Mr. John O'Callaghan:

We discovered to the tribunal what it asked for and in respect of which it made discovery orders. We also discovered items that we had which we knew to be relevant to the tribunal, as in the papers that gave rise to its establishment and other ancillary papers that were around that issue. They were discovered to the tribunal. Things that were in the knowledge of the division of the people who were dealing with the Charleton tribunal and the issues which had given rise to it. The people who dealt directly with the establishment and the conduct of the O'Neill investigation, people who before that had dealt with the O'Higgins investigation. The people who were dealing with the discovery were individuals who were fully au fait with all the issues considered by Guerin, O'Higgins, O'Neill and, now, the disclosures tribunal. They knew the documents that were available and known to them.