Mr. John O'Callaghan:

The logic of that argument is that the tribunal could have asked us to give it anything with any mention of certain individuals, issues or topics. That would have resulted in us effectively dumping, for want of a better word, thousands upon thousands of documents at Dublin Castle and leaving it to the tribunal to go through them all and decide whether they were of any relevance. We provided to the tribunal both in terms of the discovery orders and voluntary discovery the items that we were aware of that were pertinent to the terms of reference both to the establishment of the tribunal and to matters relating to it. What the acting Secretary General has been talking about is this idea of everything we ever knew about anything related to the matters that are the subject of a tribunal, regardless of whether they are relevant to the terms of reference of the tribunal. I am not sure I would use the word "unfair", but I think it would not necessarily be helpful to the tribunal for us to do that.