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A memo regarding the discovery of documents in the HIV/haemophilia litigation noted that copies of Public Expenditure Survey bids from 1975 to 1986 were not held, and that it was understood that many (if not all) of these papers had been destroyed.

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Dr Roger Williams (expert at the DHSS) noted regarding the minutes of the Hepatitis Advisory Board (of which he was a member): "I have checked this out with administrators who believe that all these minutes have been destroyed".

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A memo noted that file 00134/0007 which was assumed destroyed (and therefore not included in the original list of documents to be disclosed) suddenly materialised.

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Anita James noted in a minute to the Permanent Secretary, Chris Kelly, that when litigation was contemplated in the mid 90s, Justin Fenwick QC had advised the Department of Health to "be prepared".

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A term of the settlement agreement recorded that all documents given to the plaintiffs by any defendant should be returned or destroyed within 28 days of settlement.

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John Canavan wrote regarding a request made by solicitors to use information from the HIV litigation in HIV infection via blood transfusion litigation and confirmed agreement that there would be "nothing to be gained by objecting".

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John Canavan wrote regarding HIV litigation documents being passed between solicitors firms: "I am concerned that we should keep firm control over who has access to the haemophilia litigation documents, as provided under the terms of settlement."

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A file note about the telephone attendance of solicitor acting for the CBLA with the plaintiff solicitor, Tony Mallen, noted that in relation to hepatitis claims: "no Plaintiffs have any claim against the CBLA."

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A court order allowed plaintiffs in the HIV litigation to use the documents disclosed by defendants to make claims in respect of hepatitis infections.

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Dr Andrzej Rejman asked John Canavan and Ronald Powell to ensure that any papers in respect of public interest immunity disclosures were kept secure and not destroyed.

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In a written statement, Carol Grayson stated that she gained access to Department of Health files disclosed during the HIV litigation and kept by the plaintiffs' solicitors.

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Dr Andrzej Rejman was a senior medical officer for haematology at the Department of Health.

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John Canavan was the head of the Department of Health section responsible for blood policy and the administrative secretary to the ACVSB.

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In the article "Testing Blood Donors for Non-A, Non-B Hepatitis: Irrational Perhaps But Inescapable" published in "The Lancet" in 1987, Professor Cash and other SNBTS regional transfusion directors foresaw the possibility of litigation under the Consumer Protection Act 1987 and similar European laws.

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In an internal memo it was asked for ACVSB papers to be retrieved to see whether an estimate was made of the numbers of people who might have been saved from Hepatitis C infections.

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In an internal memo Roger Scofield sought to initiate a discovery process to ascertain whether the Department of Health acted negligently in relation to blood supply and Hepatitis C infections.

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Charles Blake had been asked to make an assessment of the Department's liability in relation to Hepatitis C, but that "the papers we have do not assist us" and that a chronology of events or a "medical history" was required in order to do so.

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Roger Scofield identified the need to look for papers which related to possible negligence claims and that might "ridicule" the Department if exposed in public.

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Dr Rejman said it would be helpful to have departmental agreement on the "rules for discovering" the relevant papers.

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Dr Rejman sent a memo to Roger Scofield expressing his reluctance to undertake litigation discovery work without a formal instruction from Dr Metters.

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