Mr. John O'Callaghan:

There is a distinction to be made. Discovery orders, which list items that are to be discovered, are complied with fully. For example, one was for the transcripts and recordings of the O'Higgins commission. The tribunal asked if it could have the transcripts and recordings and we provided them. A number of discovery orders of that type were made, asking for specific issues or records. They were discovered. On top of that, voluntary disclosure was made of other items which we had in our possession which were clearly relevant to the tribunal, for example, the O'Neill report which gave rise to the establishment of the tribunal, a number of section 41 reports and so on. Things clearly related to the establishment and business of the tribunal were discovered voluntarily. Other specific items were requested by the tribunal which were provided on foot of the discovery orders.