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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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Dr Metters sent a memo to Dr Rejman confirming that he should provide a chronology and identification of documents as a "top priority".

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Dr Rejman advised he had gone through all of his files and was "part way through the official files held by Mr Burrage" relating to the period 1989-1991.

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David Burrage was a higher executive officer in the Department of Health's blood policy team.

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David Burrage was aware that volume 4 of the GEB/1 series of documents had been destroyed. He asked for the individuals responsible to write to him and confirm this.

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In his written statement to the Inquiry, David Burrage could not recall who the individuals were whom he believed had been responsible for the destruction of the GEB/1 volume 4 documents.

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GEB/1 Volume 4 was scheduled for branch review.

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The decision to destroy GEB/1 volume 4 was not only taken in advance of the review date, but the destruction date was also set in advance of that date.

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Dr Rejman looked at the "official GEB file series" list when compiling a discovery list.

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In his oral evidence to the Inquiry, Dr Rejman recognised that the files had been sent to the DRO and thought that perhaps David Burrage had had them recalled.

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Dr Rejman did not know what steps David Burrage took to get the GEB/1 files and provide them to him.

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During his oral evidence to the Inquiry, Dr Rejman's recollection was unclear as to whether files were recalled from the DRO or not.

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In her oral evidence to the Inquiry, Dr Rowena Jecock confirmed that the Department of Health did not have sight of the Archer Inquiry report before publication.

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Dr Rowena Jecock, the head of blood policy within the Department of Health, sent a note to the Minister of State for Public Health, Dawn Primarolo, summarising the report's recommendations and setting out the policy team's "Initial Reactions" to each of them.

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