Day 6

Bank St Petersburg v Vitaly Arkhangelsky [Master]

Day 6

Bank St Petersburg v Vitaly Day 6
Arkhangelsky [Master]

1 :1 Thursday, 4 February 2016
2 (11.00 am)
3 Housekeeping
4 MR JUSTICE HILDYARD: Yes, good morning.

5 MR LORD: Good morning, your Lordship.

6 MR JUSTICE HILDYARD: Good morning, Mr and Mrs Arkhangelsky.

7 MR ARKHANGELSKY: Good morning.

8 MR LORD: Your Lordship knows that this is the hearing

9 scheduled from yesterday to deal with a number of

10 matters outside the reception of the witness evidence,

11 and we filed an aide-memoire, which I trust

12 your Lordship has, to serve as something of an agenda

13 for today.

14 MR JUSTICE HILDYARD: Yes.

15 MR LORD: Your Lordship should also have received a bundle

16 of papers relating to previous rulings on freezing

17 injunctions and a life policy surrender, which may or

18 may not need to be — which bundle may be studied today.

19 Your Lordship, I think, invited us to try to collate the

20 relevant documents that might pertain to that particular

21 inquiry, or line of inquiry.

22 MR JUSTICE HILDYARD: I flicked through my own judgment of

23 5 March and I had a quick look at the freezing order,

24 but beyond that, I haven’t really read these documents.

25 MR LORD: I am not sure your Lordship needs to. Just, if

2 :1 I could — I know it is probably going out of sequence,
2 but to just sort of cut to the chase a bit, there was

3 an issue about the surrender, I think of a Barclays life

4 policy.

5 MR JUSTICE HILDYARD: Yes.

6 MR LORD: Not a Société Générale life policy, with which

7 I think we are now concerned. Your Lordship seems to

8 have ruled — it is behind divider 7, I think it is

9 probably only a couple of paragraphs —

10 MR JUSTICE HILDYARD: I mean, there was an issue as to

11 whether this was being used in preference to other

12 assets and I ruled that there wasn’t enough evidence to

13 suggest it was, and I ruled it probably wasn’t available

14 in any event by way of enforcement in France.

15 MR LORD: I think also perhaps relevantly, there was

16 a question of whether the surrender of the life policy

17 was a breach of the freezing injunction as opposed to

18 any potential deployment of the proceeds thereby

19 generated, and your Lordship, I think, held that you

20 didn’t need to decide that question.

21 MR JUSTICE HILDYARD: No. That was the third matter.

22 I think that was right at the end.

23 MR LORD: It is in paragraph 43, my Lord.

24 I only go to that, my Lord, just to set the scene

25 a bit in terms of what may look a slightly more

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

3 :1 formidable bundle of paper than perhaps is actually
2 going to be necessary for today.

3 Your Lordship should also have had an affidavit from

4 Mr and Mrs Arkhangelsky’s French lawyer —

5 MR JUSTICE HILDYARD: Yes.

6 MR LORD: — ms Bidault, and certain points obviously arise.

7 I don’t know how your Lordship wishes to proceed. Would

8 it help if I very briefly set out what our position is

9 on this?

10 MR JUSTICE HILDYARD: Yes. Mr and Mrs Arkhangelsky,

11 I received, as I walked down the stairs, an e-mail from

12 Mr Arkhangelsky expressing concern about the sound

13 quality and the delay, and asking, as I understand it,

14 for headphones to be provided by way of ameliorating at

15 least the first of those concerns. Can you hear all

16 right, each of you?

17 MR ARKHANGELSKY: Yes, I can hear you perfectly today.

18 MR JUSTICE HILDYARD: That’s good.

19 MR ARKHANGELSKY: And my wife, I assume, requires

20 translation.

21 MR JUSTICE HILDYARD: I assume you have notified that you

22 wish to hear the feed in Russian; is that right?

23 MR ARKHANGELSKY: Should I translate to her, or …?

24 MR JUSTICE HILDYARD: It is not possible for you each to

25 have a different language, but you are able to, as

4 :1 I understand it, tell us whether you want the feed in
2 English or whether you wish to hear the feed in Russian.

3 In any event, the real time written version will be in

4 English.

5 MR ARKHANGELSKY: I would probably suggest to do it in

6 Russian and then my wife can at least follow what is

7 going on.

8 MR JUSTICE HILDYARD: How difficult is that, Mr Lord? Would

9 you like your technical guru to explain?

10 MR LORD: My Lord, I had better defer, I think.

11 MR BIRT: Well, in the absence of him I will try again. The

12 position is as was explained yesterday to your Lordship.

13 I think we were not waiting for your Lordship but the

14 idea of the mobile phone link was subject to

15 your Lordship having a think about whether you were

16 comfortable with the proceedings being sent down

17 a mobile phone. In terms of the whole thing being in

18 Russian, that can be done, I think, at the flick of

19 a switch, or something approximate to it. I just note

20 that the consequence of the feed being completely in

21 Russian is likely to be that when Mr Arkhangelsky is

22 speaking English, he will be hearing the Russian back as

23 he is talking, because it will be giving the Russian

24 feed from the court.

25 So that can be done at the flick of a switch. The

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Arkhangelsky [Master]

5 :1 second alternative as outlined to your Lordship
2 yesterday is the mobile phone link, which I think

3 your Lordship was slightly thinking — so the

4 consequence would be of having it all in Russian for

5 them, that Mr Arkhangelsky either has to bear with the

6 TV speaking to him in Russian while he is speaking in

7 English, or Mrs Arkhangelskaya not being able to have

8 Mr Arkhangelsky in translation.

9 MR JUSTICE HILDYARD: Yes. Well, I haven’t reached a view

10 on the mobile yet because I want to try and measure

11 whether it is really necessary, according to what you

12 envisage will be the likely future attendance of

13 Mrs Arkhangelskaya, which is really the only point in

14 having it. So that’s the first thing.

15 The second thing is I leave it to you as to which of

16 the two options which have been outlined you would

17 presently prefer for the purposes of today. The only

18 point I would make is, although I’m happy to see

19 Mrs Arkhangelskaya, I wonder whether the nature of

20 the application is such that it might be better to have

21 the feed in English. But, as I say, that is ultimately

22 a matter for your preference.

23 MR ARKHANGELSKY: I would suggest probably, my Lord,

24 language Russian and then, to avoid difficulty for me,

25 I would speak in Russian also, so then it could be

6 :1 comfortable for everybody.
2 MR JUSTICE HILDYARD: Very well then. We will be the people

3 with the headphones, and that is perfectly fine, though

4 the relevant direction has to be given for the switch to

5 be flicked.

6 MR BIRT: Well, I hope that now Mr and Mrs Arkhangelsky are

7 hearing us in Russian, my Lord.

8 MR JUSTICE HILDYARD: Yes, can you confirm that the feed is

9 coming through to you in Russian?

10 MRS ARKHANGELSKAYA: I can hear very well.

11 MR ARKHANGELSKY: Thank you very much.

12 MR JUSTICE HILDYARD: Mr and Mrs Arkhangelsky, I will invite

13 Mr Lord, given that you have set out the circumstances

14 in which you seek urgently some clarification of

15 the order in order to enable Société Générale to assist

16 you, I will invite Mr Lord, partly because he is in

17 front of me, and partly because it is his opposition,

18 really, to explain the basis on which he opposes, and

19 I will then invite you to attack what he says in

20 a measured way.

21 MR LORD: Just for completeness, so your Lordship has the

22 papers for today before we start, there is an e-mail

23 from Mr Stroilov which relates to the aide-memoire.

24 MR JUSTICE HILDYARD: Yes.

25 MR LORD: I don’t think he makes any point on the first

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Arkhangelsky [Master]

7 :1 item, with which we are currently engaged.
2 MR JUSTICE HILDYARD: No.

3 MR LORD: But for completeness I wanted to draw that to

4 your Lordship’s attention.

5 The other documents are some articles which were

6 posted yesterday, I think on the Co France website,

7 which I will, I think potentially have to come to, but

8 I think it is worth your Lordship noting that there is

9 further promulgation of what — the business happening

10 in court on the Co France website, and it is worth

11 noting that the footer to this internet site seems to

12 make a reference to Pavel-Stroilov, and the final

13 contact, Natalya Khmelik, we understand to be

14 Mr Stroilov’s mother.

15 So in terms of the questions of communication and

16 the closeness of all that in this case, and any points

17 about breakdowns in communication, it is, with respect,

18 relevant for your Lordship to see that certainly on the

19 face of yesterday’s posting, Mr Stroilov and his mother

20 seem to be performing some sort of ongoing role at

21 Co France, supporting these defendants’ PR endeavours.

22 If I could go, please, to the first. Can

23 your Lordship see the footer, that has

24 «Soviet.co-pavel/stroilov». Then at the end:

25 «Press service organised for the lighting of

8 :1 the trial, contact Natalya Khmelik.»
2 MR JUSTICE HILDYARD: Yes.

3 MR LORD: My Lord, on the first point, the question of

4 the life insurance policy, your Lordship will have in

5 mind the freezing injunction, and I am sure

6 your Lordship has seen that, which was made — which

7 prohibits the respondents from spending — sorry, does

8 not prevent — there is a freezing injunction and there

9 is an exception for spending £2,000 a week on living

10 expenses and also a reasonable sum on legal advice and

11 representation, but before spending any money, the

12 respondent must tell the applicant’s legal

13 representatives where the money is to come from.

14 MR JUSTICE HILDYARD: That applies to both limbs, does it?

15 MR LORD: It isn’t actually clear, my Lord, I think it is

16 right to say. I think your Lordship rightly observes it

17 is not clear. I must say, I had construed it as

18 applying to the second limb, I have to say that’s how

19 I had read it as —

20 MR JUSTICE HILDYARD: The reasonable sum, in other words?

21 MR LORD: Yes, and I had construed the notification point,

22 certainly to apply to the, if you like, uncapped legal

23 advice spend rather than —

24 MR JUSTICE HILDYARD: Yes, that’s what it would usually be.

25 MR LORD: That’s how I read it. I hadn’t read it that they

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Arkhangelsky [Master]

9 :1 would have to notify living expenses. I mean, I may be
2 wrong about that.

3 Obviously I took your Lordship to your Lordship’s

4 ruling on the life policy surrender, the Barclays one.

5 We have the affidavit this morning from

6 Mr Arkhangelsky’s French lawyer. I wonder if I could

7 just take your Lordship through it and highlight one or

8 two points, but before I do that, can I just, if you

9 like, cut to the chase and say what my position is at

10 the moment?

11 MR JUSTICE HILDYARD: Yes.

12 MR LORD: There are a host of concerns which spring from

13 recent events, from the events of the last day, and from

14 this affidavit by a French lawyer on behalf of

15 the Arkhangelskys. In my submission it is unlikely that

16 the court is going to be able to, satisfactorily and

17 fairly to all parties, resolve those queries today.

18 They are serious enough, or certainly potentially

19 serious enough, to be properly and thoroughly

20 investigated before any further steps or directions or

21 rulings are forthcoming and, therefore, it may be

22 appropriate to consider giving various directions so

23 that this matter can be swiftly resolved but thoroughly

24 resolved and not when my clients have had very little

25 time to absorb this.

10 :1 The second aspect is the urgency feature, which is
2 to make sure that money is available to ensure that what

3 needs to be done in this litigation can be done so the

4 trial maintains its current excellent progress. Those

5 are two different aspects.

6 It would certainly be my position that those two can

7 be reconciled and that the court can certainly today

8 make various directions, or make various orders by

9 consent in order to be able to release certain monies,

10 to ensure that various expenses are defrayed, and then,

11 if you like, circle back to deal at a later date with

12 the points that arise, such as the question of

13 the assets that the respondents have, the question of —

14 and, consequent upon that, issues to do with the

15 freezing injunction.

16 My Lord, there are obvious questions here. There

17 appear to be some quite significant assets available

18 which, on the face of it, could be used, for example, to

19 pay for Mr Steadman, just to take a very simple example,

20 and an awful lot has been made of the fairness of this

21 trial, and Article 6 has been regularly threatened here

22 and if, in fact, there is the sort of money available

23 that this affidavit appears, I think, to reveal, then

24 I think the court really does need, in fairness, to get

25 to the bottom of that.

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Arkhangelsky [Master]

11 :1 There are issues about the freezing injunction, and
2 I can develop our concerns, my Lord, I’m very happy to

3 do that, and I will do that, but I want, if you like, to

4 show your Lordship the bottom line here because I don’t

5 want to waste time with your Lordship if your Lordship

6 thinks that would be the right approach.

7 I am very happy to explain what our concerns are

8 arising from this affidavit, and then, if you like, to

9 deal with a possible solution, a sort of pro tem

10 solution to make sure that we keep the show on the road,

11 as it were; does that make sense, my Lord?

12 MR JUSTICE HILDYARD: That does make sense.

13 I mean, I have only grappled with this very shortly,

14 because I had an earlier meeting, however, Mr and

15 Mrs Arkhangelsky, my understanding is, and certainly

16 this is what is submitted to me by Mr Lord, that this

17 life policy with Société Générale in the amount of just

18 over €366,000 is a different policy than the policy

19 which I addressed in March 2014, which I understand to

20 have been issued through Barclays. That’s the first

21 point. Am I right in thinking that?

22 MR ARKHANGELSKY: Yes, you are absolutely correct, my Lord.

23 The money we have received from the Barclay’s policy

24 were spent by us on our living expenses in accordance to

25 your freezing order.

12 :1 MR JUSTICE HILDYARD: Yes. This second policy, was it in
2 existence in March 2014?

3 MR ARKHANGELSKY: Yes, certainly, it was in existence, and

4 in our affidavit of disclosure with regard to

5 the freezing order, this information is contained in

6 Mrs Arkhangelskaya’s affidavit.

7 MR JUSTICE HILDYARD: This, I understand from the affidavit

8 that you provided — and thank you, and I am sorry that

9 it rather blighted your evening and night — is one of

10 the three life policies disclosed in 2012; is that

11 right?

12 MR ARKHANGELSKY: Yes, absolutely correct.

13 MR JUSTICE HILDYARD: And you say that these life policies,

14 including this one, were funded out of monies which you

15 had in France as the most tax-efficient saving vehicle;

16 is that right?

17 MR ARKHANGELSKY: This is absolutely right.

18 MR JUSTICE HILDYARD: And have the monies, or any of

19 the monies, from the Société Générale policy previously

20 been remitted without difficulty through your accounts

21 at Société Générale?

22 MRS ARKHANGELSKAYA: No, this is not the case.

23 MR ARKHANGELSKY: Since the policy formally belongs to my

24 spouse and she communicates with the banks and with all

25 the matters, I would like her to comment upon this

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

13 :1 matter.
2 MRS ARKHANGELSKAYA: The largest policy is the policy that

3 we are discussing here today, the Société Générale, in

4 France, policy. Up to this day we did not draw money

5 from there. We had the money which we have disclosed in

6 2012 to the court, the money in our current account, and

7 as of today all that money has been spent, in

8 accordance — within the extent permitted by the court.

9 Therefore we ask my Lordship to give us the

10 opportunity, also within your court order, for us to use

11 €75,000 for our living expenses that are clearly stated

12 by ourselves and described in today’s document sent to

13 the court by Nadejda Bidault, our lawyer. I can

14 reiterate these expenses, exactly what we are asking to

15 spend 75,000 for. It will only be spent in accordance

16 to what was told us, so €2,000 per week. The first most

17 important expense is our apartment. As I have mentioned

18 in our affidavit twice, we live in an apartment that is

19 quite expensive for our today’s income, however, we

20 cannot sell it and buy a cheaper apartment because we

21 have the freezing order. However, we are obligated to

22 pay to the French State the tax on this apartment and

23 the rent for the apartment, and that amount is €25,000

24 per year. That is the first point.

25 Secondly, what we need the money for out of the

14 :1 €75,000, this is our trip to Paris in order to take part
2 in the court hearing for myself, my husband and four

3 witnesses: Grigory Pasko, Mikhail Nazarov, Ludmilla

4 Simonova, François Ameli, and Sergei Guriev. These

5 expenses would be around 17,000, and in today’s

6 documents we have disclosed this amount of 17,000 in

7 a bit more detail — sorry, 15,000, including the cost

8 of visas, air tickets, minimum living expenses and

9 transport expenses, something very modest, very little.

10 MR ARKHANGELSKY: And I would like to draw the court’s

11 attention — my Lord’s attention to the printout of

12 expenses that we have sent. We have not received any

13 reply and we are completely at a loss whether we can

14 spend this money to organise the witnesses’ visit.

15 MRS ARKHANGELSKAYA: And also a small but important expense

16 for our family that has to be done within this amount of

17 money because now we have no opportunity to work,

18 because my husband is taking part in the court hearing

19 and I am involved with the children more, our office of

20 Co France is closed and, therefore, we have to pay the

21 minimum lease payment for the office, and mandatory tax

22 to the French State. That’s about 4,000 per month for

23 the next four months.

24 MR ARKHANGELSKY: I also would like to draw your attention,

25 my Lord, because we are taking part in the proceedings

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

15 :1 currently, currently our business is completely
2 undermined. We lost all the clients we had and the

3 chances to reinstate it within the next several years

4 are very slim. Therefore, I would like to come back to

5 the very strange commentary of Mr Lord, in my opinion,

6 that we have excessive means for living, and this life

7 insurance policy, from the very start, from the moment

8 of its acquisition in France and receiving the money in

9 France was considered by us as a pension fund, for my

10 wife and for our children.

11 You know that there were several attempts on behalf

12 of the Bank and personally Mr Savelyev, there were

13 several threats against me and there was an attempt on

14 my life quite recently, so this money is only the

15 opportunity for my family, with regard to myself, to

16 survive a year or two in the form that we are currently

17 living in. And, as of today, I calculate my risk and

18 risk to my life and health as maximum. The current

19 London Litvinenko court hearing single-handedly

20 elucidated how risky my position is. I would like you

21 to consider that as well because this is extremely

22 important for myself and my family taking part in this

23 hearing against the monsters that are prepared not to

24 stop at anything in order to punish me.

25 MRS ARKHANGELSKAYA: I would ask your Lordship to understand

16 :1 the position that we find ourselves in. We are not
2 fabulously rich, as Mr Lord has just mentioned: the

3 75,000 is a lot of money for us. All the expenses, all

4 the breakdown of expenses have been provided and the

5 main expense will be our trip to Paris because my

6 husband and myself will have to incur certain costs.

7 They may not be extremely high but, nevertheless, we

8 have provided your Lordship with a breakdown of

9 the 75,000 for the next several months, and we would be

10 extremely grateful if your Lordship grant us that

11 possibility.

12 Should your Lordship require us to provide

13 a detailed breakdown, down to the last penny, we are

14 happy to provide that, but we will never be spending

15 more than the limit set by your Lordship, and that is

16 £2,000 per week.

17 MR JUSTICE HILDYARD: Can I just clarify one thing which

18 I am sure I should know, but has the Société Générale

19 life policy already been realised? Is the 366,000 the

20 net proceeds after realising its value?

21 MRS ARKHANGELSKAYA: No, my Lord, we would need to pay the

22 French tax.

23 MR ARKHANGELSKY: We are looking at about €40,000.

24 MR JUSTICE HILDYARD: Of tax? So it will be net, about

25 €325,000, will it?

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Arkhangelsky [Master]

17 :1 MR ARKHANGELSKY: Approximately, yes, my Lord.
2 MR JUSTICE HILDYARD: But just for clarity, you have sent

3 the instructions, and they have been fulfilled, for the

4 realisation of the life policy and its conversion into

5 cash; is that right?

6 MR ARKHANGELSKY: No, my Lord. My wife — on 12 January, my

7 wife went to the bank office as Ms Bidault has

8 mentioned, and she draw up an instruction to realise out

9 of the total amount of the policy, the realisation of

10 75,000, not to realise it completely, but only to draw

11 down 75,000 out of the total amount of the policy, and

12 that amount, after the realisation by Société Générale,

13 the understanding was that it would be transferred to my

14 wife’s checking account with Société Générale.

15 MRS ARKHANGELSKAYA: But at this point in time it is not

16 possible because, as I was explained in the bank, we

17 cannot dispose of the €366,000, ie the life insurance

18 policy, because this amount has been totally, fully

19 blocked on the basis of the English court’s order.

20 MR ARKHANGELSKY: Also, as of 12 January, no one told us

21 that that amount had been blocked, and the bank employee

22 told us that everything was fine and within the next two

23 to three weeks, depending on the realisation, the money

24 was absolutely going to be remitted to that account and

25 there were no encumbrances, and we did that together

18 :1 with my wife, we went to the bank office together with
2 my wife and we signed off on all the necessary documents

3 together.

4 MR JUSTICE HILDYARD: Right. I think I have the picture

5 now. I am sure I will have to clarify various points of

6 detail, but the overall picture seems to be relatively

7 clear, and I think I must ask Mr Lord to explain

8 a little bit more about the basis for their objection,

9 as I understand it to be, for the use of this money up

10 to 75,000 for the purposes which you have indicated.

11 MR LORD: Sorry, my Lord, I didn’t put it in those terms.

12 I said we have concerns about this event, and I’m going

13 to elaborate upon those, and I made it plain that we are

14 anxious not to, in any way, do anything to impair the

15 trial here.

16 So, for example, we were asked earlier this week

17 whether €15,000 could be paid to cover witness expenses

18 in Paris, and we said yes, but subject to having

19 a reasonable breakdown. The breakdown came an hour ago,

20 so when complaint is made to your Lordship by

21 Mr Arkhangelsky 10 minutes ago that we have not got back

22 to him on the breakdown, that is a thoroughly unfair and

23 misleading submission to make.

24 My Lord, I’m sorry to have to make a few prefatory

25 remarks, but yesterday the Bank of St Petersburg was

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

19 :1 accused of taking recent steps to try to block and
2 frustrate the withdrawal of monies so as to somehow

3 derail the trial. That’s a very, very serious point.

4 MR ARKHANGELSKY: My Lord, our position has not changed.

5 MR LORD: That is a very serious allegation and one that

6 should not be made, it should not have been made, and

7 I am going to take your Lordship to a number of other

8 statements that have been made by the respondents which

9 also appear to be untruthful, and relevantly false.

10 MR JUSTICE HILDYARD: Yes. I must, of course, listen and

11 take account of those points, but in broad terms, my

12 concern is to see not only that the travel and dwelling

13 expenses in Paris of the Arkhangelskys and their

14 witnesses within the amount — I think it is uncertain

15 whether it is 17,000 or 15,000 — I think

16 the correspondence related to 15,000 — not only that,

17 but their sustenance, if I can put it that way,

18 including the amounts due for their apartment and, no

19 doubt, for ordinary living expenses, is somehow met.

20 So I am looking at paragraph 12, which contains the

21 obligatory payments. In principle, and subject to

22 clarifying other issues as to what I was told yesterday,

23 are those amounts objected to?

24 MR LORD: Well, my Lord, in stages, the income tax —

25 MR JUSTICE HILDYARD: Yes.

20 :1 MR LORD: — that needs to be explained, because that looks
2 like it is tax on income. So your Lordship understands,

3 the idea of an exemption from a freezing injunction is

4 that you pay your bills because you don’t have enough

5 money coming in elsewhere, and you can pay for your

6 lawyers to run the litigation. That’s what this

7 exception is about.

8 When you have Co France here, a real business, and

9 you have income tax being paid, that begs a number of

10 questions.

11 Now, it is a relatively small amount of money and

12 I don’t want to put the respondents in difficulty in

13 the short term, but when does that have to be paid by?

14 Does it have to be paid by? It doesn’t have to be paid

15 in the next few days, because, in my respectful

16 submission, before the court allows frozen monies to be

17 disbursed, it should be reasonably satisfied that that’s

18 an appropriate disbursal. So income tax, potentially,

19 yes, it is small, but it begs a lot of questions.

20 Secondly, the apartment. Again, on the face of it,

21 that looks as if that probably is going to have to be

22 paid. Travel expenses to Paris, yes, of course, we’ve

23 agreed to that.

24 But then Co France. We would say no. Why is money

25 being paid out of a frozen bank account to a company

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

21 :1 that Mr Arkhangelsky runs. That’s the wrong direction
2 of travel here. There is no explanation for that. That

3 is not a living expense or a reasonable legal expense.

4 That appears to be the ebbing away, or the seeping away,

5 of frozen monies.

6 So, my Lord, in principle, and subject —

7 MR JUSTICE HILDYARD: Well, I think they would say that it’s

8 a necessary payment to preserve some prospect for the

9 future of them being able to sustain themselves now that

10 their capital assets, represented by these policies, are

11 being eroded.

12 MR LORD: But it says «rental payment and taxes for

13 Co France».

14 MR JUSTICE HILDYARD: Yes, but Co France is the means by

15 which they hope to make their living. They have offices

16 for Co France, as I understand it. Co France, I am

17 told, is not bringing in anything at the moment because

18 Mr Arkhangelsky is engaged in this case, but the rental

19 due on its office rolls on remorselessly.

20 MR LORD: My Lord, there is no evidence of any of that, so

21 it can’t be taken on trust. It absolutely can’t.

22 Now, if we agree to let these monies out, it can

23 only be on condition that we have a full and frank

24 discussion by the respondents of their asset position,

25 their income position and matters such as Co France.

22 :1 MR JUSTICE HILDYARD: I agree with that in principle, yes,
2 but I don’t think it is impermissible for me to look at

3 the proportionality of this. The fact is that, compared

4 to the amounts which you are seeking to recover if you

5 succeed in both aspects of the matter — that’s to say

6 in the defence and in the counterclaim — dwarfed by

7 such a proportion that I must expect that you have

8 other, non-financial reasons for pursuing this matter,

9 including to clear your people’s names, and that sort of

10 thing, which you have acknowledged.

11 There comes a time when excessive detail costs more,

12 really, to me, in terms of the court administration, and

13 to you, in terms of your wasted time, than the amount at

14 stake, and it’s simply not worth the candle.

15 At the moment I am just wondering why you are so

16 zealous in this regard. I want my orders obeyed, just

17 as any judge wants them, but I am just wondering what’s

18 going on here? Why are we being quite so …

19 MR LORD: I’m sorry, my Lord, taking a step back, I’m sorry,

20 my instructing solicitors, associates and trainees are

21 working around the clock at the moment — it is

22 important — it is relevant — your Lordship says why,

23 why does this matter, what lies behind it.

24 MR JUSTICE HILDYARD: It obviously matters that the monies

25 are not expended otherwise than on living expenses, and

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23 :1 I need to make sure — or legal costs — and I need to
2 make sure that there is sufficient evidence as to

3 satisfy me in general terms, but I think that you are

4 looking for a level of particularity and detail which

5 may not be worth the candle and may take such time that

6 its object, which is to enable them to meet their bills

7 in the near future, will be defeated anyway.

8 MR LORD: My Lord, the starting point is whether this gives

9 cause for concern. Your Lordship starts from the

10 assumption that there is nothing of concern in this

11 affidavit, and I have not developed that concern.

12 I made it quite plain that we were not going to stand in

13 the way of the reasonable disbursement of proper

14 expenses. I made that quite plain.

15 But I am not going to give up. I am afraid I will

16 make submissions on the reason we have concern as to

17 this asset, and very, very simply, your Lordship was

18 told that Mr Arkhangelsky could not afford to go to

19 Paris. I haven’t got the exact reference, but he said

20 something like he would have to sleep in the train

21 station.

22 I don’t want that to be quoted back, because that

23 may be my rather blurry recollection, but it was quite

24 a graphic submission, to the effect that he was right

25 down to his last cent, that was the burden of it, and

24 :1 this shows that there is an amount of money, some
2 €325,000 available, out of which he needed some €17,000

3 to be able to have the taking of evidence in the court

4 which this court, your Lordship, thought was the most

5 appropriate forum for that. Now, that is a relevant

6 factor.

7 A second directly relevant factor is the continued

8 attempt to say that this trial will not be fair because

9 of the limited resource available to

10 the counterclaimants. That has been said probably

11 hourly, certainly daily, and it is a threat that is

12 hanging over your Lordship and over my clients, and to

13 give a very specific example, it is really said that if

14 the court insists upon, or if the court allows the

15 Bank of St Petersburg, facing a counterclaim of some

16 $700 million, if it should be allowed to call its

17 forensic accountant, for which leave has been given, and

18 it has paid for a report or two or three, the trial will

19 be unfair, there would be an Article 6 point because the

20 counterclaimants can’t afford to get Mr Steadman to

21 court.

22 We had a letter from Mr Steadman only this week. If

23 we just look at this one example —

24 MR JUSTICE HILDYARD: But where are these points going to

25 help me adjudicate whether or not to release the monies,

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25 :1 which is all I am concerned about?
2 Of course I notice, Mr Lord, the fact that there are

3 these monies and that the priorities which the

4 defendants appear to attach to various things in

5 preference to others, and of course, when it comes to

6 whether there is or isn’t a fair trial by reference to

7 matters they can or cannot afford in the future, I will

8 remember very well this day.

9 But what I have to do now — now — is determine

10 whether or not to release these monies.

11 MR LORD: And one of my respectful submissions is when

12 I show your Lordship the questions and queries, the

13 fairest order to make would be a release order, subject

14 to — or not subject to, but carrying with it,

15 immediately in its wake, some order that asset

16 disclosure and income disclosure will be made.

17 MR JUSTICE HILDYARD: Can you show me where this particular

18 policy, amongst the three policies, was disclosed?

19 Could we have a look to see, was a value ascribed to it?

20 MR LORD: Yes, it was, I think.

21 MR JUSTICE HILDYARD: What was it then?

22 MR LORD: 330,000, I am told. My clients had assumed, and

23 have assumed that this money had gone on lawyers and

24 living expenses and so on. We didn’t think that this

25 money —

26 :1 MR JUSTICE HILDYARD: So this is a good day for you?
2 MR LORD: Well, it depends what it’s spent on, my Lord. If

3 it is spent to ensure the trial —

4 MR JUSTICE HILDYARD: You thought it had already gone, now

5 you are told it hasn’t. That’s good news.

6 MR LORD: Yes, my Lord, and the Mr Steadman point.

7 I am sorry, I do object to the suggestion that this is a

8 strategic move. We are trying — it’s not, my Lord,

9 I am afraid I do object to that.

10 MR JUSTICE HILDYARD: I know what you are objecting to, but

11 occasionally, I think, that whilst normally very

12 reasonable, the claimants tend to disproportionality,

13 and the question is whether this is an example of that

14 tendency or not.

15 MR LORD: Well, my Lord, I, with respect, would submit that

16 this is not a disproportionate reaction; that in this

17 exceptional case with exceptional latitude being granted

18 to these defendants — this will be, in my submission,

19 a unique case. The size of this counterclaim, and

20 when — your Lordship may think that it is absolutely

21 fine for these counterclaimants to have submitted what

22 they have submitted, and that it is all right to say: we

23 can’t have Mr Steadman because we want to keep a nest

24 egg. If your Lordship is of that view, then that’s

25 your Lordship’s view and we will obviously work with

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27 :1 that.
2 MR JUSTICE HILDYARD: I’m not saying whether it is or it

3 isn’t my view. It is a matter for another day.

4 When the issue arises as to the position with

5 respect to Mr Steadman and whether it has consequences

6 in terms of the fairness of this trial, I will remember

7 this day, I have said that.

8 MR LORD: My Lord, I would like to make submissions about

9 the asset — your Lordship will also recollect that we

10 wrote letters about the mirror companies and about

11 City Centre. Does your Lordship recollect those letters

12 that were written?

13 MR JUSTICE HILDYARD: Yes.

14 MR LORD: And a judicial hortatory observation was given

15 that it would be, perhaps, helpful, and in

16 the counterclaimants’ interests to answer those.

17 MR JUSTICE HILDYARD: Yes.

18 MR LORD: And they have not been answered. So your Lordship

19 understands the burden of that, some substantial monies,

20 not small amounts of money for income tax, but

21 substantial sums of money seem to have gone to this

22 City Centre company.

23 MR JUSTICE HILDYARD: But my concerns do not reduce their

24 living expenses.

25 MR LORD: No. My Lord.

28 :1 MR JUSTICE HILDYARD: I’m just trying to take this — all of
2 us would prefer to be doing something else today than

3 wonder about things in the future.

4 Now, for the moment there is an application for the

5 withdrawal, or some order which enables Société Générale

6 to make provision for the withdrawal of certain amounts

7 of cash, and what I am wondering about is, well, what

8 amounts really are needed; should it be a lump sum of

9 75,000, or a more controlled monthly withdrawal, or

10 what? That’s my concern.

11 Mr Lord, I have noted a number of things about the

12 priorities which the defendants attach from time to

13 time, and I will explain that to them. I notice that

14 Mr Ameli is involved. I notice that this other lawyer

15 is involved. I notice that lawyers are involved pretty

16 much everywhere except this court. Of course I notice

17 that.

18 MR LORD: My Lord, you can see from my client’s point of

19 view — I made the submission about the timetable, but

20 I am getting a lot of pressure because my client — so

21 your Lordship knows, my clients do not accept — have

22 never accepted — that the counterclaimants are as

23 bereft of resource as they have submitted. That has

24 a material bearing on this case. Your Lordship has

25 given exceptional rights of audience and exceptional

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29 :1 latitude on that premise. If that is a false premise,
2 then the matter should be reviewed.

3 MR JUSTICE HILDYARD: But there is nothing in what presently

4 emerges, given that this was one of the three policies

5 disclosed, at or around its value, which adds to

6 the body of knowledge as to whether or not they have any

7 other assets, and my conclusion was that you had not

8 demonstrated that they had, and at the moment, do you

9 want me to revise that conclusion?

10 MR LORD: I don’t my Lord, but I think I made the

11 submission, or I tried to make the submission, that that

12 was the wrong way around: it wasn’t for me to, sort of,

13 if you like, prove no resource. It was really

14 appropriate for a party seeking this regime for the

15 trial to have —

16 MR JUSTICE HILDYARD: Well, I said in my judgment, from

17 recollection, that the difficulty was that it would then

18 cause the defendants to have to prove a negative, and

19 that’s right, isn’t it? It is very difficult when

20 people say: we’ve got no other assets, for them to show

21 that’s the fact except by identifying the assets they

22 say they do have.

23 If you then at that, or at some subsequent time,

24 show that they have some other assets, that could

25 entirely alter the burden of proof, but that is not the

30 :1 position.
2 MR LORD: My Lord, going through this — does your Lordship

3 wish to deal with the substantive concerns, because

4 your Lordship asked me what today’s position is.

5 MR JUSTICE HILDYARD: Yes.

6 MR LORD: I made it clear at the beginning of today we were

7 not objecting. Your Lordship said I am objecting.

8 I think, with respect, that is an unfair

9 characterisation of my position.

10 MR JUSTICE HILDYARD: Well, I apologise if it is unfair.

11 MR LORD: It was not my position. I made it quite clear

12 that was not my position.

13 MR JUSTICE HILDYARD: So you agree to 12?

14 MR LORD: I am going to invite your Lordship to make that —

15 to release that money, but on condition, or coupled

16 with, a requirement for some sort of affidavit of assets

17 and income to be filed by the counterclaimants.

18 MR JUSTICE HILDYARD: Let’s deal with assets. What more can

19 they say? They say that this is their only asset. They

20 say that this is what they hope will be their pension,

21 and it’s not going to be.

22 MR LORD: Well, my Lord, we are getting into analysis of

23 this affidavit and what’s said in it, and we have had

24 an exhibit that is excerpts from their bank accounts.

25 MR JUSTICE HILDYARD: Okay, show me that.

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31 :1 MR LORD: I have only had half an hour, my Lord — I am
2 sorry, my Lord, but I am afraid I am going to have to

3 make a reservation(?) because I tried to — I made

4 a submission about a fair way of having a pro tem

5 solution and a proper investigation. Your Lordship

6 seems to be suggesting that we don’t have the second

7 stage.

8 MR JUSTICE HILDYARD: Well, I am simply worried about time.

9 I am worried about how to get monies which are

10 unobjectionable out to them in time for it to make

11 a difference. What do you say should be the timing? We

12 are already —

13 MR LORD: I’m not objecting to that. Your Lordship can

14 release this money today. It can go today, as far as

15 I am concerned. It should go in an hour so we can get

16 to Paris, I am not objecting to that —

17 MR JUSTICE HILDYARD: When you say «that», is that all 12,

18 or only the 15,000?

19 MR LORD: My Lord, we will agree, I have instruction that we

20 will agree to whatever the figure is, whatever the

21 figure was, that €75,000 —

22 MR JUSTICE HILDYARD: Right.

23 MR LORD: — we will, by consent, agree that that can go

24 today and be spent as set out in 12, but strictly

25 without prejudice to our position as to whether any of

32 :1 those matters are actually justified.
2 So the money can go, they can have €75,000, and they

3 can pay it for those points. But I am not having it

4 said against me next time round that I agreed it was all

5 right to pay income tax and it was all right to pay

6 Co France, because I am not accepting that. I am

7 agreeing to a sticking plaster because of

8 your Lordship’s observations and the timing, and

9 principally the requirement to get this trial to Paris.

10 So that can happen within five minutes, as far as my

11 clients are concerned.

12 MR JUSTICE HILDYARD: Right.

13 MR LORD: But that will leave the other matter, and I will

14 address your Lordship about that because there are some

15 serious concerns.

16 MR ARKHANGELSKY: My Lord, can I mention that, despite what

17 Mr Lord has just said, all the expenses, all the taxes

18 that he has been referring to, we have been meeting out

19 of our living expenses. We are not above the limit of

20 the freezing order. All the taxes, all the rent, it’s

21 not something that requires any change in the freezing

22 order. This is our ongoing expenses. The total amount

23 of the tax is our social taxes. France is a socialist

24 country with very high taxes. Anyone who gets paid more

25 than €2,000 per month is a rich person and is hit with

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Arkhangelsky [Master]

33 :1 the maximum rate of tax. Because we are foreigners, we
2 have to pay high social expenses and social

3 contributions.

4 Now, we pay that out of our daily living expenses.

5 Our tax return is in the public domain. Mr Ameli has

6 made an affidavit to that effect. He has described our

7 expenses and our income and, therefore, the accusations

8 made by Mr Lord are totally misconceived, and I fully

9 agree with you in the sense that if they have questions,

10 if they have concerns, let them show us at least one

11 euro, at least one rouble that I have stashed away or

12 hidden from yourself, my Lord, or from Mr Lord. These

13 accusations are totally misconceived and this is

14 completely against the rule of law and fair trial

15 requirements.

16 One other important comment that I believe I need to

17 bring to your Lordship’s attention is this: My ultimate

18 value is my family. Obviously, a commercial court in

19 Russia, Bulgaria, BVI, English or French court is

20 extremely important, but this has to do with my position

21 in life, and with my dignity. Having said that, my

22 family is more important to me, and I understand that

23 irrespective of the outcome, and I do hope for a fair

24 outcome, having my family go with a cap in hand would be

25 extremely unfair.

34 :1 We have been very clear about our expenses. Our
2 expenses are part of our pension pot and this is

3 a pension pot that we have put in place for our

4 children. We are foreigners, we have several young

5 children. My wife is not working, that is why we put

6 that pot in place, and the most important comment with

7 respect to something that Mr Lord keeps making and keeps

8 ignoring, even if I do prevail in this litigation, I am

9 absolutely certain that Bank of St Petersburg and

10 Mr Savelyev will never comply with an English court

11 judgment, will never pay me a single penny.

12 MR JUSTICE HILDYARD: Mr Arkhangelsky, I am sure it is my

13 fault, but I seem to have encouraged, on both sides,

14 a level of emotion which is not going to assist me

15 determine the discrete matters which I have to determine

16 today.

17 You have gone well beyond, if I may say so, that

18 which is necessary to justify, or to seek to justify

19 what you want, which is the withdrawal of certain monies

20 for the expenses you have identified. The rest of

21 the allegations which you pour out will have to await

22 another day. I am afraid by taking a minimalist

23 attitude, I seem to have encouraged a maximalist

24 emotional response, and I regret that.

25 My wish is to try and identify with a little bit

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Arkhangelsky [Master]

35 :1 more particularity, despite Mr Lord’s flexibility, which
2 I acknowledge, as to the withdrawal of sums, subject to

3 proper protections and other considerations in

4 the future, despite his flexibility, there are some

5 issues which, given that the affidavit was prepared by

6 a lawyer, I find rather surprising, and of concern.

7 The income tax headline which you want is 9,960, but

8 the only amount payable in the immediate future is

9 3,320. I imagine that income tax may be payable

10 quarterly, and that the first payment is due on

11 15 February.

12 What is the rota of payments due in respect of the

13 income tax? After the 15th, if I can put it the other

14 way —

15 MRS ARKHANGELSKAYA: Well, the first tranche is on

16 15 February, then 15 April, and the third tranche is

17 some time around June or July, definitely in the summer.

18 But for us, we are looking at a large amount, 75,000

19 as opposed to, say, 40,000, because life assurance,

20 before we can use that money for ongoing expenses, we

21 need a lot of time. The bank would need anywhere

22 between two and three weeks to do that, therefore we

23 thought that we will take €75,000, and we will be using

24 that money over a protracted period of time, say

25 12 months, not to have to go to the bank two or three

36 :1 times, because it requires a lot of time because you
2 need to make an appointment with the clerk, you have to

3 come and talk to him, then you have to wait for a long

4 time.

5 So we thought we would be asking for a lump sum of

6 70,000 that we would then be living off, within the

7 framework of the limit of 2,000, according to

8 the freezing order. Once again, the 75,000 would last

9 us anywhere between 10 and 12 months.

10 MR JUSTICE HILDYARD: I understand, I understand. Now when

11 is taxes and fees relating to the apartment in Nice,

12 when are they payable?

13 MRS ARKHANGELSKAYA: The approximate sum for the next couple

14 of months, to put it clearly, about 30,000 for the next

15 couple of months, because we have to budget for the trip

16 to Paris. That’s the biggest expense, that’s the

17 nearest biggest expense.

18 MR JUSTICE HILDYARD: I was just talking about the

19 apartment. Do you pay those taxes and fees monthly? If

20 not, how often do you pay them and in what amount?

21 MRS ARKHANGELSKAYA: Monthly. It is monthly.

22 MR JUSTICE HILDYARD: What is the monthly amount?

23 MRS ARKHANGELSKAYA: On a monthly basis about —

24 MR ARKHANGELSKY: I am sorry, we have a problem with the

25 voice. It is changing languages every second minute.

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Arkhangelsky [Master]

37 :1 (Pause).

2 MRS ARKHANGELSKAYA: On the monthly, could I please clarify
3 what the money is spent for, on a monthly basis?

4 MR JUSTICE HILDYARD: Taxes and fees related to

5 the apartment in Nice is what I’m asking about.

6 MRS ARKHANGELSKAYA: It’s about 2,500 per month.

7 MR JUSTICE HILDYARD: And are they in arrears or paid up so

8 far? Have you paid all that’s due so far?

9 MRS ARKHANGELSKAYA: Yes. Everything is paid so far, to

10 this day. The next obligatory payment that cannot be

11 delayed is 3,320, due on 15 February, and the trip to

12 Paris.

13 MR JUSTICE HILDYARD: And the Co France rental payment, are

14 you proposing that that be paid to Co France, or to

15 the landlord?

16 MRS ARKHANGELSKAYA: Certainly to the landlord. I propose

17 to pay to the landlord, because Co France does not

18 operate now, there is no income, my husband is here and

19 I am dealing with the children, so we have to take about

20 three months of rent payments within the money, because

21 we don’t want to lose the business. You can imagine two

22 foreigners arrive to France, it’s not so easy to work

23 here for us. Everything will be within our expenses, we

24 will just cut down our daily expenses on food, on some

25 small entertainment for the children, et cetera, in

38 :1 order to pay the rent.
2 MR JUSTICE HILDYARD: Do you have accounts or other

3 statements which would show how Co France has been doing

4 over the last year?

5 MR ARKHANGELSKY: Absolutely, there are accounts for

6 Co France.

7 MR JUSTICE HILDYARD: And what are they drawn to? What are

8 the dates that they cover, the accounts that you have?

9 MR ARKHANGELSKY: As of today, we have accounts for 2013 and

10 2014, and submission of accounts for 2015 shall be at

11 the end of May.

12 MR JUSTICE HILDYARD: And you would have no objection to

13 providing those accounts —

14 MR ARKHANGELSKY: My Lord, my Lord, if I may, I also wanted

15 to draw the court’s attention?

16 Of course not. This is not a problem at all.

17 I have discussed the issues of these documents with

18 Withers, when we had Withers, and since they say that

19 the cumulative assets of Co France are less than £5,000,

20 this information does not need to be disclosed to court.

21 I do not have any problem with disclosure, but I simply

22 wanted to draw your attention to that creating certain

23 temporary difficulties, because that will distract us

24 from preparing for this hearing.

25 All the more so because these are public accounts in

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Arkhangelsky [Master]

39 :1 France, one can go onto the website of the state
2 taxation service and see all the turnover, all the

3 amounts, the taxes and the actual balance sheet.

4 Mr Lord can pump it down from the internet. This

5 information is public.

6 MR JUSTICE HILDYARD: Thank you.

7 Right, now it is bound to be said that,

8 notwithstanding it is understandable you should not wish

9 to use all your monies at once, nevertheless, it does

10 not sit — it is not right for you to explain that you

11 cannot afford lawyers if you have the money whereby to

12 do so, and, more particularly, it is not right for you

13 to complain about the fairness of a process because you

14 have chosen not to pay for some essential participation

15 in it.

16 Now, that is inevitable that that should be said.

17 You may say: my goodness me, but that means that we will

18 be exposed for the future and we will not be able to

19 provide for our children, and that is an understandable

20 point, but the fact also is that if you have the money,

21 that is your choice: you are not left with no choice,

22 you are left with a human, but difficult choice. Would

23 you like to say anything about that?

24 MR ARKHANGELSKY: Absolutely, because the amounts that we

25 are discussing that we still have in our accounts, that

40 :1 is court hearings that would last for about one week.
2 I believe you understand, your Lordship. I understand

3 the Bank spends at least £1 million every month, and now

4 we are only talking about £200,000, £250,000. You know

5 very well counsel and solicitors and barristers’ rates,

6 and one needs to understand what this budget could

7 really be spent for.

8 MR JUSTICE HILDYARD: Well, I will give you an example.

9 MR ARKHANGELSKY: At the same time we have no sources of

10 income.

11 MR JUSTICE HILDYARD: Yes, I will give you an example. I do

12 not know whether Mr Ameli, or whether this further

13 French lawyer are being paid, maybe they are acting for

14 free, but in the case of Mr Steadman, who is a very —

15 MR ARKHANGELSKY: They work pro bono, your Lordship.

16 MR JUSTICE HILDYARD: Yes, thank you. In the case of

17 Mr Steadman, who has refused, as I understand it, to act

18 pro bono, have you ascertained what it would cost for

19 him to attend and whether you could afford it?

20 MR ARKHANGELSKY: My Lord, I spoke to him a week ago, or

21 three weeks ago, and he told me that we are talking not

22 about taking part in the court proceedings, and not as

23 much about taking part in the proceedings. Taking part

24 in such court proceedings where the reputation of him

25 and his company is involved would call for many months

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41 :1 of preparation on his behalf, even if we take some
2 mythical figure of £200 to £300 per hour, if you time

3 it, two or three months’ preparation, you understand

4 well what calculation we will arrive at, and he told

5 honestly about that. He said that his company is first

6 rate, they are not going to do it just for free. It’s

7 not because they don’t like my case, but because this

8 work demands a large amount of preparation, not just for

9 himself, but for his employees.

10 MR JUSTICE HILDYARD: Thank you.

11 Mr Lord, as I have explained, I regard my job today

12 as relatively discrete, but I have been asking these

13 questions because I wish to reassure myself that my

14 orders are not being not taken account of.

15 MR LORD: I understand.

16 MR JUSTICE HILDYARD: My inclination, following from your

17 indication, is to permit and make whatever direction is

18 necessary to permit, the 75,000 which is sought, but

19 I shall require evidence as to the income tax

20 liabilities, and evidence that the monies withdrawn are

21 used to discharge those.

22 Likewise as to the taxes and fees in respect of

23 Nice, the travel and dwelling expenses you have asked

24 for clarification of, but are broadly agreeable to

25 the 15,000 then imagined and 17,000 may simply be

42 :1 a further estimate, but that also has to be quantified;
2 and Co France, there must be evidence of their past

3 performance. There seems to be no problem in that since

4 I am told that they are public anyway, and there must be

5 receipted invoices of the amounts paid to the landlord.

6 I do not, Mr and Mrs Arkhangelsky, mean to suggest

7 that I simply do not believe you; I just mean that this

8 must be recorded so as to avoid question marks in the

9 future.

10 The issue as to Mr —

11 MR ARKHANGELSKY: I see no problems. Absolutely.

12 MR JUSTICE HILDYARD: The issues as to Mr Steadman, and as

13 to whether or not it would be possible to enhance your

14 representation at the trial, will have to be dealt with,

15 I think, once I have thought further and Mr Lord has

16 thought further. Those are my provisional inclinations.

17 Mr Lord, is that agreeable to you?

18 MR LORD: My Lord, yes, certainly in terms of the release of

19 the money, and in terms of, if you like, the questions

20 and concerns that arise, in my respectful submission,

21 this affidavit does cause concern as to whether the

22 court has proceeded on a fully accurate basis in terms

23 of the resource available to these counterclaimants.

24 That resource and the alleged deficiency therein has

25 been a constant refrain from these counterclaimants.

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

43 :1 They have complained about the potential unfairness at
2 every stage.

3 If it is the position that they have chosen not to

4 brief junior counsel, not to finance Mr Steadman,

5 through a choice that they have made, then that is

6 a relevant consideration, and certainly I will reflect

7 and take instructions, but in light of this affidavit,

8 this is really the end of any complaint, in my

9 respectful submission, of any unfairness due to resource

10 in this case.

11 MR JUSTICE HILDYARD: Well, I think that may not be

12 an accurate prediction. But there we are.

13 MR LORD: It is my fault. It was a bit too theatrical.

14 What I meant, my Lord, is really your Lordship asks

15 where this is going. Almost minute by minute we get

16 apologies for inefficiencies and translations and

17 alleged poor questioning, which I don’t accept,

18 Mr Stroilov is a very adept performer. But endlessly

19 there is the use of a carapace of a lack of resource

20 throughout this litigation. It affects how my

21 solicitors have to conduct it, the burden they are

22 under, complaints about how the hearing should be

23 conducted, what time should be allowed, how many of my

24 witnesses should be stood out of the timetable to let

25 a non professional cross-examiner to catch up.

44 :1 It has a host of really quite profound fairness
2 implications for my clients, but in my respectful

3 submission, this affidavit calls into serious question

4 whether that is a —

5 MR JUSTICE HILDYARD: Well, to some extent — we will have

6 to discuss this if and when it arises — 366,000 is good

7 news, but it is not going to cover their necessary

8 living expenses and legal fees for at all long. We must

9 keep a sense of proportion about this. It may be that

10 more inquiries ought to have been made by you, and

11 possibly by the court, as to what part of the 320,000,

12 as it then stood, had already been spent. All these

13 matters look sharp in retrospect, not so sharp at the

14 time.

15 We will have to return to the fray. I would say two

16 things, Mr and Mrs Arkhangelsky, more generally. The

17 first is to echo, to some extent, the point made by

18 Mr Lord that, although choices are very harsh, they

19 nevertheless are choices, and whether a choice is being

20 made not to fund, for example, the attendance of

21 a witness does affect the court’s view, from time to

22 time, as to the fairness of the process. They are

23 connected, and, therefore, you have to be candid with me

24 so that I can weigh the substance of your complaints, if

25 they continue, as to the fairness of the process.

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

45 :1 That’s rather a convoluted way of saying, I am
2 afraid, that I have promised to review the fairness of

3 the trial from time to time, but in doing so, I must

4 know what the true facts are, and amongst the facts

5 which will be relevant are the resources available to

6 you, even if you would prefer to spend them on some

7 other expenses. That’s the first point.

8 Ancillary to that first point is also this: that

9 I have urged Mr Stroilov and you, through him, and

10 I have urged you directly, always to look to cooperate

11 with the trial rather than to find ways of criticising

12 the process. It will look far better from your point of

13 view to have done so, because then if there is a true

14 unfairness, you will not have cried wolf so often.

15 I don’t know whether you know the expression «cry wolf».

16 You raised a false alarm so often.

17 The second thing is this, and I know that

18 Mr Arkhangelsky no doubt had a great shock.

19 MR ARKHANGELSKY: That’s a very old Russian fable, sir.

20 MR JUSTICE HILDYARD: Right, good, thank you.

21 The second thing is this: I know that it must have

22 been a shock for Mrs Arkhangelskaya who, as any mother

23 would, is anxious to ensure that household expenses and

24 food and everything else, and rent and taxes are all

25 paid, as you will be also, Mr Arkhangelsky. No doubt

46 :1 the shock made her less concise and clear than she
2 should have been when reporting the events to you. But

3 when the matter is relayed to the court, the court will

4 take your account — unless and until it is demonstrated

5 not to be accurate — at face value, and if it is

6 thereby misled because you have not taken the trouble to

7 check the exact accuracy, you will find the court

8 increasingly disappointed in you.

9 You must not, whether through Mr Stroilov, or

10 directly, recount matters on which you are inviting the

11 court to rely, which are not, after careful checking,

12 entirely accurate; do you understand what I am saying?

13 MRS ARKHANGELSKAYA: Yes, absolutely. We do understand, and

14 we will provide all the necessary documents.

15 MR JUSTICE HILDYARD: Yes, you will do that, but you will

16 not, in the future, put forward as an emergency

17 requiring to be dealt with that very morning,

18 withdrawals from a bank on the basis of information

19 which you now accept was inaccurate and incomplete. It

20 must not happen again.

21 MRS ARKHANGELSKAYA: My Lord, I have a small question:

22 I didn’t understand which information was inaccurate and

23 incomplete.

24 MR ARKHANGELSKY: We, to this day, believe that that was the

25 Bank of St Petersburg creating problems for us at

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

47 :1 Société Générale.
2 MR JUSTICE HILDYARD: Belief is one thing, but reporting to

3 the court that that is what Société Générale had given

4 you to understand does not appear to be accurate and

5 places no part in the comprehensive statement that

6 I asked to be put before me. Do not put before me

7 matters which you cannot and have not taken steps to

8 verify. I do not want there to be a difference between

9 what you are prepared, or your lawyers are prepared, to

10 write, and what you are prepared to say in a hurry.

11 All right. Now to the actual technicalities. So

12 sorry, yes?

13 MRS ARKHANGELSKAYA: Yes.

14 MR JUSTICE HILDYARD: The technicalities. Société Générale

15 are concerned about the order, the 2012 order. I dare

16 say they will need some specific direction or order

17 enabling the release, subject to the conditions which

18 I have adumbrated, although not specified, I suppose.

19 MR LORD: My Lord, just, again, thinking out loud, I am not

20 drafting. I imagine from the Bank’s point of view they

21 want a consent order, or possibly the consent of

22 the Bank of St Petersburg, to a certain release of

23 money. I am not sure they want the breakdown. The

24 breakdown probably comes, forensically, from the

25 defendants into this litigation, I would have thought.

48 :1 But they will need a clean order. They will just want
2 to be told on a piece of paper —

3 MR JUSTICE HILDYARD: I think you are quite right. They

4 won’t want to look behind it.

5 MR LORD: In the whys and wherefores, my Lord. I think it

6 may be that we will have to draft swiftly, and we will

7 do it now, a consent order which your Lordship, if

8 your Lordship is kind enough, could endorse today and

9 then it can be sort of faxed off ASAP and the money

10 released. I think that leaves the aftermath, really —

11 MR JUSTICE HILDYARD: Whether by a supplementary order or in

12 correspondence, which I see and approve, or if you wish

13 me to give directions in an approved form, I do wish the

14 supplementary evidence which I have adumbrated to become

15 available.

16 MR LORD: There is a further question, my Lord, about, for

17 example, the Bank statements — a number of points

18 arise. We anticipated that the Arkhangelskys would go

19 into writing, not through a lawyer, that’s the first

20 point. It is a matter for your Lordship whether that is

21 a satisfactory position, because it clearly builds in

22 distance and detachment, and that is why courts tend to

23 want the horse’s mouth, as it were, because things that

24 are very important, with the best will in the

25 world there can be a —

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Bank St Petersburg v Vitaly Day 6

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49 :1 MR ARKHANGELSKY: My Lord, could I please ask you to
relieve
2 us from unnecessary bureaucratic work? We are very busy

3 in preparation to the hearing and what Mr Lord proposes

4 here, some treatises, I think it is pointless and only

5 accumulates the expenses.

6 MR JUSTICE HILDYARD: Let us see what Mr Lord says, and then

7 I will ask you to comment on it, but let us not

8 interrupt him.

9 MR LORD: My Lord, I was going to suggest — well, the first

10 thing was to get the consent order away today. We can

11 draft some directions, because I think your Lordship has

12 in mind some verification or validation of the disbursal

13 purposes of this €75,000, or some odd, that is one part

14 of that, if you like, that is a compartment, and that

15 leaves the question whether it is appropriate to require

16 some further affidavit of assets and income from the

17 counterclaimants, and I was just prefacing that

18 submission, or that suggestion, I was observing that we

19 had not had anything from the horse’s mouth, as it were,

20 and typically when you are saying to a court: this is

21 the only money I have, or: I really must have this

22 money, you would expect that to come pretty directly,

23 because there is a focus and a rigour from that process,

24 and there’s no scope, really, for subsequent

25 explanations that actually somebody didn’t quite

50 :1 understand or didn’t remember to write something down.
2 Obviously that shouldn’t really happen, but it does

3 happen, and in this case we have had extracted — we

4 have had excerpts from bank statements. We have had

5 single pages from print outs of five or six — we have

6 had page 2 of 6, or page 1 of 5, and several accounts

7 are revealed and it is not, in my submission,

8 satisfactory where there is clearly recognition by the

9 Arkhangelskys that they should be apprising the court of

10 their financial situation, for that to be done on

11 anything other than a complete basis.

12 They have, in effect, for this affidavit and

13 exhibits, acknowledged that. So the question, really,

14 is it can’t be so unfair to require that process to be

15 perfected. I don’t know how this process of extraction

16 has been conducted in such short order; in other words,

17 there appear to be some six bank accounts identified,

18 and we only have a handful of extracts from it. And it

19 looks like there has been some filleting out, and so

20 there is, obviously, some accounting capacity and

21 capability available to the defendants.

22 Really, there are issues arising as to the freezing

23 injunction, there are issues arising as to the case

24 management and the conduct of this case, and, in my

25 submission, it would be appropriate to require

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

51 :1 affidavits — an up-to-date affidavit of means of assets
2 and income, and the exhibiting, let’s say, of the last

3 six months of bank statements, and that would be

4 an appropriate course for the court to take, if only to

5 be satisfied that the premise for the advocacy and

6 conduct arrangements is a sure one, because the review

7 process cuts both ways. I did make it plain that we

8 didn’t accept that the — I’m not going to re-argue it,

9 but that reservation remains, it remains our position,

10 and this affidavit, I am afraid, supports that concern

11 that there is additional resource that could be deployed

12 in this litigation than has been put into play.

13 There are difficult choices, your Lordship is quite

14 right, but there are plenty of litigants in this

15 jurisdiction, indigenous litigants, who end up running

16 out of money or fight a libel trial or whatever, and end

17 up having to spend their life savings, and it may not be

18 fair, it may not be right, there are all sorts of

19 comments one can make, but simply because we are dealing

20 with Mr and Mrs Arkhangelsky, it doesn’t mean that, if

21 you like, a different service applies and different

22 rules apply.

23 So I just put that reservation down, and it may

24 shade with the extent to which we are ever going to hear

25 again any complaint about the fairness of the trial.

52 :1 Because there is, on the face of it, enough money,
2 there is enough money to have deployed additional

3 representation. Our understanding is that Withers

4 offered to — if your Lordship remembers the interim

5 payment application, I think Withers agreed to do it on

6 100 per cent CFA and various counsel on a partial CFA.

7 So on these figures, and it may not have been a very

8 palatable choice, but it looks as if, potentially,

9 counsel could have been deployed for this trial and we

10 wouldn’t have had to have — I don’t criticise

11 Mr Stroilov, but there wouldn’t have been any question

12 of going down that route.

13 That’s where we are. We are where we are, but so

14 your Lordship knows, I think it would be wrong of me not

15 to alert the court to the concerns we have, as revealed

16 by this affidavit. Shall I develop those concerns, or

17 is that sufficient for your Lordship’s purposes?

18 MR JUSTICE HILDYARD: Well, develop them insofar as you want

19 me to make directions at the same time, as it were, as

20 any consent order; do you see what I mean?

21 MR LORD: Yes.

22 MR JUSTICE HILDYARD: It seems to me that your submissions

23 with respect to the fairness of the trial are not really

24 matters which I can address further at this stage,

25 profitably.

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

53 :1 MR LORD: Yes, I accept that.
2 MR JUSTICE HILDYARD: It seems to me that matters of

3 verification and any additional concerns to which the

4 revelation of partial statements in respect of six

5 accounts, those seem to me to be matters on which,

6 subject to hearing Mr and Mrs Arkhangelsky, you may

7 wish, legitimately, to press at the moment.

8 MR LORD: I see.

9 My Lord, on looking at this affidavit in

10 paragraph 7, the deponent is dealing there with the

11 Barclays life policy —

12 MRS ARKHANGELSKAYA: Could I ask a quick question?

13 MR LORD: — is dealing with the Barclays life policy, which

14 your Lordship looked at in March 2014. If your Lordship

15 looks at the final sentence, it reads as follows: most

16 of the money from the realisation of that life insurance

17 policy was, since then, spent on the legal and living

18 expenses within the limits set by the freezing order.

19 I think it was approximately €250,000.

20 So I think it is fair to assume that this affidavit

21 has been fairly carefully drafted, so most — it shows

22 that not all the money has been spent in that way, so

23 really that begs two questions: has other money been

24 spent out of that purse, other than on legal and living

25 expenses within the limits set by the freezing order

54 :1 and/or is, in fact, the money still left in that policy,
2 or the proceeds of it, following surrender and, if so,

3 how much.

4 I doubt that words have been used anything other

5 than very advisedly in this document and, therefore,

6 there is that concern or that issue about what is left.

7 Then we have the amount in the Société Générale

8 policy but, my Lord, it is really — I think the main

9 point then is really the sort of back-up for this

10 really, and the exhibits that we have had which seem to

11 reveal — there are six different bank accounts, I think

12 at Société Générale, that are revealed, and we have had

13 a handful of sort of extracts from the statements. So

14 not all the statements and not all the print outs even

15 from that, and my Lord, that must be a fairly clerical

16 or administrative matter which one would expect the

17 relationship person at Société Générale — one would

18 imagine the Arkhangelskys don’t need to be much

19 inconvenienced by the production of that.

20 It would, in my submission, be appropriate for them

21 to explain their asset position and any other bank

22 accounts that they’ve got, whether with Société Générale

23 or elsewhere, and to produce bank statements from those

24 sources, for example, covering the last six months.

25 Because, in fact, a lot has happened in the last six

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

55 :1 months in terms of this litigation, and that would allow
2 the court to satisfy itself that the basis upon which

3 the court has proceeded in terms of representation and

4 conduct on behalf of the counterclaimants has been

5 surely footed. In my submission, that would not be

6 a disproportionate intrusion, that would be a reasonably

7 clerical task that you would expect the relevant banks

8 would bear the lion’s share of the work, but there would

9 need to be a sort of candid identification by the

10 Arkhangelskys of their assets.

11 Now, if it is right that they really don’t have very

12 much left in the world other than what they have

13 revealed in recent times, then one would expect that

14 wouldn’t be a very substantial task and we would invite

15 your Lordship to make some sort of order that they file

16 affidavits, both the counterclaimants, and an affidavit

17 is filed on behalf of the corporate counterclaimant that

18 attest to their current assets, current income, and

19 exhibit any, let’s say six months of relevant bank

20 statements.

21 If it is said that that’s a burdensome task, that

22 begs the question why is it a burdensome task.

23 I understood the position to be that the Arkhangelskys

24 didn’t have many assets left or much income, and

25 wouldn’t, in our submission, take long, and it should

56 :1 include Co France. Your Lordship has been told on
2 several occasions that the necessity for Mr Stroilov is

3 that Mr Arkhangelsky has to work all hours God gives to

4 work on his businesses. So I am not criticising him and

5 I am not in any way belittling the scale of the task for

6 him, I am not doing that, I am just submitting that

7 there is a potential inconsistency between saying that

8 Co France is essentially, now, sort of moribund, or in

9 some sort of state of suspense on the one hand, and

10 suggesting that actually Mr Arkhangelsky can’t attend

11 the litigation because of his business commitments on

12 the other.

13 The court is entitled to get to the bottom of this.

14 It is not a game. It’s not trying to catch someone out.

15 These are serious matters. Your Lordship has, in my

16 submission, granted these defendants considerable

17 assistance and help to ensure fairness and, in my

18 submission, there is a reciprocity here that the

19 Arkhangelskys should level with the court, with

20 your Lordship, and to shore up the record so there can

21 be no concern or complaint about any of these matters.

22 So we would invite your Lordship not just to require

23 the supplementing on the particular disbursements that

24 I envisage pursuant to the €75,000 release, but to go

25 beyond that and to order these documents to be filed;

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

57 :1 and they would be a useful archive, in my submission, in
2 terms of case management complaints, financing of

3 disbursements for experts, and making sure that the

4 freezing injunction is and has been respected.

5 There are a number of really rather important

6 reasons why that would be a proportionate thing to

7 order, and I ask your Lordship so to order.

8 MR JUSTICE HILDYARD: Yes.

9 Mr Arkhangelsky?

10 MRS ARKHANGELSKAYA: My Lord, would I have your permission

11 to speak now?

12 MR JUSTICE HILDYARD: Yes. One or other of you. I just

13 want to set the parameters. We will make an order for

14 the benefit of Société Générale, to enable €75,000 to be

15 released. The premise of that order, and my

16 understanding, is that 75,000 is to be used for the

17 purposes you have identified in paragraph 12 of

18 the affidavit of Nadejda Bidault.

19 MRS ARKHANGELSKAYA: Would your Lordship allow me to speak?

20 MR JUSTICE HILDYARD: Yes, I just want you to know you

21 needn’t address that because that has already been

22 decided.

23 Now, the other points as to —

24 MRS ARKHANGELSKAYA: Yes, thank you.

25 MR JUSTICE HILDYARD: — what further documents and evidence

58 :1 should be provided, first the question is whether you
2 should verify, generally, two things: one is all that

3 was stated on your behalf by Mrs Bidault, and; second,

4 to confirm that, apart from the assets you have

5 previously disclosed, and the asset which Co France may

6 represent, you have no other assets; that’s the first

7 matter; yes?

8 The second matter is whether you should now provide,

9 exhibited to an affidavit, various items which should be

10 available and which, though I will be prompted if this

11 is not a complete list, will include the following: the

12 copy bank accounts for the last two years relating to

13 the six accounts at Société Générale to which you have

14 referred; secondly, the accounts in respect of

15 Co France. Given that the bank should have, at minimal

16 cost, the first, and the second you say can be printed

17 off the internet and should be available to you anyway,

18 it does not seem to me that that is a tremendous

19 intrusion, though, of course, I will hear argument to

20 the contrary if you wish to address it to me.

21 I understand, as regards the first, that is to say

22 bank statements, that people are understandably

23 reluctant to display their entire life in financial

24 terms, but you or your lawyer have chosen to identify

25 these accounts and to exhibit extracts and, having done

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

59 :1 so, and in all fairness, it is right that the entire
2 sequence should be provided, lest for any reason it be

3 suggested that the accounts chosen to be released do not

4 disclose the full and fair picture.

5 I don’t think, as to the second, Co France, you have

6 any objection, and unless and until you say otherwise,

7 I therefore propose to say no more.

8 The affidavit, thirdly, must exhibit the

9 documentation which supports the various charges and

10 taxes which are identified in paragraph 12. Those are

11 the matters on which, if you have comment, I would

12 invite you to comment now, please.

13 MRS ARKHANGELSKAYA: With your permission, I will comment.

14 Obviously, my Lord, all the documents that you have

15 listed we will definitely provide those, absolutely no

16 problem.

17 If you would bear with us, if you could give us at

18 least 10 days, because you have mentioned two years’

19 accounts plus all the bills, and we will be looking at

20 at least 300 pieces of paper, plus our affidavits, so we

21 need time for that. That’s number one.

22 Number two, if I may confirm on behalf of the two of

23 us, in 2012 when we together disclose information with

24 respect to our assets and all our worldwide accounts,

25 nothing has changed since that time. Therefore we will

60 :1 simply be doing what we already did back in 2012, but
2 because your Lordship requires us to do that, we will

3 definitely comply.

4 MR JUSTICE HILDYARD: It is a confirmation —

5 MRS ARKHANGELSKAYA: One other thing, if I may just clarify.

6 MR JUSTICE HILDYARD: Yes. So sorry.

7 MRS ARKHANGELSKAYA: So one other thing, something was said

8 with respect to the 250,000 in Barclays, Mr Lord QC said

9 that we had spent that money. That is not the case: the

10 money had been transferred to Société Générale and that

11 money is part of the 360,000 that we have been

12 discussing for the past two hours, just for the record.

13 One final thing, can I ask a question of Mr Lord QC,

14 without using any legalise, Mr Lord spent quite some

15 time saying that we are not using advocates, even though

16 we do have the resources for that. Can I ask you, sir,

17 personally, you, Mr Lord, we have £250,000, something

18 that people have seen, and something that we will see in

19 our bank accounts. I have a very simple, quick

20 question: the £250,000, how long will that money last

21 for you and your associates to do legal representation?

22 Just for us to understand. How long will that money

23 last to do legal work?

24 MR JUSTICE HILDYARD: As to that, Mrs Arkhangelskaya, the

25 point does not have to be elaborated. I sit in

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

61 :1 the courts day in, day out. I know how expensive
2 litigation is. That’s the first point.

3 The second point is that this is a formal court

4 process, not a quiz show, and I therefore do not wish to

5 get into that. I have been slightly surprised by one

6 thing that you said —

7 MRS ARKHANGELSKAYA: My apologies, my Lord.

8 MR JUSTICE HILDYARD: — I am slightly surprised, I had

9 understood that the €366,009.78 entirely related to

10 the separate policy with Société Générale and not in any

11 part to the Barclays policy which was transferred or

12 assigned to the Société Générale. Have I misunderstood

13 the position? If I have, I do not think that the lawyer

14 on your behalf has been very clear.

15 What is the value of the policy, in other words,

16 that you seek to use now?

17 MRS ARKHANGELSKAYA: My Lord, as of today, the life

18 assurance policy of €366,009.78, the second policy is

19 €1,500, and I will not be giving you the technical

20 details of where it comes from. When my husband was in

21 prison we had to pay bail. So nothing has changed since

22 2012. We did not have any additional resources

23 available to us, apart from these.

24 MR ARKHANGELSKY: May I also comment? What happens is that

25 Mr Lord tried to pick on what was said by our lawyer in

62 :1 her affidavit —
2 MR LORD: Sorry, my Lord. I don’t want them to

3 inadvertently —I don’t want them to inadvertently

4 mislead the court again, I really don’t —

5 MR ARKHANGELSKY: If I may finish —

6 MR JUSTICE HILDYARD: Hold on one second. I can’t hear you

7 both. Will you hold on one second.

8 Yes, Mr Lord.

9 MR LORD: I think in fairness, the affidavit sworn by

10 Ms Bidault, refers to an affidavit which is in

11 your Lordship’s bundle for today, behind tab 10,

12 paragraph 17, and that identifies the life policies, and

13 if your Lordship were to turn that up, it is at

14 {G1/7/6}.

15 MR JUSTICE HILDYARD: All right. There will come on your

16 screen, I hope —

17 MR LORD: I am anxious that Mrs Arkhangelskaya sees this,

18 because she is talking about policies and values, and

19 this is an affidavit by Mrs Arkhangelskaya, a first

20 affidavit.

21 MR ARKHANGELSKY: Unfortunately I do not have this on my

22 screen.

23 MR LORD: {G1/7/6}, there are the life policies there, I

24 think, set out to which cross reference is made in

25 the overnight affidavit. Your Lordship can see the

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

63 :1 values that are there said. We had understood
2 your Lordship to be right that the €300,000 plus value

3 in the Société Générale policy is separately and

4 independently generated from whatever is in the Barclays

5 policy. That was our understanding. So if I have put

6 too much stress on the word «most», then I am sorry

7 about that, but that’s how I got at that, and that seems

8 to support the premise that your Lordship is putting to

9 Mrs Arkhangelskaya.

10 MR JUSTICE HILDYARD: Yes. Do you have that document?

11 I don’t think there is a Russian translation of it. Do

12 you want some time just to remind yourself of

13 paragraph 17, which was sworn in April 2012.

14 MR ARKHANGELSKY: My Lord, we have turned up the document.

15 What I would like to say is that Mr Lord has been

16 picking on some wording used by the lawyer. So what it

17 means, actually, is that all the money from the life

18 insurance policy from Barclays, all the money had been

19 transferred to the Société Générale account. Now, from

20 that account, all the money that we have expended, we

21 have been spending only and exclusively within the

22 limits set by the freezing order. Not a single cent has

23 gone anywhere else.

24 What Mrs Bidault says where she says «most» actually

25 does mean that at this point in time we have €8,000

64 :1 sitting on the account, ie not all the money has been
2 expended, but most of the money has been used up, and so

3 Mr Lord’s comment is misconceived.

4 The other important consideration when you formulate

5 your order is this: out of the €75,000 that we are

6 referring to, 15,000 will definitely be used to pay the

7 travel expenses for us and for the witnesses. All the

8 other expenses will be within the limits set by the

9 freezing order. There will be no other expenses over

10 and above those that have been set. Therefore we would

11 like you, if I may, to allow us not to enter into the

12 totally useless correspondence with the Bank which will

13 be of absolutely no avail. They are not cooperative,

14 I am afraid.

15 MR JUSTICE HILDYARD: Right. Well, I wish you to do this

16 affidavit exhibiting these statements, and I wish you to

17 add to that affidavit, by way of confirmation of what

18 you have told me, two things: one is that the entirety,

19 subject to deductions for tax, of the €366,009.78 is

20 referable to the life insurance policy on

21 Mrs Arkhangelskaya’s life with Société Générale referred

22 to in paragraph 8 of Ms Bidault’s affidavit.

23 Secondly, I wish you to confirm that, as regards

24 the other life policy referred to in paragraph 17.3 of

25 your affidavit of 5 April, which was taken out with

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65 :1 Barclays but, so I understand, transferred to
2 Société Générale, there remains only €8,000, which

3 amount is held for you at Société Générale.

4 MRS ARKHANGELSKAYA: That is correct, absolutely.

5 MR JUSTICE HILDYARD: I want you to confirm that in

6 an affidavit, please.

7 MR LORD: My Lord, the only other issue would be whether —

8 MRS ARKHANGELSKAYA: My Lord, we will be looking at anywhere

9 between 300 and 400 pieces of paper, including all the

10 invoices, bills, and so on and so forth. 400 pages,

11 photocopies of the various expenses.

12 MR JUSTICE HILDYARD: What I understand my order to require

13 you to do is to obtain from Société Générale copies of

14 your bank accounts. They will undoubtedly charge you

15 something, but they will undertake the task of

16 collation, so that should not be a problem.

17 The problem with respect to Co France’s accounts you

18 have already confirmed to me is not, if I can put it

19 very informally, not a big deal; and the other matters

20 which I have asked you to confirm are to be confirmed in

21 an affidavit and do not require exhibits, except for the

22 matters expressly referred to in paragraph 12, which

23 should not be more than, I would have thought, 10 to

24 12 pages, because they will relate to the rent, they

25 will relate to the taxes, and they will relate to

66 :1 the amounts charged in respect of Co France. Therefore,
2 I do not think that that will be as significant a volume

3 as you suggest for you to collate.

4 MR LORD: My Lord, just one other point: we are proceeding

5 on the basis that there are no other bank accounts than

6 the six Société Générale ones that have been identified

7 in the affidavit. If, in fact, there are other bank

8 accounts that the respondents have —

9 MR ARKHANGELSKY: That is correct. There are no other bank

10 accounts and nothing has changed in terms of our status,

11 as compared with the position that existed at the time

12 we wrote the affidavit.

13 MRS ARKHANGELSKAYA: Let me just add, we provided — we did

14 not provide the total excerpts, we only provided the

15 balances, and, as I mentioned in 2012, it is not six

16 accounts: it’s two personal accounts with some sub

17 accounts within those two accounts, just for the record.

18 We will obviously provide all this. If

19 your Lordship could allow us at least ten days for this

20 amount of work to be done, because we need to find it,

21 we need to scan this, we need to ask the bank to provide

22 that. It is just a question of time, my Lord, but we

23 will definitely comply, we definitely will.

24 MR LORD: My Lord, there is a question here that if, in

25 fact, any other bank accounts have been used by the

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67 :1 respondents, that that should be disclosed as well, and
2 bank statements provided.

3 If, in fact, there are none, if, in fact, these are

4 the only accounts, that would be a very simple

5 confirmation, but it should be confirmed as part of

6 the affidavit that the respondents have not used any

7 other bank accounts in the last two years apart from

8 those which they are going to produce the statements

9 for.

10 MR JUSTICE HILDYARD: You are agreeable to that? You must

11 either say that these are the only ones, or if there are

12 any other ones you must disclose what they are and you

13 must disclose the relevant documentation. All right?

14 Now, because this has been a somewhat far-ranging

15 discussion, I will ask RPC, please, once they have had

16 the benefit of the transcript, to set out in writing,

17 addressed to you and to me, the various exercises which

18 I have required, as well as providing a draft consent

19 order, which you may wish also to discuss with

20 Mr Stroilov.

21 That leaves only, I think, two things, one I have

22 not mentioned before and I will come to, but the

23 immediate one is this: how long?

24 Now, I dare say that the indications in the

25 affidavit are that you may not get these statements

68 :1 immediately. Are you agreeable with 10 days?
2 MR LORD: Yes, my Lord, the only point is I would like to

3 have it before I cross-examine in Paris, so I would like

4 to have it really no later than — ideally a week

5 tomorrow, but if that is pushing it, I suppose if it

6 can’t be done — on the Monday morning, I suppose that

7 would be 10 days.

8 MR JUSTICE HILDYARD: We will say by 1.00 pm, Paris time, on

9 the 14th, which is the Monday.

10 MR LORD: The 15th is a Monday, I think, my Lord.

11 MR JUSTICE HILDYARD: I’m sorry, yes, the 15th. Yes.

12 All right then. The question that I had, the only

13 other point I had, is I must say I didn’t really

14 understand paragraph 14 of your lawyer’s affidavit, and

15 I wonder if you could help me or, if not, whether some

16 explanation could in due course be provided. It says:

17 «The bank’s current adviser, Ms Volkanova(?),

18 explained to her that all the necessary formalities for

19 the release of money are accomplished in the agency the

20 same day and that there was no obstacle to releasing

21 money from the policy and, therefore, no freezing order

22 registered in the bank computer system.»

23 I didn’t understand that. It does seem that the

24 freezing order is on the bank computer system, otherwise

25 we would not have the problem.

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69 :1 MRS ARKHANGELSKAYA: I’m happy to explain, my Lord.
2 MR JUSTICE HILDYARD: Do you understand that? Yes.

3 MRS ARKHANGELSKAYA: I spoke with my client adviser, bank

4 employee, or clerk. We drew up a document and I have

5 disclosed a scan of this document. This is the last

6 page of the exhibits to the affidavit, the last page of

7 the annexes.

8 Now, Mrs Volkanova merely drew this piece of paper

9 up and she entered the necessary data into the computer.

10 Then I understood the day before yesterday, the bank

11 employee spoke with the head office in Paris, spoke with

12 the people who are in charge of Assurance Vie life

13 insurance. That information went to Paris and the head

14 office did not allow that money to be credited to my

15 current account.

16 MR ARKHANGELSKY: But from what Mrs Volkanova told us, as of

17 the 12th when she was drawing this up, there were no

18 encumbrances, there were no constraints, no limits. We

19 have this piece of paper in front of us and this was

20 signed by the bank so they simply had to process this.

21 The only problem is realising the money takes

22 between two and four weeks depending on where the bank

23 had actually invested those funds, and the bank usually

24 does not allow us to have copies of these documents if

25 there are some encumbrances or freezing orders. This is

70 :1 a formal piece of paper signed by the bank which says
2 that the sale of part of the insurance policy has

3 actually been processed by the bank.

4 MR JUSTICE HILDYARD: Well, I am not sure I fully follow,

5 but lest Société Générale be in any doubt, whether at

6 head office or at local level, the freezing order of

7 2012 continues in full force and effect, subject only to

8 the consent order which is to be agreed to enable the

9 payment of the 75,000. I cannot determine what their

10 computer systems are, but it would be a source of

11 concern to me if they were at any level, as I say,

12 whether at head office or branch or at any other level,

13 not registering the English freezing order which, as

14 I understand it, is required to be given effect in

15 France as well as here.

16 MR LORD: My Lord, can I just pick up on that?

17 Your Lordship is right on paragraph 14, but if one looks

18 at 14 through to 17, and particularly in the light of

19 what Mrs Arkhangelskaya has just told your Lordship —

20 MR JUSTICE HILDYARD: Yes.

21 MR LORD: — it seems to be the position that at local

22 level, that a certain operative at Société Générale

23 seems to have agreed a certain position as to money

24 disbursements, and when this person left, the successor

25 person didn’t think that that was actually going to be

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71 :1 permissible under the injunction. So it does — these
2 paragraphs do call for some explanation, because one

3 wouldn’t have expected that degree of uncertainty, shall

4 I put it neutrally at the moment. If Mr Arkhangelsky

5 has been speaking to a local bank representative and

6 a certain position has been taken on whether a freezing

7 injunction applies, then that is something that calls

8 for explanation, and that should be covered in

9 the affidavit.

10 MR JUSTICE HILDYARD: We will examine this when we have had

11 the full run of accounting information, because I think

12 that that will provide the proof of any pudding which is

13 required.

14 But I say, as clearly as I hope I can, that whether

15 at head office level, local level, branch level or

16 otherwise, the English order is in force, the English

17 freezing order is in force, it is subject only to

18 the exceptions to which reference is made within that

19 order, and to the consent order which is to be agreed

20 pursuant to today’s hearing, and I do not expect

21 a difference of view such as has been intimated may be

22 adopted at local level to affect or deprive the English

23 order of the substantive effect which France accords to

24 it.

25 Yes. Mr and Mrs Arkhangelsky, I’m grateful to you.

72 :1 I’m sorry that in the way I approached it I initially
2 seemed to have encouraged a great deal of emotion. I am

3 glad that that has been largely dispelled. I hope that

4 this will enable you to cover the expenses which you are

5 required to cover, and I leave all further comment and

6 matters to any other issues which they relate to at some

7 subsequent time, but not today.

8 I am grateful to you for your attendance, and I hope

9 the feed was sufficient in terms of enabling you to

10 understand what was going on.

11 MR LORD: My Lord, I see the time. There are, obviously,

12 some other items of housekeeping. That was obviously

13 the main point, but there are some other items on this

14 list.

15 MR JUSTICE HILDYARD: Yes. Are these matters which are best

16 dealt with with Mr Stroilov, or are they matters which

17 you wish to address, and feel it right to address, now?

18 MR LORD: Well, number 2 I think has probably been —

19 I think number 2 is probably something that could be

20 tacked onto the order without further argument, I would

21 hope. Does your Lordship have the aide-memoire?

22 Number 2 is the breakdown for the expenses, but I think

23 your Lordship has in mind some sort of validation

24 process that would pick that up, but that was the

25 expenses for Paris.

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73 :1 MR JUSTICE HILDYARD: Well, they have gone from 15,000 to
2 17,000, and I think probably you need to show some small

3 description of how that is.

4 MR LORD: So, my Lord, I think 2 doesn’t need to trouble

5 your Lordship.

6 MR JUSTICE HILDYARD: No.

7 MR LORD: 3 —

8 MR ARKHANGELSKY: Your Lordship, I have provided all the

9 description in the maximum available form this morning.

10 MR JUSTICE HILDYARD: Okay, well I think Mr Lord is not

11 asking me to do anything further.

12 MR LORD: 3, my Lord, is the protocol, and Mr Stroilov made

13 a couple of points by his e-mail. That may be

14 something, I think your Lordship has rightly observed,

15 that has to be picked up with him. I was conscious that

16 your Lordship wanted this cleared away for good order,

17 but I am sure it could be deferred to next week.

18 4 was the pleading point. Well, your Lordship will

19 recollect what was said on the Thursday and Friday.

20 MR JUSTICE HILDYARD: The thing is, he doesn’t quite —

21 Mr Stroilov doesn’t quite agree with every aspect of

22 your letter and I think you will have to leave that to

23 him.

24 MR LORD: Yes, I see that, my Lord, so that’s one to be

25 deferred.

74 :1 Number 5. My Lord, the only question on 5 is that
2 time is ticking, in terms of getting material out of

3 various sources. We would not want to be told that

4 actually when various witnesses come to be

5 cross-examined that actually it is too late, and now

6 everyone agrees that this should be in play, it is too

7 late to get it in play. I don’t know whether the

8 defendants can help with that. We are told that

9 Mr Nazarov is just not assisting, and it is —

10 MR ARKHANGELSKY: I am very sorry, what document is being

11 discussed currently? We do not quite understand.

12 MR JUSTICE HILDYARD: Was this not sent?

13 MR ARKHANGELSKY: Which document is being discussed?

14 MR LORD: It was sent last night, actually, sorry, it is my

15 fault. It is the aide-memoire. I think it was sent by

16 e-mail to you last night.

17 MR ARKHANGELSKY: My Lord, unfortunately I haven’t received

18 anything last night. Perhaps it was sent in the middle

19 of the night. Unfortunately I haven’t read this

20 document and could I please be released from discussion

21 so as not to have any bias. Unfortunately I haven’t

22 read such a document, I wouldn’t be able to comment

23 thereupon. Could that please be deferred until Monday

24 when Mr Stroilov will be in court?

25 MR LORD: {I21/28/4}.

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75 :1 MR JUSTICE HILDYARD: They say they haven’t read it. I’m
2 going to leave it there. I’m going to allow Mr Stroilov

3 to readdress this. I’m going to say this, though: that

4 my understanding is that Mr Nazarov was, and possibly

5 is, your Russian lawyer.

6 MR LORD: And a witness coming —

7 MR JUSTICE HILDYARD: And he is to attend to be

8 cross-examined. I know that I am told that he is a busy

9 man. That probably is a description which applies to

10 pretty much everyone involved in the case. If he wishes

11 to assist the court, he really must provide these

12 documents in good time for him to be questioned

13 properly, and for him to be able to provide good and

14 complete answers.

15 MR LORD: My Lord, the only other point really I would ask

16 your Lordship to flag up, this will take a minute —

17 MR ARKHANGELSKY: My Lord, we employ all the efforts, we and

18 Mr Stroilov, in order for Mr Nazarov to submit these

19 documents, and we endeavour to do our utmost for him to

20 come to London and to be cross-examined. We do

21 everything within our powers, and if necessary,

22 Mr Stroilov will provide all the correspondence

23 available; we just have to understand that Mr Nazarov

24 hasn’t been receiving any payment for many years for his

25 efforts, and therefore his priorities are given to his

76 :1 family and his current work. He has a young child,
2 recently they had a new baby, and his wife doesn’t work,

3 I hope you understand that; and we, on our part, employ

4 all the possible efforts because it is in our interests

5 for him to come and provide the documents and his

6 evidence, without a doubt.

7 MR JUSTICE HILDYARD: I understand that, but that is partly

8 my reason for expressing it in this way. I do not

9 attach blame to you in this. I don’t exonerate anybody.

10 I just say, so that Mr Nazarov can, if necessary, be

11 shown a copy and translation of the transcript, that as

12 he has — and I welcome this — agreed to attend as

13 a witness and as he has been giving you advice in

14 the past, the court would ask him expressly to make

15 available these documents as soon as possible and before

16 he goes into the witness box.

17 MR LORD: And, my Lord, it appears to be Mr Arkhangelsky is

18 offering to provide the correspondence. That would be

19 of some reassurance. And, secondly, to confirm that

20 Mr Nazarov has been sent — because this is at least the

21 second, if not the third time, your Lordship has given

22 this direction — to show that this direction has been

23 passed on, it would be a question of printing off the

24 page in the transcript —

25 MR JUSTICE HILDYARD: I will not make a direction for the

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77 :1 production of this correspondence, but the defendants
2 may very well think that they should provide it in order

3 to explain why he is not, if he continues not, to

4 provide the documents. I will leave it to them to

5 discuss. I shall not make a direction. It is really

6 a matter for them.

7 MR LORD: Very well, my Lord.

8 Then item 6 were the questions about the mirror

9 companies and about City Centre, and I am sure the

10 message got through, but I can’t remember whether

11 Mr Arkhangelsky was — I think he was present last week,

12 I can’t remember though, when your Lordship indicated —

13 I think he had gone, it was in the afternoon, actually,

14 I think that’s right, he was there for the morning but

15 not the afternoon.

16 MR JUSTICE HILDYARD: Perhaps the thing to do, Mr Lord,

17 Mr Arkhangelsky, is for you to be directed to the part

18 of the transcript, whether you were there or whether you

19 were not there, where these mirror companies were

20 discussed and where it was agreed or directed that

21 details be provided with the request from me that they

22 should now be provided, the details which were

23 identified, without further delay.

24 MR LORD: And your Lordship indicated that you wouldn’t

25 order it, but you would hope it would be provided and it

78 :1 may be in the Arkhangelskys’ interests to provide that
2 information in a written form.

3 So, provided that message has gone home —

4 MR JUSTICE HILDYARD: I remember it now. I’m sorry. I am

5 not making a direction now either, but I think

6 Mr Stroilov suggested that this be a matter which might

7 usefully be done in cross-examination or in

8 examination-in-chief. My suggestion was that it might

9 be better from your point of view to have explained it

10 in a careful and considered way rather than have to

11 cover it all in examination, and I still think that that

12 is likely to be in your interests, although, of course,

13 I leave it to you. I do not make a direction.

14 But the request has been made, and if it is not

15 fulfilled, that will be a matter of comment, you may be

16 sure.

17 MR LORD: Also, my Lord, I suppose almost my greater concern

18 is that when I get to cross-examine Mr Arkhangelsky,

19 that he has acquainted himself with these questions and

20 these documents, which are all his own accounts and so

21 on, so that we can proceed with dispatch of

22 the questioning, and I am not told, your Lordship is not

23 told, that he has not had time to look at this, because

24 we are giving him some warning, because some of these

25 points, you need to look at the accounts and therefore

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79 :1 many weeks are going by now and I am conscious that for
2 Paris to be effective, we need to make good progress,

3 and therefore —

4 MR JUSTICE HILDYARD: I’m not going to say any more than

5 this: that as I remarked on the previous occasion, you

6 are to be examined and one of the subjects on which you

7 are to be examined has been identified for you so that

8 you can prepare yourself properly. That’s an advantage

9 to you to have it identified for you, but of course it

10 does give you the responsibility of doing your homework

11 in this regard.

12 MR LORD: My Lord, there is one other final point.

13 (Handed).

14 My Lord, the translators, I think, are anxious to

15 show that there was not a mistranslation yesterday. The

16 witness in fact may have misspoken, I think there was

17 a general agreement — sorry, my Lord, it was the point

18 about the guarantee or pledge. I am sorry my Lord, it

19 is my fault, I am being too quick.

20 Upon re-listening to the audio the translators are

21 happy that — well, the words that were used were as

22 they are —

23 MR JUSTICE HILDYARD: That is might have been misspoken.

24 MR LORD: — and in fact, it was more likely — it’s not

25 them now, it is me saying, it appears to be the witness

80 :1 may have used the wrong word, but obviously context is
2 not for the interpreters, so they are reasonably happy

3 that they have translated it faithfully and they are

4 anxious that the record doesn’t show that they have made

5 a mistake, and that the transcription record is as they

6 think it should be transcribed, even if the answer may

7 not have been exactly right as the witness gave it.

8 MR JUSTICE HILDYARD: I don’t know whether this has been

9 circulated to the other side?

10 MR LORD: It has, yes.

11 MR JUSTICE HILDYARD: There we are, subject to anything that

12 Mr and Mrs Arkhangelsky wish to comment on points just

13 raised, that leaves only the question of the continued

14 chatter about this case. I will not say anything more

15 about that since it appears to have emanated from

16 Mr Stroilov. Of course people can comment on a case,

17 but when they do so, they have to deploy such care,

18 given that the matter is sub judice, that most people

19 prefer not to. So it is a great big red flag that I am

20 raising.

21 MR LORD: Thank you, my Lord.

22 MR JUSTICE HILDYARD: Right, Mr and Mrs Arkhangelsky, is

23 there anything further you wish me to understand at the

24 moment relating to what Mr Lord has been speaking about?

25 MR ARKHANGELSKY: Yes, my Lord, if I may, to spend two brief

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81 :1 couple of minutes. I would like to comment upon my
2 acquaintances and friends commenting on the case in

3 the UK.

4 Firstly, indeed I have organised a press service.

5 My old friend Natalya Khmelik who, indeed, is the mother

6 of Pavel Stroilov, but was not connected to him in any

7 way in current life, she lives in Israel. She follows

8 the painstaking work of her son, and offered me, purely

9 pro bono, without payment, to assist me in sorting out

10 the transcripts of the hearings and being

11 a professional, she is a very professional journalist

12 known in Russia, to make professional press releases in

13 the form that she sees fit.

14 Taking into account your comments, and also absence

15 of time, my time and Mr Stroilov’s, we cannot answer any

16 journalists’ requests with him. Therefore we have asked

17 anyone who follows my fate, anyone who follows this

18 case, to address any issues to a known professional

19 qualified journalist, Mrs Natalya Khmelik.

20 Of course there were complaints that — of course,

21 taking into account the fact that on the part of

22 the Bank there were complaints that I was too emotional

23 in my approach, and formulate my words too emotionally,

24 therefore I, having heeded your order and your advice,

25 my Lord, I have completely stopped any communication

82 :1 with journalists and my valuations of the case, and
2 I asked a professional journalist who is well known in

3 Russia and abroad to read the transcripts, and should

4 she deem that it is possible to formulate and

5 communicate to the public certain things, for her to do

6 so.

7 As far as I understand, the essence of the case, the

8 case is heard in open, and the comments on the case, the

9 coverage of the case, is only welcome.

10 Just before the hearing I had a call from a business

11 novosti(?) agency in St Petersburg, a journalist who

12 follows the case and publishes a lot on the case, and he

13 said that in Russia journalists of the publication are

14 intimidated by the police and the Bank of St Petersburg,

15 because everyone understands that this case touches upon

16 not just Mr Savelyev and the Bank, but the first persons

17 in the State.

18 My Lord is aware that we offered mediation to

19 the Bank —

20 MR JUSTICE HILDYARD: Yes, we are now going beyond, I think,

21 anything which is necessary.

22 MR ARKHANGELSKY: In principle, that would be all I wanted

23 to say.

24 MR JUSTICE HILDYARD: Yes, I am grateful to you.

25 You are quite right, Mr Arkhangelsky: these are

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83 :1 proceedings in open court. What people decide to say
2 about them, subject, obviously, to rules of defamation,

3 are what they decide to say about them.

4 It is not impermissible, as I understand it, and if

5 I am wrong I would want to be corrected, provided the

6 court knows it is happening, even for transcripts to be

7 made available, and that is a growing practice, but only

8 with the permission of the court if the court’s own

9 services are being deployed.

10 It is an awkward matter if you are in connection

11 with people who are speaking on your behalf, lest they

12 say things which are considered not right to be said

13 when a matter is sub judice, so they proceed at their

14 own peril.

15 So far as Mr Stroilov’s mother is concerned, she may

16 feel in a particular difficulty, lest she cause

17 embarrassment to her son, but I must leave it at that.

18 MR LORD: My Lord, just one point. We understood that

19 a radio interview was given yesterday.

20 MR JUSTICE HILDYARD: Right.

21 MR LORD: The last answer seemed to imply that nothing had

22 been done by him except through Mr Stroilov’s mother.

23 Again, if I am wrong, I will be corrected, but if he did

24 give a radio interview yesterday, then the last

25 submission really should be qualified in that regard.

84 :1 MR JUSTICE HILDYARD: Yes, but, Mr Lord, I don’t want to be
2 seen implicitly or otherwise —

3 MR ARKHANGELSKY: My Lord, my Lord —

4 MR LORD: I’m not at all — I didn’t ask your Lordship to

5 make any directions. Mr Arkhangelsky will say what he

6 says and there will be the laws of defamation,

7 your Lordship is right, but I do think it is appropriate

8 to draw your Lordship’s question to that when questions

9 of conduct and resource are being debated, whether

10 people have a spare minute to do anything else other

11 than eat a boiled egg and get on with their

12 cross-examination notes, if you are giving radio

13 interviews and you are mounting PR — you are doing

14 collages of the characters in the thing on your own

15 website and so on, that’s coming down the line. I’m

16 going to be asking this witness about all of that.

17 He can do what he likes really, but whether I think it

18 appropriate or not is irrelevant. It may not really be

19 appropriate but it is not unlawful, but it is right that

20 he knows, your Lordship knows as the trial judge, that’s

21 going on, apprised of it for case management factors,

22 not any muzzling purposes —

23 MR JUSTICE HILDYARD: Well, there you are. There is the

24 warning. I am not going to say any more about it.

25 MR LORD: Thank you, my Lord.

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

85 :1 MR JUSTICE HILDYARD: Mr and Mrs Arkhangelsky, anything
2 else?

3 MR ARKHANGELSKY: We are very grateful, my Lord, for quite

4 a productive proceedings today. This is our first

5 experience of being litigants in person. We are very

6 grateful.

7 MR JUSTICE HILDYARD: Not at all. Thank you for attending.

8 Now, Monday, we are not sitting tomorrow.

9 MR LORD: No.

10 MR JUSTICE HILDYARD: Some homework can be done in the

11 meantime. I am assuming we will start with the witness,

12 10.30 on Monday, with Mr Guz. If there were any change

13 in that, I would want to be told as soon as possible.

14 MR LORD: Yes, my Lord.

15 MR JUSTICE HILDYARD: I should mention one thing, which is

16 it is likely, during the course of next week, that

17 I have to hear another matter for an hour, which I will

18 have listed at 9.30 am, and which I will hope to

19 conclude by 10.30 am. That may, nevertheless, lead to

20 some delay, because of the transcribers having to get

21 everything fitted up.

22 So I just give you warning: as soon as we know the

23 day, we will let you know. If we can slot it into

24 a break day that will be better, but I have not yet

25 heard whether that break day will be after Mr Guz or on

86 :1 the Friday, and it would greatly assist me — and I make
2 this point from Mr Stroilov’s point of view — my clerk

3 has provided the obvious solution, which I should have

4 thought of, which is we will do this in another court so

5 as not to discombobulate you.

6 MR LORD: My Lord, can the listing — it maybe has to be

7 done sooner this, but of course we will know better by

8 Monday at 2.00, let’s say, what Mr Stroilov plans and

9 whether we might finish such that the slot will be on

10 Wednesday —

11 MR JUSTICE HILDYARD: If it can be on a day where we are not

12 sitting in this case, that would be nicer for everybody,

13 but it may be that counsel’s availability militates

14 against that.

15 MR LORD: I understand.

16 MR JUSTICE HILDYARD: I am very grateful for your

17 attendance, everybody. Thank you very much.

18 (1.23 pm)

19 (The court adjourned until 10.30 am on
20 Monday, 8 February 2016)

20

21

22

23

24

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Bank St Petersburg v Vitaly Day 6

Arkhangelsky [Master]

87 :1

2

3

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

0

88 :1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

INDEX

PAGE

Housekeeping 1

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adopted71:22
45:25 61:24 67:19
54:20 84:7 84:18

$ adumbrated, ( 2 ) 47:18
78:17 81:14
84:19

48:14
alter29:25
approve,48:12

advantage79:8
alternative5:1
approved48:13

$70024:16

advice ( 4 ) 8:10 8:23
although ( 4 ) 5:18
approximate ( 2 ) 4:19

76:13 81:24
44:18 47:18 78:12
36:13

— advisedly54:5
always45:10
Approximately, ( 2 )
adviser, ( 2 ) 68:17 69:3
Ameli, ( 4 ) 14:4 28:14
17:1 53:19

—I62:3
advocacy51:5
33:5 40:12
April, ( 3 ) 35:16 63:13

advocates,60:15
ameliorating3:14
64:25

A affect ( 2 ) 44:21 71:22
amongst ( 2 ) 25:18
archive,57:1

affects43:20
45:4
argument ( 2 ) 58:19

affidavit ( 47 ) 3:3 9:5
amount ( 22 ) 11:17
72:20

above ( 2 ) 32:19 64:10
9:14 10:23 11:8 12:4
13:23 14:6 14:16 17:9
arise. ( 4 ) 3:6 10:12

12:6 12:7 13:18 23:11
17:11 17:12 17:18
42:20 48:18

abroad82:3

30:16 30:23 33:6 35:5
17:21 19:14 20:11
arises ( 2 ) 27:4 44:6

absence ( 2 ) 4:11 81:14

42:21 43:7 44:3 49:16
22:13 24:1 32:22 35:8
arising ( 3 ) 11:8 50:22

absolutely ( 14 ) 11:22

50:12 51:1 51:10
35:18 36:20 36:22
50:23

12:12 12:17 17:24

52:16 53:9 53:20
41:8 54:7 65:3 66:20
Arkhangelskaya ( 41 )
21:21 26:20 34:9 38:5

55:16 57:18 58:9 59:8
amounts ( 10 ) 19:18
5:7 5:13 5:19 6:10

39:24 42:11 46:13

62:1 62:9 62:10 62:19
19:23 22:4 27:20 28:6
12:22 13:2 14:15

59:15 64:13 65:4

62:20 62:25 64:16
28:8 39:3 39:24 42:5
15:25 16:21 17:15

absorb9:25

64:17 64:22 64:25
66:1
35:15 36:13 36:21

accept ( 5 ) 28:21 43:17

65:6 65:21 66:7 66:12
analysis30:22
36:23 37:2 37:6 37:9

46:19 51:8 53:1

67:6 67:25 68:14 69:6
Ancillary45:8
37:16 45:22 46:13

accepted28:22

71:9
and/or54:1
46:21 47:13 53:12

accepting32:6

affidavits ( 3 ) 51:1
annexes.69:7
57:10 57:19 57:24

accomplished68:19

55:16 59:20
another ( 4 ) 27:3 34:22
59:13 60:5 60:7 60:24

accordance ( 3 ) 11:24

afford ( 5 ) 23:18 24:20
85:17 86:4
61:7 61:17 62:17

13:8 13:15

25:7 39:11 40:19
answer ( 4 ) 27:16 80:6
62:19 63:9 65:4 65:8

according ( 2 ) 5:11

afraid ( 7 ) 23:15 26:9
81:15 83:21
66:13 69:1 69:3 70:19

36:7

31:2 34:22 45:2 51:10
answered.27:18
Arkhangelskaya’s ( 2 )
accords71:23

64:14
answers.75:14
12:6 64:21

account, ( 13 ) 13:6

after ( 5 ) 16:20 17:12
anticipated48:18
Arkhangelsky. ( 81 )
17:14 17:24 19:11

35:13 46:11 85:25
anxious ( 5 ) 18:14
1:6 1:7 3:10 3:12 3:17

20:25 41:14 46:4

aftermath,48:10
45:23 62:17 79:14
3:19 3:23 4:5 4:21

63:19 63:20 64:1

afternoon, ( 2 ) 77:13
80:4
5:5 5:8 5:23 6:6 6:11

69:15 81:14 81:21

77:15
anybody.76:9
6:12 11:15 11:22 12:3

accountant,24:17

again. ( 8 ) 4:11 20:20
Anyone ( 3 ) 32:24
12:12 12:17 12:23

accounting ( 2 ) 50:20

36:8 46:20 47:19
81:17 81:17
14:10 14:24 16:23

71:11

51:25 62:4 83:23
anything ( 15 ) 15:24
17:1 17:6 17:20 18:21

accounts ( 37 ) 12:20

against ( 5 ) 15:13
18:14 21:17 39:23
19:4 21:1 21:18 23:18

30:24 38:2 38:5 38:8

15:23 32:4 33:14
49:19 50:11 54:4
32:16 34:12 36:24

38:9 38:10 38:13

86:14
73:11 74:18 80:11
38:5 38:9 38:14 39:24

38:25 39:25 50:6

agency ( 2 ) 68:19 82:11
80:14 80:23 82:21
40:9 40:15 40:20 42:6

50:17 53:5 54:11

agenda1:12 84:10 85:1
42:11 44:16 45:18

54:22 58:12 58:13

ago, ( 4 ) 18:19 18:21
anyway. ( 3 ) 23:7 42:4
45:19 45:25 46:24

58:14 58:25 59:3

40:20 40:21
58:17
49:1 51:20 53:6 56:3

59:19 59:24 60:19

agree ( 8 ) 21:22 22:1
anywhere ( 4 ) 35:21
56:10 57:9 61:24 62:5

65:14 65:17 66:5 66:8

66:10 66:16 66:16
30:13 31:19 31:20
36:9 63:23 65:8
62:21 63:14 66:9

31:23 33:9 73:21
apart ( 3 ) 58:4 61:23
69:16 71:4 71:25 73:8

66:17 66:17 66:25

agreeable ( 4 ) 41:24
67:7
74:10 74:13 74:17

67:4 67:7 78:20 78:25

accumulates49:5
42:17 67:10 68:1
apartment. ( 10 ) 13:17
75:17 76:17 77:11

agreed ( 8 ) 20:23 32:4
13:18 13:20 13:22
77:17 78:18 80:12

accuracy,46:7

52:5 70:8 70:23 71:19
13:23 19:18 20:20
80:22 80:25 82:22

accurate ( 5 ) 42:22

76:12 77:20
36:11 36:19 37:5
82:25 84:3 84:5 85:1

43:12 46:5 46:12 47:4

agreeing32:7
apologies ( 2 ) 43:16
85:3

accusations ( 2 ) 33:7
agreement79:17
61:7
Arkhangelsky’s ( 2 )
33:13

agrees74:6
apologise30:10
3:4 9:6

accused19:1

aide-memoire, ( 4 ) 1:11 appear ( 5 ) 10:17 19:9
Arkhangelskys. ( 9 )
acknowledge,35:2

6:23 72:21 74:15
25:4 47:4 50:17
9:15 19:13 48:18 50:9

acknowledged. ( 2 )
air14:8
appears, ( 5 ) 10:23
54:18 55:10 55:23

22:10 50:13

alarm45:16
21:4 76:17 79:25
56:19 78:1

acquaintances81:2

alert52:15
80:15
around ( 5 ) 14:5 22:21

acquainted78:19

allegation19:5
applicant’s8:12
29:5 29:12 35:17

acquisition15:8

allegations34:21
application ( 3 ) 5:20
arrangements51:6

acting40:13

alleged ( 2 ) 42:24 43:17
28:4 52:5
arrears37:7

actual ( 2 ) 39:3 47:11

allow ( 7 ) 55:1 57:19
applies ( 4 ) 8:14 51:21
arrive ( 2 ) 37:22 41:4

additional ( 4 ) 51:11

64:11 66:19 69:14
71:7 75:9
Article ( 2 ) 10:21 24:19

52:2 53:3 61:22

69:24 75:2
apply ( 2 ) 8:22 51:22
articles7:5

address ( 7 ) 32:14

allowed ( 2 ) 24:16
applying8:18
ASAP48:9

52:24 57:21 58:20

43:23
appointment36:2
ascertained40:18

72:17 72:17 81:18

allows ( 2 ) 20:16 24:14
apprised84:21
ascribed25:19

addressed ( 2 ) 11:19

Almost ( 2 ) 43:15 78:17
apprising50:9
ask ( 14 ) 13:9 15:25

67:17

already ( 7 ) 16:19 26:4
approach. ( 2 ) 11:6
18:7 49:1 49:7 53:12

adds29:5

31:12 44:12 57:21
81:23
57:7 60:13 60:16

adept43:18

60:1 65:18
approached72:1
66:21 67:15 75:15

adjourned86:19

also ( 20 ) 1:15 2:15 3:3
appropriate ( 11 ) 9:22
76:14 84:4

adjudicate24:25

5:25 8:10 13:10 14:15
20:18 24:5 29:14
asked ( 7 ) 18:16 30:4

administration,22:12

14:24 17:20 19:9 27:9
49:15 50:25 51:4
41:23 47:6 65:20

administrative54:16

38:14 39:20 42:1 45:8
81:16 82:2

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asking, ( 7 ) 3:13 13:14 36:5 37:5 41:12 73:11 84:16

asks43:14

aspect ( 2 ) 10:1 73:21 aspects. ( 2 ) 10:5 22:5 asset ( 7 ) 21:24 23:17 25:15 27:9 30:19
54:21 58:5

assets ( 19 ) 2:12 10:13 10:17 21:10 29:7 29:20 29:21 29:24 30:16 30:18 38:19 49:16 51:1 55:10 55:18 55:24 58:4 58:6 59:24

assigned61:12 assist ( 5 ) 6:15 34:14

75:11 81:9 86:1 assistance56:17 assisting,74:9 associates ( 2 ) 22:20
60:21

assume, ( 3 ) 3:19 3:21 53:20

assumed, ( 2 ) 25:22 25:23

assuming85:11 assumption23:10 assurance, ( 3 ) 35:19
61:18 69:12

attach ( 3 ) 25:4 28:12 76:9

attack6:19

attempt ( 2 ) 15:13 24:8 attempts15:11

attend ( 4 ) 40:19 56:10 75:7 76:12

attendance ( 4 ) 5:12 44:20 72:8 86:17

attending.85:7 attention. ( 7 ) 7:4 14:11

14:11 14:24 33:17 38:15 38:22

attest55:18 attitude,34:23 audience28:25 audio79:20 avail.64:13 availability86:13 available ( 17 ) 2:13
10:2 10:17 10:22 24:2 24:9 42:23 45:5 48:15 50:21 58:10 58:17 61:23 73:9 75:23 76:15 83:7

avoid ( 2 ) 5:24 42:8 await34:21 aware82:18

away, ( 5 ) 21:4 21:4 33:11 49:10 73:16

awful10:20 awkward83:10

B

baby,76:2

back ( 7 ) 4:22 10:11 15:4 18:21 22:19 23:22 60:1

back-up54:9 bail.61:21 balance39:3 balances,66:15

Bank ( 51 ) 15:12 17:7 17:16 17:21 18:1 18:25 20:25 24:15 30:24 34:9 35:21 35:25 40:3 46:18 46:25 47:22 48:17

50:4 50:17 51:3 54:11 54:21 54:23 55:19 58:12 58:15 58:22 60:19 64:12 65:14 66:5 66:7 66:9 66:21 66:25 67:2 67:7 68:22 68:24 69:3 69:10 69:20 69:22 69:23 70:1 70:3 71:5 81:22 82:14 82:16 82:19

Bank’s ( 2 )47:20 68:17 banks ( 2 ) 12:24 55:7

Barclay’s11:23

Barclays ( 10 ) 2:3 9:4

11:20 53:11 53:13 60:8 61:11 63:4 63:18 65:1

barristers’40:5

basis ( 10 ) 6:18 17:19 18:8 36:23 37:3 42:22 46:18 50:11 55:2 66:5

bear ( 3 ) 5:5 55:8 59:17 bearing28:24 become48:14

before ( 13 ) 6:22 8:11 9:8 9:20 20:16 35:20 47:6 47:6 67:22 68:3 69:10 76:15 82:10

beginning30:6 begs ( 4 ) 20:9 20:19
53:23 55:22

behalf ( 9 ) 9:14 15:11 41:1 55:4 55:17 58:3 59:22 61:14 83:11

behind ( 4 ) 2:8 22:23 48:4 62:11

Belief47:2

believe ( 4 ) 33:16 40:2 42:7 46:24

belittling56:5 belongs12:23

benefit ( 2 ) 57:14 67:16 bereft28:23

best ( 2 ) 48:24 72:15 better ( 6 ) 4:10 5:20

45:12 78:9 85:24 86:7 between ( 6 ) 35:22 36:9

47:8 56:7 65:9 69:22 beyond ( 4 ) 1:24 34:17

56:25 82:20 bias.74:21

Bidault, ( 7 ) 3:6 13:13 17:7 57:18 58:3 62:10 63:24

Bidault’s64:22

big ( 2 ) 65:19 80:19 biggest ( 2 ) 36:16
36:17

bills ( 4 ) 20:4 23:6 59:19 65:10

BIRT: ( 2 ) 4:11 6:6 bit, ( 6 ) 2:2 2:25 14:7

18:8 34:25 43:13 blame76:9 blighted12:9 block19:1 blocked ( 2 ) 17:19

17:21 blurry23:23 body29:6 boiled84:11

bono, ( 3 ) 40:15 40:18 81:9

both ( 6 ) 8:14 22:5 34:13 51:7 55:16 62:7

bottom ( 3 ) 10:25 11:4 56:13

bound39:7 box.76:16

branch ( 2 ) 70:12 71:15 breach2:17

break ( 2 ) 85:24 85:25
chase ( 2 ) 2:2 9:9
complain39:13
continued ( 2 ) 24:7

breakdown ( 9 ) 16:4
chatter80:14
complained43:1
80:13

16:8 16:13 18:19
cheaper13:20
complaint ( 4 ) 18:20
continues ( 2 ) 70:7

18:19 18:22 47:23
check46:7
43:8 51:25 56:21
77:3

47:24 72:22
checking ( 2 ) 17:14
complaints ( 5 ) 43:22
contrary58:20

breakdowns7:17
46:11
44:24 57:2 81:20
contributions.33:3

brief ( 2 ) 43:4 80:25
child,76:1
81:22
controlled28:9

briefly3:8
children ( 7 ) 14:19
complete ( 3 ) 50:11
conversion17:4

bring33:17
15:10 34:4 34:5 37:19
58:11 75:14
convoluted45:1

bringing21:17
37:25 39:19
completely ( 6 ) 4:20
cooperate45:10

broad19:11
choice: ( 6 ) 39:21
14:13 15:1 17:10
cooperative,64:13

broadly41:24
39:21 39:22 43:5
33:14 81:25
copies ( 2 ) 65:13 69:24

budget ( 2 ) 36:15 40:6
44:19 52:8
completeness, ( 2 ) copy ( 2 ) 58:12 76:11

builds48:21
choices ( 3 ) 44:18
6:21 7:3
corporate55:17

Bulgaria,33:19
44:19 51:13
comply ( 3 ) 34:10 60:3
correct, ( 4 ) 11:22

bundle ( 4 ) 1:15 1:18 chosen ( 4 ) 39:14 43:3
66:23
12:12 65:4 66:9

3:1 62:11
58:24 59:3
comprehensive47:5
corrected, ( 2 ) 83:5

burden ( 4 ) 23:25 27:19
circle10:11
computer ( 4 ) 68:22
83:23

29:25 43:21
circulated80:9
68:24 69:9 70:10
correspondence ( 6 )
burdensome ( 2 ) 55:21
circumstances6:13
concern ( 14 ) 3:12
19:16 48:12 64:12

55:22
City ( 3 ) 27:11 27:22
19:12 23:9 23:10
75:22 76:18 77:1

bureaucratic49:2
77:9
23:11 23:16 28:10
cost ( 3 ) 14:7 40:18

business ( 6 ) 7:9 15:1
claimants26:12
35:6 42:21 51:10 54:6
58:16

20:8 37:21 56:11
clarification ( 2 ) 6:14
56:21 70:11 78:17
costs. ( 3 ) 16:6 22:11

82:10
41:24
concerned. ( 6 ) 2:7
23:1

businesses.56:4
clarify ( 4 ) 16:17 18:5
25:1 31:15 32:11
counsel ( 4 ) 40:5 43:4

busy ( 2 ) 49:2 75:8
37:2 60:5
47:15 83:15
52:6 52:9

buy13:20
clarifying19:22
concerns. ( 13 ) 3:15
counsel’s86:13

BVI,33:19
clarity,17:2
9:12 11:2 11:7 18:12
counterclaim ( 3 ) 22:6

clean48:1
27:23 30:3 32:15
24:15 26:19

C clear, ( 9 ) 8:15 8:17
33:10 42:20 52:15
counterclaimant55:17

18:7 22:9 30:6 30:11
52:16 53:3
counterclaimants.
34:1 46:1 61:14
concise46:1
( 11 ) 24:10 24:20

calculate15:17

cleared73:16
conclude85:19
26:21 27:16 28:22

calculation41:4
clearly ( 5 ) 13:11 36:14
conclusion ( 2 ) 29:7
30:17 42:23 42:25

call ( 4 ) 24:16 40:25
48:21 50:8 71:14
29:9
49:17 55:4 55:16

71:2 82:10
clerical ( 2 ) 54:15 55:7
condition ( 2 ) 21:23
country32:24

calls ( 2 ) 44:3 71:7
clerk, ( 3 ) 36:2 69:4
30:15
couple ( 5 ) 2:9 36:13

can’t ( 10 )21:21 21:21
86:2
conditions47:17
36:15 73:13 81:1

24:20 26:23 50:14
client ( 2 ) 28:20 69:3
conduct ( 5 ) 43:21
coupled30:15

56:10 62:6 68:6 77:10
client’s28:18
50:24 51:6 55:4 84:9
course, ( 16 ) 19:10

77:12
clients ( 7 ) 9:24 15:2
conducted, ( 2 ) 43:23
20:22 25:2 25:5 28:16

candid ( 2 ) 44:23 55:9
24:12 25:22 28:21
50:16
38:16 51:4 58:19

candle. ( 2 ) 22:14 23:5
32:11 44:2
confirm ( 7 ) 6:8 58:4
68:16 78:12 79:9

cannot ( 8 ) 13:20 17:17
clock22:21
59:22 64:23 65:5
80:16 81:20 81:20

25:7 37:10 39:11 47:7
closed14:20
65:20 76:19
85:16 86:7

70:9 81:15
closeness7:16
confirmation ( 3 ) 60:4
court’s ( 5 )14:10 17:19

cap33:24
collages84:14
64:17 67:5
38:15 44:21 83:8

capability50:21
collate ( 2 ) 1:19 66:3
confirmed ( 3 ) 65:18
courts ( 2 ) 48:22 61:1

capacity50:20
collation,65:16
65:20 67:5
cover ( 6 ) 18:17 38:8

capital21:10
come ( 10 ) 7:7 8:13
connected, ( 2 ) 44:23
44:7 72:4 72:5 78:11

carapace43:19
15:4 36:3 49:22 62:15
81:6
coverage82:9

care,80:17
67:22 74:4 75:20 76:5
connection83:10
covered71:8

careful ( 2 ) 46:11 78:10
comes ( 4 ) 22:11 25:5
conscious ( 2 ) 73:15
covering54:24

carefully53:21
47:24 61:20
79:1
creating ( 2 ) 38:22

carrying25:14
comfortable ( 2 ) 4:16
consent ( 10 ) 10:9
46:25

cash; ( 2 ) 17:5 28:7
6:1
31:23 47:21 47:21
credited69:14

catch ( 2 ) 43:25 56:14
coming ( 4 ) 6:9 20:5
48:7 49:10 52:20
cried45:14

cause ( 4 ) 23:9 29:18
75:6 84:15
67:18 70:8 71:19
criticise52:10

42:21 83:16
comment ( 15 ) 12:25
consequence ( 2 ) 4:20
criticising ( 2 ) 45:11

cent, ( 3 ) 23:25 52:6
33:16 34:6 49:7 59:11
5:4
56:4

63:22
59:12 59:13 61:24
consequences27:5
cross62:24

Centre. ( 3 ) 27:11 27:22
64:3 72:5 74:22 78:15
consequent10:14
cross-examination ( 2 )
77:9
80:12 80:16 81:1
consider ( 2 ) 9:22
78:7 84:12

certain ( 12 ) 3:6 10:9
commentary15:5
15:21
cross-examine ( 2 )
16:6 28:6 34:9 34:19
commenting81:2
considerable56:16
68:3 78:18

38:22 47:22 70:22
comments ( 3 ) 51:19
consideration, ( 2 ) cross-examined ( 3 )
70:23 71:6 82:5
81:14 82:8
43:6 64:4
74:5 75:8 75:20

cetera,37:25
commercial33:18
considerations35:3
cross-examiner43:25

CFA ( 2 ) 52:6 52:6
commitments56:11
considered ( 3 ) 15:9
«cry45:15

chances15:3
communicate82:5
78:10 83:12
cumulative38:19

change ( 2 ) 32:21
communicates12:24
constant42:25
current ( 9 ) 10:4 13:6

85:12
communication ( 3 ) constraints,69:18
15:18 55:18 55:18

changed. ( 4 ) 19:4
7:15 7:17 81:25
construed ( 2 ) 8:17
68:17 69:15 76:1 81:7

59:25 61:21 66:10
companies ( 3 ) 27:10
8:21
currently ( 5 ) 7:1 15:1

changing36:25
77:9 77:19
contact, ( 2 ) 7:13 8:1
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characterisation30:9
company ( 4 ) 20:25
contained12:5
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characters84:14
27:22 40:25 41:5
contains19:20
cuts51:7

charge ( 2 ) 65:14 69:12
compared ( 2 ) 22:3
context80:1

charged66:1
66:11
continue,44:25

charges59:9
compartment,49:14

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daily, ( 3 ) 24:11 33:4 37:24

dare ( 2 ) 47:15 67:24 data69:9

date10:11 dates38:8

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days, ( 5 ) 20:15 59:18 66:19 68:1 68:7

deal ( 7 ) 1:9 10:11 11:9 30:3 30:18 65:19 72:2

dealing ( 4 ) 37:19 51:19 53:10 53:13

dealt ( 3 ) 42:14 46:17 72:16

debated,84:9

decide ( 3 ) 2:20 83:1 83:3

decided.57:22 deductions64:19 deem82:4 defamation, ( 2 ) 83:2
84:6 defeated23:7

defendants’ ( 10 )7:21 25:4 26:18 28:12 29:18 47:25 50:21 56:16 74:8 77:1

defer,4:10 deferred ( 3 ) 73:17

73:25 74:23 deficiency42:24 definitely ( 6 ) 35:17

59:15 60:3 64:6 66:23 66:23

defrayed,10:10 degree71:3

delay, ( 3 ) 3:13 77:23 85:20

delayed37:11 demands41:8 demonstrated ( 2 ) 29:8
46:4

depending ( 2 ) 17:23 69:22

depends26:2 deploy80:17 deployed ( 4 ) 51:11

52:2 52:9 83:9 deployment2:18 deponent53:10 deprive71:22 derail19:3 described ( 2 ) 13:12

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despite ( 3 ) 32:16 35:1 35:4

detachment,48:22 detail ( 4 ) 14:7 18:6

22:11 23:4 detailed16:13

details ( 3 ) 61:20 77:21 77:22

determine ( 4 ) 25:9 34:15 34:15 70:9

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dignity.33:21 directed ( 2 ) 77:17
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direction ( 10 ) 6:4 21:1 41:17 47:16 76:22 76:22 76:25 77:5 78:5 78:13

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67:12 67:13 disclosed ( 9 ) 12:10

13:5 14:6 25:18 29:5 38:20 58:5 67:1 69:5

disclosure ( 4 ) 12:4 25:16 25:16 38:21 discombobulate86:5

discrete ( 2 ) 34:15 41:12

discuss ( 3 ) 44:6 67:19 77:5

discussed ( 4 ) 38:17 74:11 74:13 77:20 discussing ( 3 ) 13:3

39:25 60:12 discussion ( 3 ) 21:24
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59:9 67:13 documents ( 17 ) 1:20

1:24 7:5 14:6 18:2 38:17 46:14 56:25 57:25 59:14 69:24 75:12 75:19 76:5 76:15 77:4 78:20

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force ( 3 ) 70:7 71:16

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62:3 62:4 63:11 74:7
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exercises67:17
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76:9 80:8 84:1
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54:10 65:21 69:6
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drafting.47:20
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drawing69:17
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{G1/7/6}. ( 2 ) 62:14

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possibly ( 3 ) 44:11
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