that regard. I will have another

25 read through Mr Savelyev’s evidence, and perhaps you

168 :1 might too. I think four days is a lot.
2 MR LORD: My Lord, your Lordship will understand that the

3 Bank is keen, really, for your Lordship to hear some of

4 the senior — one of the principal alleged wrongdoers

5 here, that in a way, in terms of the presentation of

6 the case that’s an important feature.

7 MR JUSTICE HILDYARD: Well, I understand that, but your

8 clients need to know, as I am sure they have been told,

9 that in the particular circumstances of this case,

10 excessive rigidity and a desire to get things over could

11 be a very shortcut to the longest possible of roads.

12 MR LORD: Yes, my Lord. I don’t think we can be criticised

13 so far. I think we have been pretty flexible, I would

14 have said, so far.

15 MR JUSTICE HILDYARD: No, I am not saying you are, I’m just

16 saying that when you are asked by your witnesses why you

17 can’t give more definite, blame A, the judge, B, the

18 circumstance. It’s my responsibility to try and ensure

19 that this is and is seen to be a fair trial. If it were

20 not, then there would be very considerable difficulties

21 at the end of the day and a lot of time would have been

22 wasted.

23 MR LORD: I understand, my Lord. I don’t mean to be

24 argumentative, I’m not intending to prolong this, but as

25 your Lordship understands, my intention would be that if

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169 :1 we can get some witnesses from different parts of
2 the hierarchy that, if you like, the sort of terrain

3 might become a bit more apparent.

4 MR JUSTICE HILDYARD: That is a matter of sequencing.

5 MR LORD: That was my hope, my Lord.

6 MR JUSTICE HILDYARD: I have sought not to boss you about

7 about sequencing, simply about timing. If you believe,

8 having had the experience of the last two days, that

9 a different sequence, putting up the primary witnesses

10 up the ladder, then I’ll leave that to your excellent

11 judgment, but you need to keep Mr Stroilov informed,

12 because he, as I remember, may survive day-to-day

13 knowing only and preparing only for the next day, and if

14 you are suddenly told that the next day is going to be

15 a different event, you are completely and utterly

16 discombobulated.

17 MR LORD: Yes, well I shan’t do that, my Lord.

18 Just one other point, on translations. We will

19 revisit that, but it would, in my submission, be

20 appropriate for any complaint about translations to be

21 identified so we can have them translated to save time.

22 In my respectful submission, none of the complaints

23 about — none of the documents that we have had had

24 translation complaints about, on a fair view,

25 there wouldn’t really have been a huge advantage to any

170 :1 witness if, in fact, that had been done a little ahead
2 of time and we would have saved a lot of time, and saved

3 understandable judicial ire, and also, where time is at

4 a premium, we shouldn’t really have to be sort of

5 faffing around complaining about translations. That is

6 an unnecessary inefficiency.

7 MR JUSTICE HILDYARD: I think it is — I mean, the machine

8 translations can be very far from satisfactory. The

9 «calamari» incident is an example of that, and it is

10 troubling when the court is asked to look at a paragraph

11 which really makes no sense.

12 MR LORD: I understand that, my Lord.

13 MR JUSTICE HILDYARD: Judicial ire is inevitable in those

14 circumstances, and as it is not part of my job to go

15 fishing around the documents to see what are and aren’t

16 proper translations, I am afraid the responsibility

17 lies, in effects, on your lot.

18 MR LORD: My Lord, it would be helpful if, in the normal

19 way, with this number of foreign language documents,

20 each party would identify which documents —

21 MR JUSTICE HILDYARD: I know.

22 MR LORD: This trial is costing a fortune each day, and

23 again, I am getting understandable querying as to why

24 that sort of efficiency can’t be carried out. The

25 client said: well, we’ve paid for Magnum, we’ve paid for

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

171 :1 a translator, we have done all we — if there are
2 documents that aren’t properly translated, we couldn’t

3 do every one, because that would have cost £1 million or

4 some fantastical figure. So surely the judge is going

5 to help us and say: well, which documents, Mr Stroilov,

6 do you want translated and we will try and do it, I’m

7 trying to explain: well, you know …

8 So I do ask again — in my submission, the

9 importance of preserving a degree of surprise, such as

10 it is, is outweighed by the efficient conduct of this —

11 if your Lordship is against me and we keep going as we

12 go, I will do the best I can, but I cannot, I am afraid,

13 promise to have ironed out every possible infelicity

14 that Mr Stroilov might want to alight upon to say: oh,

15 that’s not a very good translation. I cannot possibly

16 see how that might unfold given how many bundles there

17 are, where what we have done is try to err on the

18 inclusive side and now we’re almost being criticised for

19 having put too much in.

20 So my client says: how do we win? If we had left

21 stuff out there would have been complaints; we put it in

22 now and the judge is saying we haven’t translated it

23 all. What do we do?

24 So, my Lord, I am beseeching your Lordship to see

25 things from my perspective, perhaps just briefly.

172 :1 MR JUSTICE HILDYARD: Well, I try to see it and I understand
2 the words you explain. My concern is to ensure on

3 documents which are of substantive importance I know

4 what they say. In that respect I was, initially, at any

5 rate, surprised that documents which comprise or

6 evidence the decision-making processes at the Bank ought

7 to be intelligible. Other documents may not need to be,

8 but those seem to me to be documents which, by and

9 large, ought to be intelligible.

10 Now, I would very much have expected Mr Stroilov and

11 his client to have identified some time ago documents

12 which they were going to place particular reliance on,

13 and if they had done that, they could have preserved the

14 element of surprise, because there’s nowhere better to

15 hide a book than in a library. So that would have been

16 an alternative way of doing things.

17 As it is, that is not the course that is adopted.

18 I do not have much sympathy for the surprise argument,

19 but I know that if I cause Mr Stroilov to identify the

20 documents, he will have the less time, in

21 the circumstances that have arisen, to prepare.

22 Mr Stroilov, if there are documents which you

23 already know will require translation, it seems — and

24 if there are many of them, in your estimation — forget

25 about the judge’s ire, then I think you, in the

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

173 :1 circumstances, must provide that list. I think you
2 cannot have it all ways.

3 MR STROILOV: But I’m sorry, my Lord, I mean this really

4 suggests some misconception as to how — you know,

5 how — well, you obviously know how many of us are

6 there, but how it is going. I am literally working

7 to every deadline —

8 MR JUSTICE HILDYARD: I was careful in that the way

9 I expressed it. I said if you already know, that’s to

10 say, if it will not take more than ministerial time,

11 then why not send those? I just don’t think that I can

12 put the element of surprise at such a premium as to

13 dislocate this trial. Something has to give.

14 MR STROILOV: Yes, well that’s right, but obviously the

15 other part of it, and I don’t want to play the blame

16 game for too long, but ultimately the claimants were

17 responsible for the preparation of the bundle.

18 MR JUSTICE HILDYARD: No, Mr Stroilov. You and your clients

19 were also responsible for identifying in the bundle,

20 many months ago, when you were provided with the index,

21 those documents of which you thought the translations

22 were inadequate. I fully understand that that was

23 a great burden on you, having regard to your limited

24 resources, but I do not think that you were simply

25 entitled to say: we are in such a rotten position that

174 :1 you must do all our work for us, and if you can’t do it,
2 take the ire of the judge and the difficulties which

3 arise in due course. I do not think you can have your

4 cake and eat it in that way. There we are.

5 MR LORD: We will do our best, my Lord. I have set in

6 train, doing our best, to see if we can identify any of

7 these documents. We will do our best. We were hoping

8 that we might get a bit of reciprocity but we will see

9 what happens.

10 MR JUSTICE HILDYARD: The only thing I can say is if there

11 are documents — and I haven’t got into the documents —

12 it has been difficult enough keeping up with the actual

13 primary evidence, but if there are documents which

14 record substantive decisions of the Bank, or evidence

15 those decisions, then it will be necessary, I think, for

16 there to be a better translation than there is. Being

17 candid about it, I think that the machine translations

18 are much less satisfactory than I had imagined. They

19 are a very good example of why humans are better

20 than machines.

21 MR LORD: My Lord, we have tried — for a lot of the Bank

22 decisions that feed into how we see the case, those have

23 been faithfully translated. We don’t know really, to be

24 fair, how many in the myriad of decisions and minutes

25 and notes are going to be held to be forensically very

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

175 :1 important. So we will do our best, but I do have, with
2 respect, to make that point again. That is a fairness

3 point.

4 MR JUSTICE HILDYARD: So far as I am aware there are only

5 sort of less than 20 or so documents which so far as

6 Mr Stroilov is concerned, are suitable cases for

7 treatment.

8 MR STROILOV: I just have to mention that there has been —

9 out of that category which your Lordship spoke about,

10 there have been — it required an order for specific

11 disclosure of institutional and central files for these

12 documents to be disclosed, some are two and a half years

13 after they should have been.

14 MR JUSTICE HILDYARD: They were done in November latest,

15 weren’t they? I think it was October or November.

16 MR STROILOV: Quite.

17 MR LORD: I am sorry, my Lord, it is right that an awful lot

18 of time was spent in the last two or three months by the

19 defendants in challenging the idea of this trial, a lot

20 of time was taken, so again, we are where we are, but I

21 just ask that what is expected of my clients in a number

22 of ways, I am sure it will be, will just be tempered by

23 how we have got here and what — I’m not saying it won’t

24 be, I know it will be, but I just want to make sure that

25 I don’t end up being in the dog house every minute of

176 :1 every day of this trial, my Lord.
2 MR JUSTICE HILDYARD: Don’t worry, my ire is short-lived and

3 I wish to try and get to the right answer.

4 MR LORD: Thank you, my Lord.

5 MR JUSTICE HILDYARD: I’m not going to say much more, except

6 I know piously, but very seriously meant, there is only

7 one way in which the parties can justify the amount of

8 court time that they are seeking, and that is by

9 a proper and constructive collaboration to do the best

10 they can. It is not right that parties in any

11 predicament should not have done their best to

12 collaborate, even though some parties have greater

13 resources to put that collaboration into effect than

14 others.

15 Now, 10.30 am is your preference, Mr Stroilov?

16 MR STROILOV: That’s right, my Lord.

17 MR JUSTICE HILDYARD: Yes, and sequencing will be given

18 attention to, and I will be told, I think, tomorrow,

19 early, when Mr Guz is to be rescheduled, and whether it

20 is to be before or after Paris, and I would like a feel,

21 as early as possible, for my own preparation, what is to

22 become of next week.

23 I shall also want to know what unfairness there

24 would be if Mr Savelyev came after the Arkhangelskys,

25 given that a lot of the case does focus on the

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Bank St Petersburg v Vitaly Day 4

Arkhangelsky [Master]

177 :1 counterclaim, but I will leave that to you.
2 Very good. 10.30 am tomorrow. Thank you very much.

3 (4.50 pm)

4 (The court adjourned until 10.30 am on
5 Wednesday, 3 February 2016)

6

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

178 :1 INDEX
2 PAGE
3 Housekeeping ………………………………….. 1
4 MR ANDREI AKATOVICH BELYKH ……………………… 2
5 (Continued)
6 Cross-examination by MR STROILOV ………….. 2
7 (Continued)
8 Questions by MR JUSTICE HILDYARD …………. 54
9 Re-examination by MR LORD ……………….. 63
10 Housekeeping …………………………………. 66
11 MR VICTOR PROKOFIEV, Interpreter …………. 76
12 (Affirmed)
13 ELENA SERGEYEVNA BLINOVA (Affirmed) …………….. 76
14 Examination-in-chief by MR LORD ………….. 76
15 Cross-examination by MR STROILOV …………. 78
16 MS ELENA EDWARDS, Interpreter (Affirmed) …..95
17 Housekeeping ………………………………… 153
17
18

19

20

21

22

23

24

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Arkhangelsky [Master]

0

179 :1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

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additional ( 9 ) 4:8 38:1
40:23 43:11 43:23
150:7 150:8 159:7

$ 43:17 44:17 45:4 45:9
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162:2 162:23

58:5 98:1 129:4
133:10 133:17 140:3
amend58:12

additions98:17
140:9 165:22
amended,37:20

$20,00030:15

address ( 4 ) 1:13 45:5
agreed ( 2 ) 37:17 59:10
amending123:2

70:15 76:25
agreeing145:3
amendment.77:21

A addressed ( 2 ) 33:23
agreement, ( 40 ) 6:9
amendments ( 5 ) 37:21

159:20
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38:8 58:18 98:17

absence ( 2 ) 21:13
adjourned177:4
7:15 7:24 25:8 26:22
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adjournment, ( 3 ) 71:3
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among ( 4 ) 10:5 80:22

49:25

71:12 92:7
31:6 35:2 36:5 36:9
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absent22:4

adjust ( 3 ) 5:3 110:25
39:6 59:13 61:15
amongst ( 2 ) 68:5 68:5

absolutely ( 9 ) 9:7 9:11

131:8
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65:25 75:10 121:2

adjusted ( 2 ) 71:1
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124:12 141:18 146:12

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150:10

adjustments.110:21
90:10 91:1 91:5 91:16
analyse87:16

abstract ( 2 ) 15:21

ADK; ( 7 ) 13:20 13:25
98:21 100:17 119:5
analyses98:16

89:19

14:4 14:12 15:17 16:4
119:10 139:9 142:16
analysis ( 6 ) 18:9 18:9

accent ( 2 ) 1:24 2:2

62:16
agreements ( 10 ) 6:7
88:12 88:19 89:11

accept ( 14 ) 3:7 9:24

administration36:6
6:14 6:14 6:16 84:12
90:14

15:17 20:3 20:6 21:17

administrative83:9
88:15 88:21 89:2
ancillary ( 2 ) 86:6

88:8 118:10 133:15
admirably109:15
101:11 140:25
157:25

148:9 163:14 163:15

admit143:24
agrees ( 2 ) 80:21
and/or ( 2 ) 81:2 112:1

163:17 164:18

admitted43:18
140:23
ANDREI ( 2 ) 2:13 178:4

acceptable ( 2 ) 15:23

ado94:25
ahead ( 3 ) 11:14 72:22
angles167:23

41:18

adopted.172:17
170:1
another ( 39 ) 5:8 16:20

accepted ( 2 ) 59:9

advance ( 2 ) 80:21
AKATOVICH ( 2 ) 2:13
16:22 16:23 17:4

145:9

92:24
178:4
19:10 22:18 25:19

accepts ( 2 ) 145:15

advanced? ( 2 ) 82:8
Alekseyev,20:14
44:22 44:24 47:3 47:5

149:23

155:3
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55:9 57:17 63:3 73:12

accident, ( 2 ) 67:6

advancing81:10
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83:21 84:20 85:17

88:15

advantage ( 4 ) 17:9
46:21 46:22 46:23
90:12 90:20 96:7

accommodate ( 2 )
24:22 157:25 169:25
47:7 47:9 48:13 48:20
105:4 106:20 108:19

144:18 146:4

advise ( 2 ) 50:12 159:4
48:25
108:25 109:12 115:19

accompanied85:15

(Affirmed) ( 6 ) 76:6
alienation25:4
115:20 116:5 116:14

«Accomplished96:4

76:16 95:2 178:12
alight171:14
121:24 122:23 129:14

accordance ( 5 ) 35:1

178:13 178:16
allegation ( 3 ) 138:18
132:1 142:19 148:17

35:8 36:4 36:8 66:3

affixed142:6
138:19 138:20
152:11 167:24

according ( 3 ) 3:10

affixing144:19
alleged ( 4 ) 8:9 118:24
answer ( 15 ) 11:6 11:11

120:20 121:25

afraid ( 18 ) 5:14 8:25
118:25 168:4
63:25 68:24 71:8

Accordingly, ( 5 )
19:5 20:11 42:12 63:8
alleging ( 2 ) 136:7
72:17 73:3 93:11

127:22 128:8 128:21

80:5 96:11 104:7
136:7
110:2 131:25 137:18

128:25 146:6

109:5 110:2 114:2
allow ( 2 ) 60:9 72:4
150:22 150:23 151:4

account. ( 17 ) 10:14

119:23 137:1 159:22
allowed ( 4 ) 11:9 67:12
176:3

59:6 60:5 60:13 60:18

166:12 170:16 171:12
153:4 156:21
answering ( 3 ) 11:1

60:19 60:20 60:25

after, ( 31 ) 3:18 3:18
allowing157:3
136:18 150:5

61:21 61:22 62:3

8:7 8:9 16:3 19:22
almost ( 3 ) 159:4 159:6
answers ( 6 ) 11:3 53:20

62:12 84:19 90:19

22:4 22:12 31:5 39:25
171:18
76:17 83:25 149:5

91:6 91:7 142:19

46:13 46:14 48:12
alone166:11
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accounts ( 6 ) 69:2

48:16 59:2 66:3 70:12
along90:25
anticipate136:15

69:18 82:24 83:1

74:18 74:22 94:13
already ( 26 ) 16:5
anticipated ( 3 ) 66:4

83:20 86:18

107:19 117:4 124:19
35:10 55:20 67:9
66:14 160:20

accretion,97:22

128:12 130:13 155:4
67:17 85:18 94:20
anxious ( 3 ) 34:11 94:8

accrued32:4

162:7 162:19 175:13
101:19 102:6 103:24
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accumulated, ( 2 )
176:20 176:24
110:14 112:4 113:15
anybody92:2

128:4 135:3

afternoon ( 2 ) 152:8
115:5 122:17 128:5
anymore? ( 2 ) 10:2

accumulation.97:22

154:3
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accusations,125:12

again. ( 37 ) 1:7 8:25
155:16 162:10 172:23
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accused7:23

14:7 25:24 31:17
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accustomed131:18

34:22 37:9 61:22
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21:4 25:6 38:18 38:20

achieve166:22

64:23 68:9 68:14
43:18 45:22 50:16
40:17 67:13 75:24

acquired19:8

71:23 71:23 79:4
50:17 59:9 67:6 71:8
76:1 76:21 103:20

across ( 3 ) 104:16

79:19 83:5 84:4 86:21
88:17 92:18 100:8
112:19 112:20 112:25

131:12 148:11

90:16 101:21 107:7
104:20 109:1 109:10
123:2 123:4 125:13

acting ( 3 ) 137:23

110:11 111:3 112:17
118:21 118:24 120:17
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113:3 113:13 119:25
122:8 123:20 124:21
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127:4 131:10 132:11
131:22 134:20 141:13
75:18 75:23 76:22

activity86:24

136:12 137:17 162:24
143:11 145:16 150:16
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acts109:19

170:23 171:8 175:2
160:11 170:3 173:19
apart ( 10 ) 95:9 107:5

actual ( 7 ) 18:2 24:4

175:20
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26:21 28:25 37:5

against ( 8 ) 49:13
alteration, ( 2 ) 135:12
115:4 129:7 139:25

98:13 174:12

138:18 138:19 138:21
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added, ( 10 ) 58:11 69:1

140:18 147:20 148:2
alternative172:16
apartment56:7

97:12 97:15 100:20

171:11
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apologies, ( 5 ) 85:13

101:6 101:17 118:14

ago, ( 7 ) 44:6 63:1 63:7
55:10 72:21 145:15
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120:16 134:22

114:24 124:20 172:11
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apologise ( 12 ) 2:2

addition41:8

agree ( 19 ) 4:1 9:4
always ( 9 ) 13:16
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13:17 13:25 19:13
141:15 144:17 148:19
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116:16 152:25 153:7 153:11

apparent.169:3 apparently ( 5 ) 39:6

87:5 97:14 97:18 122:9

appear ( 3 ) 24:3 63:14 137:14

appears ( 12 ) 8:6 11:1 17:19 37:4 37:14 115:16 115:17 115:22 116:19 118:9 118:20 139:2

application ( 3 ) 69:12 80:24 89:10

application-specific.84:4

applications, ( 2 ) 19:3

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approval ( 8 ) 59:12 59:15 59:17 61:16 61:18 61:21 62:9 66:2

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argumentative,168:24 arise174:3

arisen, ( 2 ) 132:9 172:21

arising63:18

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128:20 158:14 159:23 170:5 170:15

arrange ( 3 ) 82:21 89:1 91:24

arranged ( 4 ) 27:7 37:1 59:17 106:17

arrangement86:7 arrangements ( 4 )

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arrears, ( 3 ) 86:17 134:23 134:23

arrival143:15 arrive143:15

arrived ( 4 ) 144:5 144:7 148:1 163:12

article ( 3 ) 47:21 48:6 48:10

artificially32:10 ascertain117:22 aside. ( 2 ) 62:1 116:18 ask ( 31 ) 13:11 20:8
25:1 35:13 40:11 40:20 50:4 51:2 71:24 72:6 72:7 72:11 72:12 74:9 75:23 82:12 84:22 94:23 103:4 117:23 125:10 126:4 132:1 137:4 145:7 146:9 150:23 151:7 155:18 171:8 175:21

asked ( 21 ) 10:8 10:20 11:2 16:12 45:11 66:12 94:24 122:6 122:10 125:6 128:12 129:13 129:25 135:12 138:1 143:6 161:16 162:3 165:24 168:16 170:10

asking, ( 13 ) 15:14 16:25 21:23 30:23 44:3 87:21 104:8 106:12 109:24 120:3 130:23 131:18 150:5

asks ( 2 ) 41:12 41:18 aspirational ( 2 ) 155:2

165:17 assembled106:25 assert101:18 assertion43:13

assess ( 2 ) 82:7 140:11 assessment ( 4 ) 81:12

84:3 90:4 165:14 assets? ( 5 ) 16:21 21:1 32:9 103:18 111:18 assist ( 7 ) 72:6 94:16

109:21 125:12 126:14 136:17 137:2

assisted132:3 associated85:12 association148:1 assume ( 3 ) 15:4 20:19
20:21 assumed67:14 assuming167:14 assumption18:19 assumptions ( 8 ) 12:2

12:3 12:22 12:24 13:1 17:19 124:2 166:9

assurance68:17

attached ( 3 ) 114:1

114:6 133:2 attachment ( 3 ) 39:5

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27:12 30:24 33:17 69:22 113:5 119:12 129:21 131:9 132:16 133:7 176:18

attitude ( 3 ) 7:9 10:9 14:10

auctions34:15 audit130:21

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36:8 77:12

authentic,65:15 authorised ( 3 ) 15:4

81:4 85:23 authorities, ( 2 ) 52:10

52:23 authority,61:19 automatically31:8 autumn ( 4 ) 128:20

130:21 130:23 137:14 availability,74:13 available ( 5 ) 75:25

100:11 133:23 142:5 164:11

avoid94:2

aware ( 7 ) 4:3 38:16 56:21 86:2 114:17 157:11 175:4

away ( 2 ) 74:22 160:1 awful ( 4 ) 73:19 93:10
159:17 175:17

B

{B1/4/8},65:21 {B1/5/8},65:22 {B1/7/13},65:20

B114126:17

{B2/12/3}.42:12 {B2/9/22}, ( 2 ) 76:11
77:5

{B2/9/43},77:10 {B2/9/45}, ( 2 ) 76:13
77:16

back ( 21 ) 5:9 5:11 9:22 37:10 66:5 69:11 70:19 70:25 101:20 108:7 121:7 123:24 131:1 131:4 143:18 153:10 153:11 154:14 154:16 154:17 160:4

back-up81:18 backdated,64:9

bad ( 7 ) 8:13 20:17 27:7 106:6 118:5 136:19 164:7

badly. ( 2 ) 52:25 141:2

Bank ( 168 ) 2:5 4:20 6:8 7:20 8:9 9:13 10:16 12:25 14:13 16:6 16:16 17:3 18:20 18:24 19:10 19:17 21:9 23:16 24:4 25:12 26:12 33:12 35:1 35:6 36:4 37:4 40:3 40:12 40:13 40:17 40:21 41:13 41:18 41:19 41:24 43:16 44:8 44:21 45:17 45:24 46:5 46:7 46:8 46:12 46:14 46:17 46:19 46:21 46:22 46:23 47:5 47:6 47:7 47:9 47:18 48:13 48:20 48:25 49:7 49:23

50:17 50:19 50:21 51:3 51:3 51:6 51:8 51:15 51:17 51:17 51:20 51:23 52:2 52:16 53:3 56:24 59:5 60:18 60:24 61:4 61:5 63:5 63:13 70:21 80:20 80:21 80:24 81:4 81:9 81:20 82:6 82:23 83:1 83:20 83:21 84:19 84:20 85:17 85:23 86:12 86:12 86:15 86:15 86:17 86:24 87:19 90:3 90:14 90:20 91:5 91:7 91:10 91:11 91:15 96:25 98:22 99:24 100:1 100:2 100:12 101:9 103:20 104:2 104:11 105:5 110:17 112:11 114:24 116:18 117:15 121:5 121:14 121:15 121:15 123:6 128:21 128:23 132:24 133:12 134:16 136:9 139:15 139:22 140:1 141:13 141:16 142:3 142:5 142:13 142:19 142:21 143:16 143:19 144:15 147:1 147:5 147:9 147:9 148:19 149:16 157:19 158:11 158:19 163:9 168:3 172:6 174:14 174:21

Bank’s ( 14 )10:17 13:5 26:11 62:3 62:12 62:18 90:9 90:12 90:17 90:21 101:22 103:18 106:24 143:8

banks ( 5 ) 51:19 82:23 91:8 91:8 91:12

based? ( 11 ) 12:22 14:10 30:19 43:19 54:17 55:3 85:2 89:11 103:25 143:8 147:10

basically ( 7 ) 6:15 43:7 70:1 90:1 102:10 102:11 149:4

basis ( 8 ) 17:20 24:10 85:25 97:24 99:19 128:4 133:9 145:12 bear ( 2 ) 74:10 114:4

bearing156:21 became ( 5 ) 16:6 57:24

123:22 130:5 137:23 become ( 2 ) 169:3

176:22

becomes ( 2 ) 97:23 158:4

becoming132:5 before, ( 37 ) 3:11 3:22

11:5 17:8 19:20 19:21 29:11 29:21 29:24 31:23 32:7 36:20 41:2 41:23 43:23 44:6 46:16 47:10 58:13 59:12 64:16 66:23 70:2 75:7 78:13 80:21 81:10 82:7 95:14 120:4 130:18 131:19 132:1 153:10 155:17 156:9 176:20

beg ( 12 ) 2:17 5:21 13:13 25:21 29:16 45:2 45:13 78:9 87:3 106:19 133:16 147:14

began ( 3 ) 10:21 46:7 130:25

beginning, ( 3 ) 67:1 76:14 116:11

behalf ( 5 ) 20:2 33:12 44:20 73:15 159:21

behaviour. ( 2 ) 53:6 68:1

behind ( 3 ) 73:16 73:23 76:11

belief ( 2 ) 77:25 78:2 believe ( 19 ) 11:19

19:17 21:8 28:9 38:5 43:7 46:8 46:10 46:16 59:16 80:8 94:10 122:22 127:10 131:1 131:5 135:17 163:21 169:7

bell, ( 2 ) 29:19 85:4 bells? ( 3 ) 21:7 31:9

39:12 below8:14

Belykh ( 56 ) 1:22 2:9 2:13 2:15 3:20 4:20 4:21 5:19 6:17 7:23 8:4 8:14 8:21 9:4 9:6 9:12 11:7 11:13 13:9 14:19 14:24 15:6 16:8 20:14 23:8 25:1 25:15 26:4 26:14 29:4 32:8 33:6 34:12 35:14 35:16 36:17 36:23 37:12 37:13 41:5 41:22 42:17 42:20 43:8 44:3 45:2 50:16 51:5 53:20 54:4 54:8 63:23 65:5 74:5 154:5 178:4

bend159:12 beneficial81:23 benefit35:13 benefits157:24 Berezin ( 2 ) 58:6 142:1 Berezovsky.48:8 berth36:12 beseeching171:24 best ( 18 ) 1:10 23:8

35:23 54:13 77:24 78:2 125:11 151:9 163:17 164:13 166:13 171:12 174:5 174:6 174:7 175:1 176:9 176:11

better, ( 10 ) 35:20 48:2 52:14 64:23 68:10 116:10 153:15 172:14 174:16 174:19

between ( 21 ) 3:23 5:20 19:15 20:13 40:6 40:8 45:21 46:12 50:8 56:16 59:10 62:17 64:14 71:3 73:8 82:22 86:14 98:10 137:22 151:12 157:21

bezaktseptnam ( 4 )

85:3 89:2 90:18 91:2 big ( 13 ) 2:8 2:16 20:23 26:5 27:16 28:11

31:15 33:10 33:23 37:5 37:14 56:13 159:19

bigger146:7 bilingual ( 3 ) 6:2 6:10

29:2 binding155:8

bit ( 23 ) 5:6 6:20 12:13 22:24 26:8 27:3 41:14 42:23 43:3 55:21 74:24 95:10 135:18 152:24 161:1 164:9 164:25 165:11 165:14 165:18 165:19 169:3 174:8

biting164:10 bits167:11

blame ( 2 ) 168:17 173:15

Blinova ( 77 ) 66:20 69:23 70:3 70:9 71:23 74:1 74:7 74:21 75:7 76:9 76:16 76:19 76:24 77:1 77:4 77:6 77:16 77:22 78:3 78:7 78:15 78:22 80:13 87:4 88:8 92:1 95:13 97:18 103:4 103:7 107:17 107:24 109:16 109:22 111:6 112:10 113:16 114:12 114:12 114:22 114:22 116:25 117:14 119:15 120:1 120:3 120:13 129:11 132:13 133:10 133:25 134:9 136:5 136:16 138:16 138:25 143:23 144:24 145:24 146:16 147:14 149:3 149:19 150:20 150:25 151:2 151:25 152:9 152:21 152:25 153:5 154:6 156:13 160:3 160:6 162:12 178:13

Blinova’s ( 3 )76:10

136:18 149:10 block? ( 3 ) 56:7 56:8

56:9

board ( 16 ) 50:13 59:16 60:1 62:10 64:1 64:12 64:22 65:8 65:11 66:3 103:17 104:5 131:12 134:4 148:11 154:12

body ( 5 ) 2:9 60:7 81:4 82:15 85:23

Book, ( 2 ) 12:16 172:15 books116:22

Borisova, ( 12 ) 98:7 98:14 99:5 99:8 99:12 99:21 102:8 102:19 115:17 115:21 128:15 128:21

borrower. ( 5 ) 81:1 86:23 123:5 130:5 130:5

borrowers, ( 3 ) 110:21 141:13 147:9

boss ( 3 ) 129:25 138:14 169:6

bosses ( 2 ) 141:15 141:19

both ( 25 ) 6:2 30:13 46:7 46:17 68:5 76:14 92:22 95:4 96:7 100:3 102:21 103:10 106:19 107:8 108:8 108:17 109:23 112:3 115:22 116:15 117:18 123:15 124:9 125:2 151:22

bother ( 2 ) 87:20 146:20

bottom ( 10 ) 9:1 13:14 20:12 34:7 48:10 88:6 96:3 96:9 143:21 151:7

box ( 5 ) 53:21 75:7 88:6 88:25 153:16

branch ( 11 ) 47:7 47:9 47:12 47:17 79:1 98:23 100:4 101:17 128:24 130:23 148:12

branch’s ( 2 )100:1 119:13

branches.57:3 branching86:23 breach ( 2 ) 7:14 144:20 breached6:8 breaches7:5

breaching, ( 3 ) 7:12

7:23 144:23 break, ( 12 ) 22:12

53:10 53:17 70:2 70:12 74:18 74:23 76:21 125:21 125:24 126:1 163:2

breaks. ( 5 ) 161:11 162:5 166:1 166:15 166:15

breath155:17

brief. ( 4 ) 11:15 12:13 64:11 81:7

briefly ( 9 ) 9:22 10:9 10:11 12:3 12:5 39:3 73:12 101:20 171:25

bring ( 7 ) 29:22 52:11 52:14 53:3 58:8 99:8 159:23

brings ( 4 ) 15:16 15:22 30:10 64:23

British26:13 broadly72:20

brought ( 6 ) 33:16 76:8 129:8 129:21 131:9 143:18

brutal138:17 build164:24 building ( 5 ) 43:17

56:12 56:13 56:20 86:12

buildings, ( 5 ) 11:23 56:10 56:15 56:23 56:25

built154:5 bundle. ( 9 ) 23:21

47:22 77:4 77:10 77:17 107:14 126:10 173:17 173:19

bundles ( 2 ) 130:6 171:16

burden ( 2 ) 57:21 173:23

burns24:6

business ( 9 ) 7:2 11:21 38:10 41:13 48:7 58:1 68:6 81:23 87:16

businesses, ( 2 ) 7:4 40:14

C

{C1/1/45}.41:4 {C1/9/2}13:11 {C1/9/4}.41:10

C159136:23 cadastral ( 7 ) 2:5 9:5

9:8 36:10 36:13 79:10 79:16

cake174:4

«calamari», ( 4 ) 6:23 6:24 8:7 170:9 calculation ( 2 ) 3:12
18:13

calculations ( 2 ) 14:10 137:18

calendar,59:4

call ( 13 ) 4:14 9:23 14:25 16:8 42:22 66:20 69:23 76:9 133:24 156:4 156:21 156:24 158:17

called ( 12 ) 21:3 26:12 27:3 87:6 96:4 98:7 100:14 100:14 102:7 106:15 119:18 135:19

calling165:1

calls ( 2 ) 45:9 158:10 calm161:17 camera.5:7

cameras4:25

can’t ( 15 )23:3 26:14 30:1 63:9 71:16 119:2 154:24 156:4 157:11 158:15 163:18 167:16 168:17 170:24 174:1

candid174:17

cannot ( 31 ) 22:4 30:2 32:5 32:15 33:19 38:19 40:5 41:25 60:16 65:12 85:11 89:25 101:18 102:3 104:7 106:12 109:21 110:2 114:10 122:13 124:3 124:21 125:6 129:3 129:6 140:11 144:6 144:12 171:12 171:15 173:2

capacity17:2 capital3:6 capitalisation ( 4 )

17:13 17:18 18:4 18:19

car ( 2 ) 44:13 44:18 career49:5

careful ( 3 ) 14:21 67:7 173:8

carefully ( 4 ) 18:20 18:25 32:14 94:17

carried ( 2 ) 101:23 170:24

carry ( 4 ) 1:15 81:12 90:3 150:18

cases ( 6 ) 68:4 91:14 111:17 111:19 112:14 175:6

cash ( 10 ) 43:20 44:7 44:8 44:12 44:15 44:21 45:5 45:9 91:8 91:12

cashing44:9 categorically ( 2 ) 42:3
42:5

category ( 2 ) 146:18 175:9

caught ( 2 ) 157:21 157:22

cause ( 2 ) 73:2 172:19 caused ( 2 ) 2:3 68:2 causes153:1 ceaselessly,157:18 cent ( 4 ) 17:14 52:1

155:3 155:4 central; ( 13 ) 23:18

23:25 43:19 50:19 51:3 51:17 51:20 51:23 61:5 121:15 132:23 159:20 175:11

centralisation130:17 centralise130:6 certain ( 27 ) 6:14 6:15

7:1 15:19 16:11 19:17 28:23 31:19 37:20 38:1 38:4 40:17 45:21 46:19 49:23 80:14 81:6 85:18 89:12 106:5 114:17 117:4 125:2 139:6 146:18 158:15 158:25

certainty.166:23 certified ( 2 ) 140:16
141:4

certify? ( 4 ) 141:3 141:7 142:6 148:8

cetera.123:20 chairman154:11 challenging175:19 chance ( 3 ) 27:11
154:10 160:8 change, ( 4 ) 111:11
123:13 129:20 137:7

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changed ( 8 ) 14:9
131:2 141:19 144:17
59:22 59:24 60:1 60:7
confidence67:15
continue ( 2 ) 2:11

27:22 38:5 58:16
147:25 170:25 171:20
61:17 62:10 79:1
confident28:17
94:25

87:25 113:8 113:10
172:11
common ( 3 ) 64:21
confined167:18
(Continued) ( 4 ) 2:13

138:8
client’s ( 2 )60:13 91:7
140:3 140:8
confirm ( 8 ) 6:3 20:14
2:14 178:5 178:7

changes. ( 7 ) 45:22
clients ( 25 ) 21:8 28:5
companies, ( 2 ) 69:15
20:18 21:24 67:6
continues ( 2 ) 31:5

97:16 97:17 112:1
51:7 51:10 51:14
147:8
77:22 78:1 79:21
96:8

113:5 123:23 129:19
62:21 83:17 86:16
company ( 20 ) 13:19
confirmation64:24
continuing,122:21

«changing79:16
144:10 144:18 144:21
21:2 21:3 21:3 21:6
confirmed58:20
contract, ( 16 ) 82:15

charge ( 4 ) 83:12
146:19 147:13 148:10
25:9 25:10 26:12 27:5
confirms58:23
82:16 84:10 84:21

114:18 134:24 142:21
148:12 148:13 148:17
34:25 38:17 38:19
conformity,143:13
84:25 85:1 85:7 85:14

charging83:20
148:18 148:18 157:17
87:6 87:7 88:18 90:6
confront71:9
85:14 85:19 85:22

chase,159:22
159:4 159:22 168:8
90:9 90:10 90:14
confused. ( 2 ) 63:8
86:11 86:13 86:13

chat153:6
173:18 175:21
102:17
96:12
86:14 105:13

chattering67:2
close ( 8 ) 55:18 59:6
compare, ( 4 ) 113:12
conjuring117:3
contracts, ( 8 ) 83:11

check ( 9 ) 45:25 71:1
60:5 60:19 60:20
113:12 113:17 143:20
connected, ( 2 ) 48:19
84:8 85:9 86:10 86:19

98:15 99:9 126:8
60:25 61:20 62:2
compared ( 3 ) 51:19
68:18
105:9 137:16 143:12

126:12 127:11 145:11
Closed ( 3 ) 21:3 21:6
142:4 142:7
connection. ( 3 ) 43:21
contradiction44:14

158:13
128:17
competence.83:8
48:21 93:2
contradicts41:14

checked ( 3 ) 102:19
closely. ( 2 ) 28:17 37:3
compile107:25
connections52:22
contrary ( 2 ) 6:7 6:13

140:18 144:2
closing ( 3 ) 60:17
compiled. ( 7 ) 96:22
conscious53:8
control ( 2 ) 46:15

checking ( 4 ) 12:8
61:22 69:2
97:8 107:19 111:7
consent ( 19 ) 2:5 9:14
150:12

13:24 16:1 62:19
clumsily,27:4
111:22 112:15 166:9
25:3 26:11 33:25 37:6
controlled,102:19

checks130:22
clumsy53:22
compiling102:10
103:18 139:15 139:24
convenience103:3

cheques44:9
coach120:8
complaining170:5
140:8 140:13 142:14
convenient72:19

chew164:10
coincide ( 2 ) 4:6 37:25
complaint169:20
142:15 142:17 144:8
conveniently104:11

chewed157:17
coincided49:4
complaints ( 3 ) 169:22
147:2 147:3 148:20
conveyed68:22

children, ( 6 ) 74:2
coincidence ( 2 ) 19:15
169:24 171:21
149:15
copies106:23

94:13 141:14 144:15
49:1
complete. ( 8 ) 5:22
consents ( 3 ) 143:18
copy, ( 4 ) 58:9 106:18

149:1 157:20
coincides48:25
16:24 17:5 70:9
148:3 148:24
107:1 108:11

choke ( 2 ) 10:22 11:1
collaborate,176:12
111:12 131:25 136:17
consequently, ( 2 ) corporate84:2

choose41:12
collaboration ( 2 ) 156:1
81:24 124:15
corporation’s84:3

chosen10:16
176:9 176:13
completed ( 4 ) 92:13
consider ( 8 ) 14:6
corporations84:6

chronological. ( 11 ) collated ( 2 ) 100:20
99:20 131:20 160:25
14:13 15:23 44:3 56:9
correct ( 32 ) 1:20 2:7

38:24 100:25 101:7
102:6
completely ( 6 ) 19:4
74:24 94:17 158:16
9:6 9:7 9:20 16:13

104:22 104:23 105:19
collateral ( 3 ) 81:16
58:10 58:10 63:3
considerable, ( 2 ) 18:16 33:3 46:18

106:6 106:11 111:13
81:16 88:8
154:24 169:15
94:10 168:20
48:14 49:19 77:13

111:23 113:20
colleague147:21
completeness, ( 4 ) consideration ( 4 ) 80:1 83:12 84:1 90:2

chronologically. ( 2 ) colleagues ( 2 ) 27:13
31:3 34:20 36:20
34:13 74:12 89:22
95:25 98:9 100:23

106:17 111:22
56:11
108:21
91:9
101:5 107:20 121:8

chronology ( 2 ) 96:23
collected134:18
complicated ( 5 ) 11:16
considered. ( 16 ) 4:8
121:11 122:20 123:24

97:13
come ( 28 ) 8:7 9:22
12:14 12:17 12:18
10:1 10:2 10:5 11:17
123:25 130:11 131:3

circumstance ( 3 ) 68:17 73:21 74:10
89:20
19:17 19:20 22:22
132:10 139:5 149:18

146:4 158:2 168:18
75:20 75:21 82:3
complied135:1
24:11 24:12 27:6
151:17

circumstances, ( 11 ) 89:10 89:12 110:18
comply139:6
31:13 31:15 33:11
corrected ( 12 ) 77:23

74:12 124:4 148:22
113:4 118:18 121:7
compound67:20
37:13 91:5
123:10 124:14 128:6

155:8 155:13 160:16
123:24 141:16 141:21
comprise172:5
considering ( 6 ) 5:5
128:7 128:25 129:8

166:18 168:9 170:14
142:12 142:23 148:23
computer,99:7
6:10 7:21 19:2 58:9
133:1 133:6 133:20

172:21 173:1
158:15 158:23 159:5
computers,112:14
158:21
133:22 134:5

cite131:6
159:11 161:2 165:2
conceal ( 4 ) 117:16
considers ( 2 ) 18:15
correction ( 7 ) 76:12

claimant’s126:17
165:19 167:22
117:17 133:11 136:10
28:21
77:18 77:24 111:9

claimants’ ( 2 )136:24
comes ( 10 ) 4:11 8:11
concealed117:18
consistent44:4
112:9 122:20 132:14

173:16
8:15 15:21 52:7 58:13
concept,15:11
conspiracy,167:13
corrections131:11

clarified86:21
75:7 81:5 105:5
concern ( 2 ) 157:8
constant57:3
correctly, ( 4 ) 18:12

clarify ( 9 ) 80:17 86:3
109:13
172:2
constantly167:5
45:17 99:14 128:20

110:11 116:10 126:4
comfort ( 2 ) 52:11
concerned ( 10 ) 49:18
constrained51:6
corresponds127:10

127:12 127:15 129:6
150:13
51:14 52:4 74:1 104:7
constructed52:6
cost ( 4 ) 93:9 93:12

137:12
comfortable ( 3 ) 70:2
149:2 153:17 154:21
constructing56:25
94:5 171:3

clause ( 7 ) 30:3 30:14
76:20 158:8
161:19 175:6
constructive176:9
costing ( 2 ) 93:10

30:16 31:4 87:22 89:3
coming ( 8 ) 2:1 110:16
concerning ( 6 ) 7:2
consult40:13
170:22

141:10
131:18 144:14 152:14
12:2 15:2 28:19 40:14
consultancy ( 4 ) 39:6
couldn’t ( 4 )61:20

clauses ( 2 ) 29:18
158:23 159:10 164:4
49:22
39:7 40:4 40:23
62:12 143:17 171:2

30:23
command ( 2 ) 137:7
concerns.69:25
consultants. ( 3 ) 39:22
count ( 2 ) 96:19 112:22

clear ( 22 ) 1:25 7:15
149:20
concessions ( 2 ) 63:5 63:14
counter44:8

15:10 20:1 20:5 40:7
comment ( 19 ) 21:11
147:10 147:12
consulting40:17
counterclaim,177:1

57:5 57:20 57:22 59:4
32:5 37:19 39:18
concise,151:8
contact ( 3 ) 40:13
countersign143:21

59:8 61:2 115:8 119:1
39:23 41:15 42:1
conclude87:18
141:23 142:7
country153:8

120:4 120:5 129:18
64:11 83:3 104:7
concluded, ( 2 ) 1:15 contain ( 7 ) 80:8
couple ( 4 ) 38:21 49:9

134:9 138:7 138:8
109:17 111:25 112:17
90:11
100:25 106:4 117:5
69:25 152:16

144:24 157:4
112:25 113:13 114:11
concludes53:24
122:1 122:2 122:5
courier144:21

cleared58:5
129:6 134:7 136:12
conclusion ( 3 ) 125:17
contained, ( 3 ) 115:18
course. ( 42 ) 2:10 5:13

clearly,118:23
commenting67:7
125:18 129:9
122:4 129:5
11:8 11:22 12:8 16:15

client, ( 40 ) 7:19 15:15
comments ( 7 ) 14:7
conclusions ( 3 ) 16:11
containing126:18
21:17 28:21 35:5

15:21 27:3 27:9 27:18
32:15 33:14 41:21
88:5 89:12
contemporaneous. ( 2 ) 38:8 44:24 49:23 50:1

28:3 28:7 28:13 33:10
67:7 67:14 67:24
concrete58:18
1:23 90:8
58:17 60:3 62:6 64:17

37:25 40:13 49:23
Commersant,48:6
condition88:13
content ( 3 ) 22:21
70:22 71:4 71:19

50:13 51:2 60:9 61:24
committee ( 23 ) 2:8
conditions ( 4 ) 81:6
24:15 160:18
72:21 73:15 79:7

63:5 63:7 63:11 83:15
2:17 20:24 21:13
84:8 87:23 88:19
contents, ( 2 ) 15:17
80:24 83:17 91:17

86:12 86:15 86:24
23:17 26:6 27:17
conduct171:10
77:23
94:8 104:8 106:12

90:9 101:25 127:18
28:12 28:21 31:16
conducted, ( 2 ) 68:7
context ( 8 ) 11:3 11:5
108:3 113:8 123:1

128:9 129:1 129:15
33:10 33:24 37:5
68:7
11:10 151:5 151:6
125:23 133:8 133:13

130:2 130:7 130:9
37:14 37:22 38:6
conducting159:21
151:13 151:14 161:23
139:17 147:12 149:10

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157:3 160:23 172:17 174:3

court’s94:3

credit ( 27 ) 2:8 2:17 20:23 21:12 23:17 26:5 27:17 28:11 28:21 31:16 33:10 33:24 37:5 37:14 37:22 38:6 79:1 87:6 98:21 100:17 101:6 101:11 101:16 101:23 114:13 138:5 148:15

crept124:13 criminal ( 2 ) 47:11
48:19

crisis ( 3 ) 11:25 14:8 51:13

critical ( 2 ) 151:22 167:24

criticise ( 2 ) 6:1 159:3 criticised ( 2 ) 168:12

171:18 criticism149:3 cross-examination,

( 17 ) 1:14 2:14 2:24 10:25 53:25 74:22 78:5 94:25 146:1 149:5 149:11 150:4 162:13 165:6 166:17 178:6 178:15

cross-examinations166:10

cross-examine152:9 cross-examined,153:14 cross-examining ( 3 )

71:5 150:11 155:17 crucial.146:12 curiosity123:11 curious147:24 current45:22 customers.51:16 cut159:22

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{D1/2/1},87:2 {D1/2/10}87:2 {D1/2/11}.87:3 {D1/2/19}88:4 {D1/2/9},88:4 {D10/228.3/0.1},47:25 {D10/228.3/0.3}48:2 {D10/228.3/1}.48:5 {D117/1763/1},4:14 {D117/1763/2}.5:19 {D122/1935/1},20:8 {D122/1935/3}.20:10 {D126/1991/3}.14:16 {D126/1991/4},14:23

{D126/1991/5}. ( 2 )

14:23 17:25

{D128/2060/1}.29:1 {D128/2060/2},30:14 {D128/2060/4}.29:4 {D130/2111/0.1}.127:1 {D130/2111/0.3}127:8

{D134/2202.1/0.1}. ( 2 )

25:20 37:10

{D134/2202.1/1}.26:4 {D134/2202/1}33:21 {D134/2202/2}33:22 {D134/2203/1},36:21 {D34/537/1}.38:23 {D34/537/2}.39:1 {D37/621/0.1}.95:8 {D37/621/0.2},108:25

{D37/621/0.3} ( 3 )

102:25 108:8 109:11

{D37/621/0.4}. ( 3 )

96:10 102:22 107:9

{D37/621/1}.95:12
debt ( 10 ) 95:19 97:23
departments, ( 4 ) directly ( 6 ) 45:18

{D37/621/2},108:25
98:20 106:6 106:7
100:12 102:1 104:1
45:20 72:12 83:1

{D37/621/3}, ( 3 ) 102:24
118:5 134:23 134:23
134:16
90:19 98:14

108:9 109:7
135:2 136:19
departure ( 2 ) 47:11
director ( 6 ) 119:13

{D37/621/4}, ( 2 ) 96:10 debtors.102:3
48:18
128:24 137:23 137:25

107:9
debts ( 9 ) 51:9 51:9
depend58:18
138:14 141:25

{D38/641/1};138:22
95:22 99:1 99:25
depending122:19
director’s129:8

{D38/641/2}.138:24
100:3 102:1 121:13
depends ( 8 ) 14:6
directorate; ( 16 ) 27:19

{D93/1166/1}. ( 2 ) 78:8
124:16
28:18 56:9 72:9 72:10
28:3 28:7 28:14 33:11

78:10
December ( 2 ) 3:23
82:14 122:19 158:13
127:18 127:24 128:9

{D93/1166/2}.78:12
55:11
describe14:5
129:2 129:15 130:1

{D93/1166/3}78:19
decide ( 2 ) 162:1 162:9
described ( 6 ) 17:2
130:3 130:4 130:10

{D93/1166/4}78:20
decided ( 7 ) 19:8 37:6
60:5 84:25 91:14
130:16 131:2

{D93/1166/5}79:18
37:15 41:12 41:17
99:13 107:24
disagree.43:24

{D93/1166/6}79:19
49:5 85:22
describes98:3
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{D98/1251/1},63:22
decides81:4
describing106:8
16:6 67:1 162:14

{D98/1253.1/0.1}.65:2
deciding18:20
description16:13
162:25

{D98/1253.1/1}.65:10
decision ( 29 ) 2:16
descriptions,68:1
disappointing,153:2

{D98/1256/1}8:23
2:23 3:11 3:15 3:17
desire168:10
disappointments,16:17

{D98/1256/2},8:24
4:5 20:23 25:19 26:10
desk ( 6 ) 43:20 44:7
disbursed ( 2 ) 60:13

{D99/1282/1},69:1
26:16 26:20 28:13
44:15 44:22 45:6 45:9
62:7

daily ( 3 ) 94:19 99:19
28:15 37:24 38:4
desperately70:1
disbursing ( 2 ) 61:22

133:9
38:8 49:6 52:15 64:16
despite ( 2 ) 6:14 16:17
61:25

danger157:10
64:17 64:20 65:8
destroy132:22
disclosed ( 11 ) 105:6

dare ( 4 ) 117:2 117:3
82:14 83:13 85:23
destroyed, ( 4 ) 129:4
106:9 115:14 115:25

158:18 163:24
90:24 103:17 104:6
132:15 132:17 132:21
116:7 116:13 116:14

date ( 23 ) 2:19 2:19
134:3
detail, ( 6 ) 3:2 6:21
116:15 117:5 118:12

4:11 30:9 55:10 61:7
decision-making ( 2 ) 24:14 28:2 28:12
175:12

64:4 64:9 69:19 95:18
24:4 172:6
149:25
disclosure ( 6 ) 104:11

95:18 103:14 108:17
decisions ( 8 ) 37:20
detailed87:4
107:2 112:12 116:4

114:19 117:4 119:6
51:24 64:14 84:5
details, ( 19 ) 9:19 27:21
136:24 175:11

121:24 123:1 124:1
174:14 174:15 174:22
38:3 49:14 59:3 63:7
discombobulated.169:16

126:5 128:13 128:18
174:24
78:24 79:2 80:5 80:11
disconnect,113:14

140:19
declarant’s140:19
90:12 99:23 109:18
discovered ( 3 ) 1:19
dated ( 5 ) 5:21 5:22
declaration ( 12 ) 140:4
135:23 140:17 140:18
8:20 95:20

27:15 128:14 128:18
140:16 140:18 140:22
142:7 142:8 144:2
discrepancies?127:13

dates ( 9 ) 64:24 69:3
141:4 142:13 143:7
detain54:9
discrepancy,65:25

96:8 97:9 98:2 116:19
143:9 144:1 144:6
detained153:8
discuss ( 8 ) 15:20 71:2

116:20 142:10 144:6
144:25 147:22
determine72:18
71:13 71:21 75:16

day ( 39 ) 30:18 32:3
declarations, ( 4 ) devalue10:25
92:1 96:14 153:13

54:14 54:22 54:23
141:17 142:2 144:20
development ( 2 ) 7:2
discussed ( 7 ) 8:22

55:1 57:25 58:2 59:5
148:2
12:2
16:5 22:22 26:19 38:4

59:17 59:18 61:6
declare51:15
diary ( 3 ) 57:11 57:14
44:15 89:2

61:12 64:19 72:13
declined, ( 2 ) 162:16
71:16
discussing ( 4 ) 2:16

74:5 74:6 108:4 108:4
162:17
didn’t ( 17 )4:13 7:4
45:19 55:23 153:16

124:12 127:22 131:8
deduction52:1
7:10 7:14 16:24 57:11
discussion ( 8 ) 2:22

137:21 143:19 143:19 deeply ( 2 ) 14:12 27:24
83:24 90:22 96:19
21:4 21:25 22:6 26:20

144:16 152:22 152:22
default ( 8 ) 8:9 28:23
104:15 113:9 116:20
44:11 58:16 58:17

154:6 154:9 155:18
51:24 51:25 82:25
120:23 123:3 142:25
discussions ( 5 ) 7:1

157:8 157:20 163:7
84:18 86:17 130:13
148:1 152:16
17:1 38:1 50:2 79:14

168:21 169:13 169:14
defaults51:15
differ.133:16
dishonest, ( 3 ) 134:1

170:22 176:1
defendants ( 4 ) 20:2
difference ( 5 ) 3:11
135:7 136:9

day-to-day169:12
104:10 159:14 175:19
46:11 72:22 98:10
dishonesty ( 4 ) 67:18

{Day3/27:1},54:16
defer73:8
111:17
116:21 118:25 138:20

{Day3/98:1},58:23
deference1:13 different ( 36 ) 3:13
dislocate173:13

days ( 26 ) 30:8 72:15
deficiency27:10
6:11 10:16 12:1 12:13
dispensing89:16

93:8 97:4 97:25
deficient.24:17
14:8 14:8 18:16 18:17
disposal72:6

120:15 137:22 154:7
definite,168:17
27:1 44:25 44:25
disputed69:9

154:8 155:5 155:6
definitely ( 8 ) 6:23 12:1
45:7 45:21 49:5 55:17
disputing113:19

156:2 156:22 157:4
50:11 52:15 55:8 63:1
55:22 56:1 56:16 57:3
disrespect,150:23

157:23 164:16 164:17
65:12 124:11
63:4 84:4 84:5 109:24
distance,19:17

164:20 164:21 164:21
degree171:9
110:16 110:16 121:5
distraction150:11

164:22 165:7 166:24
delay5:15
123:13 138:6 142:15
divider ( 2 ) 76:11 77:5

167:6 168:1 169:8
delegated28:6
142:15 142:17 159:10
document ( 61 ) 8:21

deadline173:7
delete135:21
169:1 169:9 169:15
20:8 20:10 21:19 22:1

deal ( 8 ) 27:13 32:2
deleted ( 5 ) 68:21
difficult ( 15 ) 4:4 11:16
23:17 23:19 23:24

81:5 89:21 89:24
111:11 112:14 136:1
23:24 24:1 56:12
24:8 25:18 25:22

149:12 149:13 160:14
138:9
72:16 94:11 131:22
27:15 28:19 29:10

dealing ( 6 ) 27:23
deliberately5:11
144:16 150:10 151:22
29:24 31:14 32:5

40:12 44:13 52:18
demand91:11
151:23 161:13 164:23
32:15 32:16 33:18

90:13 122:24
demonstrated11:8
174:12
33:20 33:21 39:15

deals,40:16
denies ( 2 ) 43:19 43:22
difficulties ( 4 ) 50:18
43:22 65:1 68:24

dealt152:10
deny ( 2 ) 21:24 42:3
94:9 168:20 174:2
78:11 78:20 78:21

dear.75:10
denying ( 2 ) 49:15
difficulty159:1
78:22 78:24 78:25

debate ( 2 ) 23:14 62:16
56:18
diminish156:10
80:3 80:6 80:7 80:8

debit ( 14 ) 82:22 83:20
department ( 15 ) 15:25
direct ( 16 ) 46:14 82:22
87:3 87:7 87:10 87:15

84:12 85:5 85:13
27:2 27:7 100:4 101:8
83:20 84:12 85:5
87:22 95:13 109:23

85:16 86:7 86:10
101:25 102:2 130:7
85:13 85:16 86:6
113:20 115:13 115:23

89:17 90:18 91:1 91:5
130:21 137:24 137:25
86:10 89:17 90:18
116:2 118:17 119:15

91:12 91:15
141:24 142:21 143:14
91:1 91:5 91:12 91:15
126:17 126:22 128:22

148:15
134:15
133:3 133:4 133:5

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133:19 136:23 139:6 143:21 144:25 146:23

documentation83:13 documents ( 86 ) 3:8

3:16 23:20 24:2 24:3 24:12 37:13 38:3 48:20 59:2 71:9 76:14 83:16 90:7 100:18 100:18 100:19 103:11 106:4 106:24 109:22 111:13 111:16 111:21 112:23 113:10 113:13 113:17 114:1 114:4 114:5 114:8 114:9 114:9 115:9 115:12 117:5 117:15 118:2 120:6 120:14 120:15 122:2 122:4 123:6 124:9 124:12 130:15 130:24 131:4 131:8 131:12 132:25 133:11 134:19 134:21 137:6 137:13 138:2 138:6 138:13 143:22 152:17 166:3 167:19 167:19 169:23 170:15 170:19 170:20 171:2 171:5 172:3 172:5 172:7 172:8 172:11 172:20 172:22 173:21 174:7 174:11 174:11 174:13 175:5 175:12

does ( 29 ) 8:7 21:6 23:6 31:9 31:9 38:7 39:12 44:22 44:24 54:1 54:3 63:14 65:10 73:3 80:8 81:20 83:2 84:2 85:4 85:5 111:2 115:14 125:2 130:17 140:7 145:2 153:25 165:6 176:25

doesn’t ( 21 )10:22 13:12 25:15 29:7 31:1 31:2 37:17 37:24 39:21 43:21 48:16 65:18 75:1 78:9 137:17 145:2 150:18 150:20 154:19 162:14 163:9

dog175:25

doing ( 14 ) 53:22 63:10 83:9 95:4 102:9 102:12 130:25 133:9 137:9 161:10 161:15 167:1 172:16 174:6

domestic153:1 don’t ( 160 )1:23 3:14

4:25 6:1 6:20 10:3 10:7 10:17 12:19 13:18 14:11 15:20 16:19 17:5 20:2 20:4 20:6 20:21 21:9 21:16 22:5 23:2 23:12 23:25 26:18 26:20 29:8 29:11 31:14 31:17 31:18 31:21 31:24 32:13 33:8 33:14 33:16 33:18 34:8 34:8 35:25 38:3 38:11 38:13 38:14 38:18 38:18 39:13 39:15 40:5 40:6 40:7 40:16 40:21 40:24 42:1 42:4 42:5 42:6 42:7 42:14 44:13 46:9 47:2 48:23 49:14 49:14 49:15 49:20 49:21 50:6 50:6 50:22 50:25 51:22 52:20 53:5 53:5 54:6 54:6 54:21 54:25 56:19 57:19 62:23

63:6 63:6 63:7 63:11 65:4 66:10 66:11 66:21 69:4 71:19 73:18 75:12 75:17 79:24 83:4 87:16 87:19 87:20 88:22 92:15 96:25 103:13 104:8 106:7 107:23 108:12 109:7 110:1 111:20 112:2 112:22 115:11 116:9 116:23 117:9 117:21 118:6 124:6 131:7 132:4 134:7 136:3 142:18 145:25 146:1 146:8 146:10 146:19 146:20 148:5 149:6 149:6 149:14 150:8 151:21 152:7 152:17 155:12 157:19 159:2 159:3 160:19 161:12 162:10 164:18 165:9 166:14 167:23 168:12 168:23 173:11 173:15 174:23 175:25 176:2

done ( 30 ) 2:8 11:7 12:14 16:14 19:11 60:21 63:9 63:11 70:24 75:12 90:14 95:18 97:20 98:19 100:2 112:11 121:16 126:25 137:9 145:19 149:19 149:21 162:23 163:6 170:1 171:1 171:17 172:13 175:14 176:11

Doomsday12:16 dossier100:14 double ( 2 ) 116:12
116:22

doubled-up ( 2 ) 126:6 126:7

doubling-up128:10 doubts ( 2 ) 147:18
148:20

down, ( 30 ) 14:19 14:22 26:7 26:7 30:13 37:11 42:13 48:2 60:10 65:3 65:4 65:9 69:5 76:19 78:19 79:18 88:3 96:2 96:7 102:22 107:8 109:6 109:6 109:10 115:12 123:14 158:23 164:5 164:12 165:13

dozens ( 5 ) 19:3 96:17 111:15 111:15 113:18

draft ( 5 ) 20:23 21:20 24:3 39:6 39:25 drafted ( 9 ) 33:6 80:9

87:8 87:24 97:6 97:21 97:24 134:20 138:15

drafting ( 4 ) 97:14 99:2 103:25 121:2

drafts98:13

draw ( 6 ) 26:24 44:8 60:16 70:6 119:12 155:17

drawing ( 3 ) 30:24 112:6 114:18

drawn ( 5 ) 60:9 69:21 108:3 147:3 165:10

dream157:14

drew ( 2 ) 108:3 133:23 driven150:11 dual92:25

due ( 5 ) 2:10 27:12 28:23 60:3 174:3

duly38:6

duplicated ( 3 ) 104:21 107:12 113:17

duplicates, ( 2 ) 111:15
62:2 70:24 87:22
80:14 87:18 142:25
except ( 3 ) 76:17 97:12

111:15
97:12 105:21 119:21
150:20
176:5

during ( 8 ) 4:7 19:2
129:12 130:20 157:9
establish ( 2 ) 19:8
exceptions148:21

35:11 45:19 53:13
157:11 168:21 175:25
125:15
excessive ( 3 ) 151:20

55:6 55:8 62:7
endeavour ( 3 ) 127:12
established15:25
152:10 168:10

duties ( 2 ) 123:4 123:5
151:9 151:12
estate ( 9 ) 22:7 25:11
exchange ( 5 ) 5:20

duty121:11
endeavouring154:4
26:12 29:6 34:24 35:6
5:22 5:24 8:7 58:15

ending ( 2 ) 107:25
36:3 36:16 88:10
executive. ( 6 ) 98:12

E 119:10
estimate ( 5 ) 70:5 74:6
98:13 102:16 102:18

ends108:1
155:5 159:2 164:24
120:25 122:23

enforced; ( 3 ) 86:7
estimates, ( 6 ) 164:16
executor, ( 5 ) 98:8 99:5

e-mail ( 20 ) 5:20 5:22

139:19 139:20
164:19 165:5 165:5
119:17 119:22 120:1

5:24 6:5 7:6 8:12 8:13
England, ( 2 ) 12:17
166:11 166:11
exercise,28:4

8:14 9:2 36:24 36:24
72:21
estimation172:24
exhausting71:6

39:5 39:8 78:15 78:16
English ( 25 ) 17:11
evaluate ( 2 ) 96:19
exhibit ( 2 ) 14:1 14:4

78:17 78:18 99:12
22:12 23:2 23:3 23:7
143:6
exhibited,14:18

110:19 141:22
25:7 26:9 29:2 35:19
evaluated143:11
exist.56:23

e-mailed132:20
36:1 38:24 67:15
evaluation. ( 2 ) 18:17
existed, ( 2 ) 11:25

eager92:16
69:11 76:13 78:14
19:16
137:14

ear157:17
79:24 93:1 93:19
evaluator,18:15
existence ( 3 ) 12:9 12:9

earlier ( 8 ) 46:8 46:9
93:21 93:23 103:8
Even ( 11 ) 48:5 66:15
12:10

66:4 73:2 74:20 76:8
109:9 127:5 127:9
68:7 74:5 78:24 114:4
existing147:11

112:22 162:16
138:25
160:25 162:4 165:16
expect ( 4 ) 18:24 101:7

early ( 10 ) 45:23 57:8
enjoy68:15
165:17 176:12
150:8 165:9

58:7 58:14 130:20
enjoyable92:2
event, ( 4 ) 74:19 155:18
expectation154:7

156:15 163:5 164:14
enormously ( 2 ) 32:23
155:18 169:15
expected ( 4 ) 152:23

176:19 176:21
165:25
events, ( 11 ) 19:22
167:17 172:10 175:21

easier14:15
enough. ( 11 ) 19:18
45:19 48:18 48:21
expecting ( 2 ) 39:23

easing147:11
20:4 27:11 32:4 52:22
55:23 57:6 57:12
151:25

easy.22:10
58:16 61:2 119:1
57:15 127:17 134:8
expects152:14

eat ( 2 ) 162:21 174:4
162:3 162:8 174:12
167:10
expenses94:10

eating ( 2 ) 161:1 161:1
ensure ( 5 ) 24:7 131:24
ever ( 4 ) 31:22 63:4
expensive;39:11

economic ( 4 ) 12:7
159:12 168:18 172:2
122:7 123:16
experience? ( 8 ) 17:9

12:11 18:8 18:11
enter ( 4 ) 62:12 85:21
every ( 23 ) 82:15 86:22
18:24 70:4 81:15

EDWARDS, ( 2 ) 95:2
121:17 145:2
89:21 89:22 97:4
86:22 166:16 167:4

178:16
entered ( 5 ) 85:1 85:7
97:10 97:25 105:8
169:8

effect ( 10 ) 10:25 33:7
85:19 86:20 98:16
105:11 110:14 114:19
experienced,158:4

33:13 33:16 59:13
entering140:24
115:12 120:14 127:22
experiment ( 2 ) 24:21

93:17 110:24 140:23
Enterprises ( 2 ) 26:13
143:14 144:11 155:1
34:9

158:24 176:13
38:16
161:13 171:3 171:13
expert, ( 2 ) 10:16 22:11

effective?139:12
entire ( 2 ) 30:15 30:17
173:7 175:25 176:1
experts11:20

effectively,31:7
entirely ( 3 ) 75:20
everyone ( 3 ) 35:20
expired31:6

effects,170:17
104:24 151:18
75:4 161:9
expiring,4:7

efficiency170:24
entitled ( 2 ) 32:24
everything ( 5 ) 67:15
explain ( 13 ) 8:2 10:9

efficient171:10
173:25
99:14 126:9 126:24
10:11 10:21 10:23

efforts159:12
entrances, ( 2 ) 56:11
161:22
19:1 39:17 43:21

eight90:1
56:17
everywhere,108:23
98:10 110:11 129:3

either ( 5 ) 98:6 110:1
entries ( 11 ) 68:25
evidence. ( 28 ) 16:2
171:7 172:2

115:21 151:22 167:19
97:12 99:8 101:3
43:12 44:4 52:6 57:18
explained ( 7 ) 3:9

elastic154:24
108:15 108:20 110:13
57:21 64:5 64:8 66:18
10:24 12:3 23:21

electronic ( 2 ) 109:2
112:14 117:6 118:14
69:17 74:4 83:23 86:3
28:20 55:3 157:7

109:12
125:1
86:8 94:19 114:5
explaining ( 3 ) 27:20

elegant112:16
entry ( 37 ) 103:1
120:5 122:6 131:20
27:21 54:17

elegantly ( 3 ) 50:24
103:12 103:23 107:11
142:25 149:15 151:17
explanation ( 15 ) 11:10

51:1 51:1
108:9 108:19 108:25
156:12 157:1 167:25
58:25 113:3 113:3

element ( 2 ) 172:14
109:8 109:9 109:12
172:6 174:13 174:14
115:1 115:3 115:4

173:12
110:8 110:24 111:17
evident145:4
117:25 118:7 124:6

ELENA ( 6 ) 76:16 77:1
112:14 113:20 115:13
exact ( 4 ) 55:10 107:1
124:7 124:21 125:11

95:2 141:24 178:13
115:19 115:19 115:24
119:2 142:9
125:15 135:11

178:16
116:2 116:12 116:22
exactly, ( 23 ) 15:25
exploit35:16

else ( 3 ) 32:24 92:2
119:4 119:22 120:2
37:23 44:12 46:9 47:2
exposure,3:13

132:20
122:1 122:3 122:5
55:12 58:6 58:21 63:6
expressed173:9

emendations.135:16
128:6 128:16 128:18
64:13 80:18 82:4 94:7
expressly ( 2 ) 162:7

emerge24:14
129:13 129:14 134:6
96:21 99:22 100:6
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emerging66:12
135:14 135:17 138:9
111:4 115:8 118:15
extend ( 4 ) 2:17 2:18

emotional ( 2 ) 7:9 68:3
equation,151:23
128:1 129:1 130:11
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emotions,68:5
equipment ( 4 ) 6:24
144:4
extendable, ( 2 ) 31:7

emphasise11:4
6:25 40:15 81:2
examination, ( 3 ) 11:8
31:8

employed110:17
erasure.136:11
75:4 131:22
extended ( 4 ) 3:21

employee ( 2 ) 90:13
ergo48:16
Examination-in-chief 32:21 85:24 140:12

122:23
err171:17
( 2 ) 76:23 178:14
extending19:20

employees ( 5 ) 47:16
error ( 8 ) 2:2 121:11
example, ( 16 ) 5:8
extension ( 2 ) 3:6

48:12 100:4 121:6
124:13 124:18 128:2
12:16 60:10 93:7 98:2
157:14

148:15
128:5 128:7 129:5
99:6 110:22 115:19
extent, ( 3 ) 147:10

encourage ( 3 ) 11:5
errors1:19 121:9 123:18 128:14
151:19 158:1

29:13 68:4
especially145:1
164:15 165:2 165:7
extra156:5

encouragement145:16
essence ( 3 ) 3:14 22:13
170:9 174:19
extract64:1

encumbrance34:15
22:20
exceeded, ( 2 ) 70:5
extraordinary89:9

end ( 22 ) 5:16 14:23
essential159:11
160:5
extreme148:22

46:10 47:1 47:1 49:10
essentially, ( 8 ) 27:14
excellent169:10

50:9 50:16 52:2 55:9
27:16 28:3 33:24

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extremely ( 6 ) 17:15 18:5 94:11 121:14 162:14 162:25

extremis,165:3

F

F/162.136:25

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112:24 115:11 117:15 118:19

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157:3 158:12 165:17
164:22
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168:13
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110:3 111:4 112:1
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113:10 124:22 124:23
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76:8
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137:11 137:21 137:22
57:1 57:4 57:10 57:14

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99:4 99:20 128:10
60:14 60:17 60:22

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176:25
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100:1 100:5 101:24
73:18 73:25 74:17

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80:22 81:2 81:11
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120:22 121:19 121:21

110:1
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50:19 50:25 51:3
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161:5 163:6 163:13
150:17 150:18 150:19
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168:10 169:1 174:8
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157:7 157:22 159:7

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160:3 162:13 162:24
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162:19 163:10 163:20

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155:14 155:17 156:11
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166:24 167:6 168:1
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19:23 24:5
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161:17
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friends ( 2 ) 126:13
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152:2
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132:23
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32:2 32:17 33:4 34:11
152:6 152:15 152:17

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156:5 161:4 162:22 162:22 162:24 163:1

hour’s74:22

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156:17
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158:16 159:14 163:22
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impossible ( 2 ) 159:4
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112:4 114:17
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information ( 28 ) 4:8
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joining ( 2 ) 46:13 46:14 Joint ( 5 ) 21:3 21:6

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174:2 judge’s172:25 Judging97:9 judgment. ( 4 ) 4:4

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107:11 107:19 107:20
117:15 136:10 138:19
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108:1 108:17 126:15
146:4 156:2 157:4
13:13 25:21 29:16

175:15
160:8 163:6 166:22
45:3 45:13 78:9 87:3

odd ( 3 ) 121:21 123:14
175:10
106:19 147:14

124:19
ordered92:24
Paris, ( 6 ) 72:9 72:10

offence.133:21
ordinarily72:2
72:13 72:21 72:23

offer ( 11 ) 83:3 104:7
ordinary160:15
176:20

109:17 111:25 112:17
organisation.50:14
part ( 22 ) 13:19 18:13

113:1 113:14 114:10
organise93:25
37:4 51:11 58:3 58:24

115:4 134:7 136:12
organisers92:23
58:25 59:1 71:6 80:4

offered ( 3 ) 39:7 80:25
organising ( 2 ) 50:8
83:18 89:7 107:2

87:23
50:11
110:12 118:22 121:13

offering143:15
original ( 2 ) 92:20
122:15 134:17 135:5

office, ( 14 ) 42:9 43:13
124:17
140:13 170:14 173:15

43:17 43:19 44:17
originally ( 2 ) 74:3
participate, ( 2 ) 92:17

44:22 45:4 45:6 45:9
156:6
94:9

54:20 56:18 99:24
originated,136:10
participated21:25

100:5 101:24
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officer. ( 6 ) 7:20 49:24
148:11
particular ( 25 ) 13:11

87:23 88:7 120:25
others ( 5 ) 24:17 84:7
28:19 33:19 33:20

138:5
146:5 150:9 176:14
58:18 62:8 95:23

officer’s88:2
otherwise ( 6 ) 52:3
109:20 110:19 111:5

offices ( 3 ) 49:12 56:3
73:9 76:18 116:22
111:5 117:16 123:5

56:22
140:12 156:3
132:16 134:6 135:17

141:19 142:11 142:14

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144:5 144:23 151:21
134:11 138:20 140:6
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160:2 168:9 172:12
144:11 145:3 147:2
11:18 27:20 93:24

particularly ( 2 ) 157:23
personally, ( 9 ) 40:22
142:20

162:15
59:13 134:1 135:4
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parties ( 5 ) 68:5 82:22
138:18 147:18 148:16
4:21 4:22 5:15 7:3

176:7 176:10 176:12
148:23 157:8
28:11 38:9 40:24

«partition»,79:16
persons ( 2 ) 67:13 88:1
42:14 65:5 74:20

partly14:14
perspective,171:25
74:25 89:15 89:17

parts ( 2 ) 33:20 169:1
persuade3:17
92:17 92:21 92:23

party, ( 7 ) 73:15 75:25
perused114:9
93:12 93:25 102:11

86:15 86:16 86:18
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125:21 126:21 151:6

161:21 170:20
35:1 35:6 36:4 36:7
154:20 168:11 171:13

pass73:17
36:11 36:14 46:12
176:21

passage,13:11
47:6 47:7 47:9 49:7
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passed ( 2 ) 130:9
77:2 84:19
119:19 148:21 171:15

134:20
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passport ( 4 ) 140:17
PhD18:23
postpone51:9

140:19 144:2 145:11
phone ( 2 ) 93:2 135:25
postponed ( 2 ) 64:18

Patrakova ( 12 ) 70:10
photographs ( 2 ) 1:21 110:25

70:12 74:21 152:5
1:25 potential ( 3 ) 7:2 40:16

152:9 152:13 156:12
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82:12

156:16 156:18 160:21
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161:3 162:21
141:16 144:15
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(Pause). ( 5 ) 25:23 41:3
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149:8 158:24

42:19 91:18 146:24
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pausing17:18
pieces81:1
practice ( 17 ) 37:20

pay ( 2 ) 32:2 133:7
piously,176:6
50:1 64:21 82:6 82:17

paying27:11
pity,158:1
82:19 82:21 83:23

payments.3:25
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91:11 101:12 101:14

peculiar155:7
55:13 55:17 55:22
144:8 146:17 147:11

people ( 21 ) 12:8 19:9
56:1 62:5 64:12 64:22
148:6 148:7 151:16

19:19 27:8 44:18
86:11 94:2 94:20
pre-trial161:25

47:18 67:10 67:17
104:19 118:4 123:23
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67:18 68:5 85:21
130:18 131:14 135:24
predicament, ( 2 ) 164:7

102:12 110:17 135:25
157:21 165:24 172:12
176:11

136:9 138:1 138:2
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prefer ( 3 ) 1:14 73:20

146:4 146:5 157:19
plan ( 4 ) 41:13 152:5
92:18

158:21
160:21 164:23
preference,176:15

per ( 7 ) 17:14 30:15
planning ( 2 ) 72:13
premises,99:18

52:1 83:13 139:22
72:14
premium, ( 2 ) 170:4

155:3 155:4
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pere79:12
119:17 128:19 138:15
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perfectly62:24
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57:2 70:7 90:7 160:12

performed.98:4
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173:17 176:21

perhaps ( 42 ) 1:10 4:15
pleased1:11 preparations166:1

6:3 10:11 14:15 14:19
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prepare ( 7 ) 89:7

17:7 20:12 23:8 24:20
26:12 33:13 36:15
126:11 127:16 127:23

26:21 28:24 29:18
79:5 103:20
138:2 160:11 172:21

34:8 39:18 40:22
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40:25 41:7 52:17
35:6 35:10 36:3 36:9
65:6 70:3 87:5 94:6

66:7 66:7 68:20 69:24
36:16 103:18
94:16 95:16 105:5

70:9 70:10 71:2 71:12
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114:13 122:18 126:24

96:17 99:23 102:21
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162:4 162:6

126:10 126:12 136:14
25:11 36:9 79:9
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136:21 150:17 151:3
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83:19 87:7 87:9

151:20 158:3 165:21
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114:10 127:16 127:20

165:24 167:25 171:25
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163:25 169:13

period ( 10 ) 4:7 30:17
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presence, ( 11 ) 140:17

45:23 46:20 51:10
points ( 5 ) 58:20 150:9
141:5 141:8 142:9

62:8 98:25 101:3
151:1 159:17 159:20
144:2 144:3 145:10

102:4 127:25
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145:23 146:5 147:4

periodically ( 2 ) 95:17
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97:4
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permanently100:13
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permission, ( 2 ) 105:7
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110:10
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168:5

permitted,72:3
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person ( 13 ) 7:25 15:3
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19:5 65:7

26:24 73:14 99:24
14:19 21:24 27:2
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124:15 124:16 128:23
37:16 48:25 58:12
71:14

139:10 141:23 145:19
73:16 81:12 81:21
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147:2 167:22
81:25 82:7 84:3 84:6
172:13

personal ( 26 ) 28:19
90:4 92:25 113:12
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57:20 59:21 62:11
156:4 173:25
171:9

69:1 69:13 74:14
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80:15 80:22 81:3
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81:10 81:15 81:17
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presumably ( 3 ) 89:7

83:24 86:4 86:5 86:19
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98:22 99:15

86:22 86:25 134:2
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pretty ( 3 ) 96:12 158:6
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168:13
152:12
11:6 18:6 22:13 22:20

previous ( 9 ) 11:11
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41:14 97:11 99:7
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30:22 32:11 40:9 43:9

121:11 123:25 124:1
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45:1 48:9 63:25 71:25

124:14 129:24
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72:8 73:4 73:6 80:17

previously155:3
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82:4 83:5 87:21 90:22

price; ( 5 ) 11:19 34:14
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92:15 101:10 105:22

39:22 40:8 40:11
60:10 60:12 61:23
106:14 107:21 110:2

primarily44:17
171:2
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primary ( 2 ) 169:9
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174:13
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principal ( 2 ) 3:10
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168:4
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61:15 62:11 89:15
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print ( 2 ) 99:8 99:15
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printed ( 4 ) 99:17 99:17
28:16 28:22 33:25
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112:15 138:3
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prior ( 2 ) 46:16 112:12
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priority147:9
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54:7 54:9 54:14 63:18

prisoner? ( 2 ) 34:22
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35:1
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76:17 78:4 162:20

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39:2 54:12 67:17 75:8
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105:3 145:15 154:16
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problem ( 23 ) 28:5
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40:10 40:20 67:21
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95:19 95:22 98:20
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25:25 32:2 32:4 37:23

98:21 99:1 99:25
82:12 103:17 124:6
38:8 38:23 41:22

100:3 102:1 102:3
129:14 147:12 173:1
43:13 44:4 47:13 49:6

104:2 109:5 110:15
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50:15 50:22 51:4 52:3

110:21 111:12 121:13
92:25 107:2 140:1
52:7 55:22 56:1 57:19

124:16 130:5 132:6
173:20
65:14 81:20 83:17

135:2
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problematic106:6
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problems ( 3 ) 27:6 73:1
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103:2 105:3 105:9

153:1
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105:10 110:13 116:9

procedure ( 12 ) 19:1
32:21 32:22
117:8 125:18 134:10

20:3 27:23 45:11
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138:16 141:8 143:5

48:19 80:14 80:19
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147:24 149:12 149:25

80:20 81:3 81:8
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152:19 152:19 161:9

105:14 141:22
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161:17 163:24 164:7

procedures135:1
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164:8 166:19 166:25

proceed71:11
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145:12
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67:3 67:8 67:16 68:9
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71:17 72:6 76:2 87:10
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100:15 104:10 106:10
136:24
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113:25 116:18
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153:3 156:1

process ( 11 ) 24:4
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38:11 71:10 80:18
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87:9 90:7 105:15
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107:3 107:24 137:8
119:2 123:2 123:3
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166:3
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56:11 129:13
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120:14 130:3
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102:18
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proffering147:2
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145:13 148:4 148:6
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progress70:17
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project,87:16
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PROKOFIEV, ( 2 ) 76:6
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178:11
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prolonged53:22
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«promise» ( 2 ) 152:13
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171:13
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18:1 19:21 19:21 22:14 31:19 32:7 35:9 68:16 93:18 130:15

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34:24 35:5 36:3 36:15 40:19 88:10

realised ( 3 ) 33:7 33:12 166:19

realism158:7

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rearrange71:15 reason ( 20 ) 3:21 3:22

9:19 11:3 15:20 16:5 34:15 37:7 37:21 39:25 42:13 56:24 89:15 89:17 91:2 138:8 141:18 144:22 148:25 157:3
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reasons. ( 9 ) 28:23 89:4 91:4 141:17 143:17 144:19 146:8 147:11 149:8

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121:2 121:8 121:15
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122:7 122:8 122:15
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123:17 123:25 128:3
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103:13 104:12 104:16
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104:18 104:20 104:23
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105:4 105:4 105:9
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119:4 121:4 121:9
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121:11 121:23 122:8
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122:17 122:19 122:21
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122:23 123:19 124:14
31:9 39:12 85:4
3:24 50:4 50:9 58:8

126:6 126:14 127:16
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127:20 127:23 127:24
156:18
159:8 159:9 159:11

128:2 128:5 128:7
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159:24 161:20 163:22

128:16 128:25 129:4
143:10
164:17 164:22 165:8

129:20 130:2 131:13
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166:23 176:24

132:15 132:19 134:5
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136:19 137:16
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represented72:3
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10:2 48:7
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152:11
80:7 80:18 83:4 105:8

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114:7 114:16 118:6

86:6 94:19 144:8
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119:3 128:20 129:10

147:1 172:23
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151:11 168:15 168:16

135:13 175:10
69:14
171:22 175:23

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139:15 139:18
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22:7 25:3 25:9 88:18

requirements ( 4 ) RPC72:11
90:6 90:10

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143:9
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rescheduled,176:19
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159:21 159:24
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resources, ( 2 ) 173:24
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176:13
20:20 22:15 23:5 23:9
87:2 95:8 95:11 95:14

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25:1 26:3 29:3 34:12
96:2 96:10 101:2

58:24 62:10 67:2
35:14 35:22 36:1
102:24 104:25 105:16

82:15 84:9 86:10
36:22 38:25 42:21
107:18 108:12 108:24

86:19 104:5 109:19
43:6 43:6 47:22 48:7
108:24 109:3 109:6

110:15 111:5 112:5
68:7 69:6 69:10 75:18
115:13 116:6 138:23

113:14 114:11 114:19
76:10 76:12 78:12
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134:6 135:14 140:1
79:12 79:13 79:22
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156:13 164:18 172:4
85:3 92:19 93:1 93:1
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175:2
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respectful ( 4 ) 158:17
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159:16 159:18 169:22
100:15 103:5 109:6
65:4 69:5 78:19 79:18

respectively ( 4 ) 82:23
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88:4 104:17 127:6
139:2 149:14 157:17
107:8 108:8 109:3

response8:15
109:6 109:6 109:10

scrolled14:21

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scrolling65:3
sell ( 2 ) 11:18 16:17
105:24 105:25 106:1

scrolls65:9
send ( 8 ) 40:1 78:25
106:2 106:17 107:10

scrutinise28:12
99:12 127:24 130:24
108:1 126:19

scrutiny20:3
131:4 141:22 173:11
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18:3 22:19 22:20 32:6
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44:9 105:25 109:8
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163:20 164:3 164:13
160:4 165:23 170:11
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96:4 96:24 96:24
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98:14 102:7
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81:15 81:17 81:18
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134:24 140:25
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9:12 9:15 9:16 13:1
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13:13 14:12 14:20
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15:20 18:14 20:21
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20:24 21:19 26:4
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26:10 26:14 26:15
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27:14 28:9 29:5 30:3
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30:6 30:10 30:14
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55:2 59:1 63:23 65:5
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66:6 69:5 69:6 70:16
76:16 77:1 178:13
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70:17 74:9 74:17 75:3 series ( 4 ) 115:9 115:18
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77:7 77:9 77:18 78:12
131:21 137:22
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78:17 78:25 79:24
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96:8 96:8 96:11 96:16
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96:23 96:24 96:25
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97:5 97:9 101:1 101:2
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104:25 104:25 105:16
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106:18 107:18 108:11
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119:21 124:18 125:19 sets ( 8 ) 104:22 104:23
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142:21 147:24 148:4
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152:16 155:25 161:20
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162:22 163:25 164:6
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170:15 171:16 171:24
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66:25 70:4 76:13 80:7
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90:6 96:5 98:5 168:19
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143:16 143:20 144:2
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signify ( 2 ) 139:9
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125:6 140:21 142:13
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142:23 147:19 147:20
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148:2 152:16
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similar. ( 7 ) 42:23
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97:11 101:7 104:22
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117:21 118:1 119:1

105:9 105:10 147:21
12:18 14:9 14:9 19:3
72:13 72:20 72:20
120:7 122:11 124:24

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125:4 125:8 125:20

52:7 60:15
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110:21 110:25 138:5
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24:22 34:9
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160:14 160:15 160:17
132:2 132:7 132:11

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160:18 162:16 162:17
135:10 136:3 137:12

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135:19
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14:25 15:16 18:7
square ( 2 ) 36:10 36:13
32:8 33:5 34:12 34:17
4:10 6:8 39:11 39:24

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suggests ( 5 ) 36:25 40:19 48:11 136:11 173:4

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technically ( 2 ) 92:23 94:7

technologically93:12 technology ( 2 ) 5:3

5:12 tedious,137:5 telephone ( 2 ) 58:14

110:18 telephoned49:18 telling ( 3 ) 50:21

114:16 123:16 tells ( 2 ) 112:4 112:6 tempered175:22

ten ( 9 ) 47:16 47:19 48:12 53:12 53:13 53:15 97:25 120:14 121:9

ten-minute125:24 term ( 6 ) 30:18 31:6

34:15 79:12 79:17 126:6

Terminal ( 8 ) 1:21 2:6 14:16 26:11 29:7 57:7 79:6 103:19

terms ( 17 ) 4:3 6:6 6:13 18:21 22:6 29:12 52:18 52:19 69:18 79:13 81:6 84:8 87:23 88:6 89:24 135:2 168:5

terrain169:2 terrible166:2 terribly ( 4 ) 5:4 5:8

109:11 132:2 tested,94:2 testing167:13

text, ( 7 ) 6:4 6:22 15:2 18:14 35:13 65:6 140:15

thanks. ( 6 ) 5:17 46:16 72:25 73:6 98:19 153:21

That’s ( 80 )2:6 4:8 5:22 6:17 7:10 7:19 8:9 9:10 12:13 13:10 14:16 14:22 15:23 20:22 27:25 28:1

32:17
33:1 38:24
27:14 27:16 31:19
too ( 17 ) 23:12 28:17

39:22
41:1 41:9 41:25
32:21 33:17 43:17
39:11 75:5 107:12

44:11
45:9 48:6 50:1
44:6 45:19 45:21
138:17 144:14 152:13

50:11
50:15 51:12
45:22 45:24 46:2
153:9 157:8 157:10

52:24
55:22 56:5
46:5 46:6 46:10 46:19
163:18 167:4 167:24

62:24 64:2 65:25
46:20 46:23 48:8 49:1
168:1 171:19 173:16

69:5 72:11 73:5 79:21
49:4 49:6 51:13 51:22
took ( 2 ) 64:22 161:19

80:1 89:21 96:15 98:8
55:6 56:23 57:8 60:18
topics.92:3

103:16 105:2 106:13
62:19 62:20 62:22
total ( 4 ) 17:16 36:15

107:15 107:18 108:18
62:25 63:1 63:7 70:5
62:6 154:9

108:21 111:17 113:8
70:8 72:12 72:14
totally52:24

118:6 119:14 119:16
72:19 72:20 72:23
touch40:3

119:23 120:15 122:9
73:9 73:23 74:6 76:21
towards ( 4 ) 20:12

124:19 126:16 127:11
80:10 85:11 86:22
50:16 119:20 129:12

130:24 134:9 137:1
88:13 88:14 88:20
tracking115:12

137:10 140:6 140:8
88:20 89:8 89:8 94:3
trades43:5

140:25 150:1 150:1
98:25 100:12 101:3
tradition,12:15

159:7 162:13 166:13
101:15 102:4 102:17
train,174:6

167:7 168:6 171:15
103:15 107:13 110:3
transaction ( 5 ) 61:14

173:9 173:14 176:16
111:5 113:16 114:24
81:7 89:23 117:16

themselves123:13
115:1 115:2 115:25
136:11

theoretically,92:22
116:7 118:14 120:16
transactions ( 4 ) 61:10

theory,104:22
120:19 121:3 121:6
61:11 62:4 133:11

There’s ( 3 )22:17
121:14 121:18 122:13
transcript, ( 5 ) 1:19
22:18 172:14
122:16 123:14 124:19
35:13 54:13 66:25

thereabouts, ( 2 ) 97:9
124:20 125:2 125:23
67:4

127:18
127:15 127:25 128:3
transcription.76:2

thereafter.156:17
128:8 130:16 130:18
transfer ( 6 ) 22:6 55:11

therefore ( 28 ) 4:3 6:11
136:15 137:14 137:24
69:13 103:18 111:18

6:25 19:11 21:15 27:7
138:4 141:14 141:18
142:19

27:10 27:24 33:18
141:23 141:25 142:6
transferred ( 3 ) 21:2

35:10 46:11 48:17
143:14 144:10 146:11
30:7 101:24

57:2 58:1 59:6 60:15
147:8 147:23 149:9
transferring25:9

61:10 84:7 86:16
150:15 150:16 153:15
transfers.142:22

93:11 105:18 129:24
153:18 154:24 155:17
translate6:12

132:20 138:6 146:10
155:20 158:5 158:10
translated ( 14 ) 6:2

158:11 158:21 160:8
159:5 160:5 160:11
6:23 20:15 22:13

thing, ( 21 ) 7:18 12:13
160:12 160:12 161:1
23:19 34:4 34:6 42:25

14:17 22:12 44:22
161:20 165:15 165:18
100:16 169:21 171:2

44:24 44:24 51:13
166:22 166:24 167:2
171:6 171:22 174:23

61:24 68:8 68:16
167:7 167:15 168:21
translation ( 30 ) 6:21

79:13 86:9 118:5
169:21 170:2 170:2
9:1 20:12 22:9 23:7

131:13 137:5 145:20
170:3 172:11 172:20
24:15 24:22 34:23

146:1 146:7 149:18
173:10 175:18 175:20
35:21 36:2 47:23

174:10
176:8
47:24 48:3 69:5 79:20

thinking ( 10 ) 7:3 11:22
time-consuming137:5
92:18 92:21 95:9

12:11 12:12 55:4 60:4
times,113:9
96:12 103:2 103:4

114:25 123:24 143:3
timetable ( 15 ) 70:11
103:5 109:5 131:19

167:9
74:4 154:1 154:25
131:25 149:8 169:24

thinks ( 4 ) 6:15 8:3
155:2 155:21 155:25
171:15 172:23 174:16

164:16 165:15
156:11 158:22 159:23
translations, ( 11 )
third ( 4 ) 86:15 86:16
162:1 162:7 165:23
23:15 24:13 76:14

86:18 105:25
166:6 166:8
92:16 169:18 169:20

thirdly,37:4
timetabling? ( 3 ) 153:3
170:5 170:8 170:16

though. ( 4 ) 1:16 78:25
153:6 153:17
173:21 174:17

114:4 176:12
timing ( 5 ) 64:6 69:18
translator, ( 3 ) 22:11

thought ( 12 ) 1:8 39:25
74:13 159:2 169:7
35:24 171:1

57:10 70:23 74:8 83:9
tired75:5
translators ( 3 ) 23:10

119:1 128:11 139:21
today. ( 8 ) 74:4 74:8
34:9 103:10

163:2 164:1 173:21
77:25 89:6 89:13
travel153:10

thoughts139:25
109:18 152:1 153:20
travelling ( 3 ) 72:9

thousands67:10
together» ( 7 ) 8:13
72:10 163:10

three ( 10 ) 22:18 47:2
83:10 83:15 98:23
treat146:5

63:2 74:2 82:22 164:4
104:13 137:16 151:2
treatment.175:7

164:16 164:20 164:21
told ( 22 ) 15:6 52:8
trial ( 7 ) 93:10 153:25

175:18
53:2 54:15 57:6 92:22
168:19 170:22 173:13

three-quarters53:9
93:5 93:13 93:15
175:19 176:1

through ( 12 ) 29:12
93:16 129:12 132:11
trials157:24

29:18 42:17 73:21
134:2 134:3 134:13
trick,117:3

73:21 80:2 113:18
135:23 141:15 141:20
tried174:21

143:12 154:18 155:25
143:2 168:8 169:14
trigger30:25

163:14 167:25
176:18
triggers80:3

throughout45:17
tomorrow ( 22 ) 64:19
trilateral85:1

thumbnail81:7
70:24 74:20 126:11
tripartite ( 7 ) 83:19

Thursday ( 3 ) 94:1
136:16 152:3 152:4
84:8 84:12 84:16

154:15 161:17
152:6 152:8 152:24
86:14 89:1 89:16

tight19:15
154:4 154:17 155:19
trouble ( 2 ) 112:3

time. ( 154 ) 1:10 4:6
156:12 156:14 156:14
133:25

4:10 4:13 4:23 7:3 7:5
156:19 160:6 160:22
troubles ( 2 ) 49:25 50:1

10:11 13:5 19:4 19:11
162:12 176:18 177:2
troubling170:10

24:7 24:20 27:12

Magnum services provided by Opus2 International Ltd +44 (0)20 3008 5900

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true. ( 10 ) 20:22 44:11
116:1 120:13 131:15
93:23 93:24 96:13

77:24 78:1 86:25
132:13 139:7 139:11
108:9 108:24 109:2

92:25 122:16 123:7
139:17 145:8 165:12
109:2 109:8 109:10

144:3 150:10
understands, ( 3 ) 109:13 109:14 120:22

truly ( 2 ) 71:16 94:18
115:23 133:3 168:25
123:17 126:18 127:3

trust141:18
understood ( 3 ) 93:6
127:5 127:6 127:9

trusted ( 3 ) 27:12 28:16
93:13 159:7
128:15 129:14 133:1

145:11
undoubtedly71:6
133:2 134:5 138:25

truth ( 3 ) 35:23 114:14
unenforceable ( 2 ) 139:2

114:16
149:17 149:22
versions ( 10 ) 103:11

try ( 27 ) 11:15 16:12
unfairness176:23
112:3 115:17 117:18

54:14 57:17 65:4
unfold171:16
120:24 123:15 123:19

73:2 82:3 83:5 107:11
unfortunately, ( 7 ) 129:24 132:14 136:19

110:8 120:9 120:9
10:18 57:13 102:3
via ( 4 ) 1:9 110:18

125:11 126:23 131:24
122:13 129:6 129:17
110:18 143:14

151:2 151:5 151:7
163:17
VICTOR ( 2 ) 76:6

160:1 163:6 164:6
unknown146:3
178:11

164:13 168:18 171:6
unless ( 6 ) 5:7 10:13
videolink,1:10
171:17 172:1 176:3
61:21 66:9 91:2
viewed12:18

trying ( 19 ) 2:19 5:2
149:15
Viktoria ( 2 ) 147:21

19:6 25:21 40:9 59:2
unlimited149:9
147:22

96:21 114:25 117:21
unnecessary170:6
violated.6:16

118:1 118:7 129:11
unravel120:9
violating7:13

129:19 157:15 165:3
unrealistic165:5
VIP ( 2 ) 141:13 148:18

167:9 167:12 167:12
unreasonable157:14
Virgin26:13

171:7
unsatisfactory79:20
visit ( 3 ) 57:6 148:19

Tuesday, ( 2 ) 1:1 64:17
unseemly162:11
148:23

turn ( 4 ) 74:15 77:10
unusual ( 5 ) 29:13
visited ( 2 ) 56:19

77:16 77:17
29:15 29:17 31:11
147:20

turning ( 2 ) 5:11 160:4
40:17
Vitaly ( 2 ) 140:24

turnover91:6
unusually149:5
141:12

twin116:22
updated97:25
voice92:20

Twitter67:2
used ( 4 ) 6:22 13:19
void,149:17

type ( 2 ) 84:21 85:7
18:13 116:17
Volodina ( 5 ) 20:13

typed21:14
useful52:13
36:25 37:15 65:22

types52:13
uses ( 3 ) 40:4 40:22
163:24

41:24
volume110:4

U using ( 4 ) 31:5 41:23
volumes ( 2 ) 106:20

97:18 108:6
106:20

usual,29:19
voluntarily41:12

ultimate ( 2 ) 81:23

usually ( 7 ) 81:18 81:22
Vyborg ( 16 ) 87:6 95:24

125:17
87:24 108:3 143:18
95:24 102:17 104:13

ultimately, ( 2 ) 146:11
148:20 148:23
105:18 105:20 105:24

173:16
utterly169:15
105:25 106:1 106:2

unconnected45:6
106:17 107:10 108:1

undercapitalisation17:16
V 126:15 126:19

underlining ( 4 ) 22:17

22:18 22:19 22:20
W

undermine131:21
valuation ( 18 ) 10:6

underpinning135:24
11:16 12:21 13:1 14:2

understand ( 75 ) 4:23
14:3 14:5 14:6 14:25
wait ( 2 ) 64:18 78:3

7:7 7:9 7:10 7:12
15:3 15:10 15:12
waited93:15

10:4 15:6 15:7 15:14
15:18 15:22 16:1
waiting93:13

16:3 16:25 23:25 24:9
16:20 16:23 19:20
walking ( 2 ) 66:1 160:4

32:8 40:10 42:4 45:16
valuations. ( 9 ) 9:23
wanting22:10

47:10 57:5 67:23 68:3
10:12 15:4 15:7 16:6
wants ( 5 ) 10:22 15:15

68:4 68:11 68:13
16:9 19:4 20:3 32:8
66:21 136:5 151:6

68:20 71:10 75:6
value ( 8 ) 11:23 11:25
warned147:23

75:17 79:15 79:17
12:12 19:12 32:9
warning ( 2 ) 70:13

80:13 80:18 83:4 83:6
32:22 35:11 36:15
71:11

83:14 84:15 96:21
valued11:18
wary164:9

97:3 102:10 103:7
valuer? ( 3 ) 9:25 13:20
wasn’t ( 15 )16:9 20:4

105:6 105:7 105:23
18:23
44:16 47:8 75:19

106:2 106:3 106:8
valuer’s18:9
116:14 122:4 122:23

106:13 106:22 113:22 valuers; ( 5 ) 13:5 13:15
128:23 144:3 144:3

118:23 120:10 123:18
62:16 62:18 63:15
146:21 146:22 151:16

124:5 129:11 132:9
various ( 14 ) 15:11
165:1

139:5 139:18 140:20
48:12 49:12 49:13
waste ( 2 ) 73:23 146:11

141:1 146:8 154:23
57:6 80:25 87:25
wasted.168:22

157:13 157:16 160:22
96:23 96:24 100:12
wasting94:3

161:3 164:7 164:8
104:1 130:15 133:11
water ( 2 ) 76:21 76:22

166:25 167:4 168:2
157:18
waters.125:14

168:7 168:23 170:12
VAT, ( 3 ) 30:15 32:20
way, ( 42 ) 6:4 7:11

172:1 173:22
47:12
35:16 49:6 49:22

understandable, ( 3 ) version ( 47 ) 4:15 5:18
51:10 52:14 53:23

123:9 170:3 170:23
17:24 20:9 20:20 26:3
68:6 71:1 74:11 79:3

understandably, ( 2 ) 26:9 29:3 29:3 36:22
79:15 79:17 81:19

91:20 157:18
38:24 38:25 42:21
87:15 97:21 99:6

understanding ( 15 ) 47:22 69:7 78:12
99:10 100:1 106:14

16:16 45:8 81:24
78:14 79:22 79:25
128:10 129:1 132:18

94:11 96:22 115:24
93:19 93:20 93:21
133:22 134:11 136:8

136:12 140:24 141:21
wish ( 8 ) 12:19 18:15
worried159:8
(10.00 ( 2 ) 1:2 160:9

147:20 147:24 149:3
67:20 75:3 132:4
worry, ( 5 ) 10:17 104:8
10.30 ( 6 ) 72:23 160:18
4
159:10 160:11 161:10
153:15 162:10 176:3
143:2 150:1 176:2
162:17 176:15 177:2

168:5 170:19 172:16
wished11:10
worrying136:11
177:4

4.15,151:24

173:8 174:4 176:7
wishes149:20
worse66:7
100. ( 3 ) 13:23 52:1

ways. ( 2 ) 173:2 175:22
withdrawing61:25
worthwhile.75:5
137:17
(4.50177:3

we’re171:18
withdrawn,21:14
wouldn’t ( 22 )18:18
102. ( 2 ) 110:7 110:8
4,80036:13

we’ve ( 5 )6:7 93:3
withdrew) ( 2 ) 66:19
18:25 28:7 28:16
(11.4553:16
49-year37:6

162:3 170:25 170:25
153:23
28:17 33:2 40:23
(11.5553:18
4th,163:5

wearing ( 2 ) 71:10
witness, ( 75 ) 4:24 5:4
47:18 51:8 60:4 60:9
12.50, ( 3 ) 160:25

131:17
5:6 5:9 13:10 17:2
72:4 96:19 123:9
162:13 162:15
5
website,48:6
24:7 41:1 41:2 41:9
139:12 148:14 157:14
1279.119:11

Wednesday, ( 5 ) 64:13
42:10 65:17 66:19
160:10 165:1 166:6
13.317:14
5.2:31:4

64:19 64:23 66:1
71:8 74:13 74:19
166:7 169:25
13069:14

177:5
74:25 75:7 76:10
write ( 6 ) 37:16 82:25
131.77:3

Wednesdays64:13
77:4 77:7 77:14 77:19
84:19 86:17 108:4
150117:14

week, ( 34 ) 64:16 97:5 77:23 78:1 86:21 108:5 …………………………………153178:17 6
97:8 97:10 110:14
106:20 114:1 114:6
writing ( 3 ) 9:13 39:10
160127:10
64A, ( 3 ) 54:18 55:4

120:14 120:23 120:23
114:10 115:8 115:10
130:15
16th ( 2 ) 41:1 41:2

55:19

127:22 156:1 156:21
115:16 115:21 116:10
written114:20
17/06/2009.103:16

157:1 157:9 158:17
117:9 117:19 118:8
wrong. ( 16 ) 3:15 6:21
170 ( 8 ) 104:12 106:16
7
158:23 158:23 158:24
118:11 124:25 125:6
15:5 35:7 58:10 64:4
112:21 113:9 113:10

159:8 159:9 159:11
125:12 125:16 130:16
65:24 90:2 99:11
113:11 131:3 136:10

161:16 161:18 161:18
141:9 141:10 145:8
102:23 116:18 129:23
173 ( 2 ) 41:2 41:17
73,39736:10

162:2 163:14 163:15
145:9 146:2 146:2
135:20 137:18 139:5
178 ( 5 ) 54:20 55:5 55:8

163:16 163:18 163:20
146:9 146:25 149:16
166:19
55:16 55:19
8
164:3 164:13 165:12
150:5 150:12 150:19
wrongdoers168:4
19th ( 2 ) 13:10 41:9

165:13 176:22
150:21 152:14 153:4
wrongly.10:17

week’s123:17
153:16 153:23 154:9
2 8226 ( 2 ) 36:11 36:13

weekends,156:9
155:1 156:3 156:5
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weekly ( 2 ) 97:24 128:4
159:5 163:22 163:23
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weeks. ( 7 ) 97:10
163:25 165:1 167:6

Yashkina, ( 8 ) 34:1

156:10 162:2 162:4
167:9 167:14 167:20
156:18 162:21

162:4 162:5 166:5
170:1
65:20 147:21 156:23
(2.0592:8
9.30163:5

weight ( 2 ) 67:13
witness’s ( 6 )118:20
161:6 163:4 163:6
2.1.130:6

150:18
118:25 125:15 131:19
163:13
2.15,162:22

weighty148:25
131:25 151:20
year ( 5 ) 46:11 47:3
20,00032:20

weren’t ( 2 )83:11
witnesses. ( 33 ) 4:25
47:4 52:3 62:3
20055:15

175:15
11:1 11:5 64:6 67:24
years ( 16 ) 12:16 30:4
2003. ( 4 ) 46:11 47:1

Western ( 8 ) 1:21 2:6
70:19 71:20 74:10
32:3 32:19 32:20
47:10 48:12

14:15 26:11 29:6 57:7
92:19 150:7 152:10
32:25 37:8 37:12 63:1
2004. ( 4 ) 46:1 46:2

79:6 103:19
155:21 155:24 155:25
63:2 67:9 74:2 87:11
46:7 46:16

what’s ( 6 )15:5 35:3
156:9 156:21 156:24
90:1 167:3 175:12
2007 ( 3 ) 49:12 49:17

60:17 116:8 122:10
157:5 158:5 158:14
yesterday. ( 24 ) 1:22 50:10

124:19
158:14 158:15 158:18
2:16 2:22 3:8 3:9 3:16
2008 ( 8 ) 3:23 36:5 36:8

whatever ( 19 ) 2:18 3:5
158:22 158:25 163:18
8:22 9:18 10:8 15:7
50:16 51:18 55:6 55:8

11:24 16:5 37:7 37:14
164:4 164:5 166:5
16:5 37:24 43:12
78:16

37:16 37:21 38:12
167:23 168:16 169:1
43:16 44:5 44:12
2008/2009 ( 2 ) 46:2

39:4 42:13 50:20
169:9
44:14 44:15 54:14
56:21

52:19 59:9 60:7 64:13
won’t ( 14 )24:15 45:13
55:1 67:4 68:22 74:4
2009, ( 19 ) 2:1 2:23

74:11 95:18 120:20
68:17 74:15 75:18
93:8
3:22 5:23 27:15 30:11

whatsoever48:21
96:11 108:18 152:10
yesterday’s ( 2 )2:24
55:6 55:12 57:8 98:3

whenever, ( 6 ) 2:1
153:9 158:22 167:4
66:25
101:15 102:5 103:1

27:17 80:15 82:21
167:14 167:16 175:23
you’ve ( 2 )16:4 131:2
108:10 109:1 126:15

96:23 160:15
wonder, ( 9 ) 1:7 35:12
young ( 2 ) 144:15
127:18 128:20 129:12

whereby ( 3 ) 84:25
43:23 63:22 65:1
148:25
2010, ( 3 ) 45:5 107:11

98:23 141:22
65:16 69:23 150:16
yours,139:2
122:22

whichever ( 2 ) 117:4
159:8
yourself, ( 2 ) 58:23
2011101:19

133:22
wondering ( 3 ) 47:25
72:18
2013104:10

Whilst ( 5 ) 94:8 94:14
124:10 146:8
2015.77:12

153:14 154:21 162:24
wording ( 2 ) 50:23 61:1
Z 2016 ( 2 ) 1:1 177:5

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work ( 34 ) 16:13 34:11
24th123:20

whoever ( 9 ) 6:1 33:6
45:17 57:18 59:2
zero3:13
26th, ( 2 ) 64:23 65:25

33:9 84:20 133:3
83:10 91:21 94:7
274,36:13

134:2 134:20 135:12
95:4 95:18 95:21 96:4
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138:19
98:3 99:1 99:25 100:2

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101:20 102:8 102:9
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118:18 130:9 131:21
102:12 102:14 110:20
0.1, ( 2 ) 26:2 127:5

167:18
112:11 121:16 123:4

0.2.127:7
3.130:14

wholly146:3
123:5 134:17 137:17

0.3102:24
3.15,163:2

whom ( 10 ) 15:4 29:15
155:24 157:19 161:14

0.4,96:11
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29:17 46:6 83:15
163:9 164:13 174:1
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117:17 135:6 136:9
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152:5 157:19
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widespread148:7
46:3 46:7 46:12 46:14

30055:15

wife, ( 5 ) 92:16 93:25
46:17 46:19 97:19
1.00. ( 4 ) 160:16 160:19

31st,123:20

94:12 140:22 145:4
100:3 100:19 102:3

160:19 163:7
3500-081279,119:6

wife’s72:9
102:17 121:13 130:8
1,00012:16

win?171:20
141:11 173:6
(1.0492:6

wise,70:8
works? ( 3 ) 99:9
1,286,805,92036:16

102:15 105:23
1.3,30:3