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TRAN.022.0001 R COMMISSION OF INQUIRY INTO THE LOSS OF HMAS SYDNEY II Before The Hon TRH Cole AO RFD QC Held at level 5, 55 Market Street, Sydney Counsel Assisting: CMDR J Rush RFD QC RANR CAPT R McLAUGHLIN RAN LCDR P Kerr RANR LEUT J Nottle RAN Counsel Representing: CMDR J Renwick RANR On Monday, 19 January 2009 at 10am (Day 22) .19/1/09 (22) 1232 Transcripl produced by Merrill Legal Solulions

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Page 1: COMMISSION OF INQUIRY INTO THE LOSS OF HMAS SYDNEY II … · 2009-08-02 · Executive Officer in a patrol boat is the senior watch-keeper, but the navigation officer spends a lot

TRAN.022.0001 R

COMMISSION OF INQUIRY INTO THE LOSS OF HMAS SYDNEY II

Before The Hon TRH Cole AO RFD QC

Held at level 5, 55 Market Street, Sydney

Counsel Assisting: CMDR J Rush RFD QC RANRCAPT R McLAUGHLIN RANLCDR P Kerr RANRLEUT J Nottle RAN

Counsel Representing: CMDR J Renwick RANR

On Monday, 19 January 2009 at 10am(Day 22)

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TRAN.022.0002 R

Sir, with your permission, I call LEUT Rivett.

CAPT McLAUGHLIN: Q. LEUT Rivett, when did you join theRoyal Australian Navy?

CMDR RUSH: Sir, CAPT McLaughlin will take the first twowitnesses this morning, who are Navy serving officers, andthey will be followed, I anticipate, sir, by Mr Samuels andMr Karlov, who will be the witnesses for today.

In particular, CAPT Bairstow will provide comment asto the effects of the weather on initial positioning,reading signal flags, launching sea boats and the tacticalappreciation of remaining daylight. CAPT Bairstow will notcomment on the actual engagement, as that is not thepurpose of today's examination.

[10.03am]<SCOTT JAMES RIVETT, sworn:

<EXAMINATION BY CAPT McLAUGHLIN:

We will first hear from LEUT Scott Rivett, who is aRoyal Australian Navy seaman officer and meteorologist.LEUT Rivett has examined a range of weather-relatedmaterials submitted to the Commission of Inquiry. Inparticular, LEUT Rivett will provide evidence as to seastate and direction, wind speed and direction, the bearingof the sun and the time of sunset, and the impending phaseof the moon for 19 November 1941.

CAPT McLAUGHLIN: Commissioner, today we will hearevidence from two experts. This evidence will relate tothe weather pertaining at the time of the initialSydneylKormoran signalling interaction, and it will alsoaddress the effects of such weather conditions and theeffects they would have likely had on the tacticalappreciation by both ships of the situation theyencountered.

Following this, we will hear from CAPT WarrenBairstow, who is currently Commander, Surface Task Group atFleet Command. CAPT Bairstow is a very experienced seamanofficer and gunnery specialist. He has commanded bothpatrol boat and a WA-based major fleet unit. He hasexperience, including command experience, of the effects ofweather on tactical decision making off the coast ofWestern Australia.

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TRAN.022.0003 R

A. In January 1996, sir.

Q. Through what training establishment did you join?A. I joined at the Australian Defence Force Academy.

Q. How long did you spend at ADFA?A. Three years, completing a Bachelor of Science degree.

Q. What were your areas of specialisation in your sciencedegree?A. I majored in chemistry and politics and sub-majored inmathematics.

Q. After the Defence Academy, when you graduated, whatwas the next step in your training continuum?A. I proceeded through the junior warfare applicationcourse to HHAS Watson and various establishments aroundAustralia to train up through all four phases of the seamanofficer basic training, culminating in a BridgeWatch-Keeping Certificate.

Q. How long is this training continuum, culminating inthe award of a Bridge Watch-Keeping Certificate?A. It's one year to complete all the different phases -learning about relative velocity, ship identification,basic seamanship - and then anywhere between 6 months and18 months to be awarded a Bridge Watch-Keeping Certificate,depending on which ship you were sent to and how much seatime you got.

Q. What are the major components? You have mentioned acouple already. What are the major components of thistraining?A. All manner of identifying vessels, so you have tolearn to read flags, learn rudimentary reading of signallamps, ship handling, learn how to conduct boardingoperations. In ship handling, the key things are keepingthe ship safe and running activities within the ship, soyou are organising your people and your time.

Q. On completion of your training, when you achieve theBridge Watch-Keeping Certificate, what are you qualified todo?A. You are qualified to represent the Captain on thebridge and keep the ship safe by day or by night, incompany or not in company, also known as single shipsteaming, so you are responsible for the ship's safety.

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12 Q. After qualifying, where did you then serve?3 A. I served in HHAS Townsvi7le, a Cairns-based patrol4 boat, completed some work there and got my ticket. I then5 joined HHAS Canberra, which was a Western Australian based6 frigate, and served there for approximately nine months,7 doing various exercises and training. I was awarded my8 major fleet unit ticket on 11 September 2001.9

10 Q. By "ticket", you mean?11 A. A bridge watch-keeping certificate, sir, which is your12 entitlement to stand watch and represent the Captain.13 I then joined HHAS Newcastle, which was a Sydney-based14 frigate, and went to the Middle East for seven months doing15 work in the Gulf. When I completed that, I came back to do16 my navigation course for minor war vessel navigation and17 again posted to Cairns, this time joining HHAS Townsvi7le,18 and spent close to a year doing patrol boat operations out19 of there before going to Iraq for another seven months,20 training up the new Iraqi Navy and the Coalition Military21 Assistance Training Team.2223 Q. When you did your minor war vessel navigation24 training, is this a step further than the basic navigation25 training that a seaman officer does?26 A. It is, sir. As Navigator, you have a higher level of27 responsibility for maintenance of the chart outfit and to28 the Captain, and you are a more responsible member of the29 command team, and you also have a responsibility for30 training the junior warfare officers.3132 Q. Once you became qualified as a minor war vessel33 Navigator, you went on to serve in HHAS Townsville?34 A. That's correct, sir.3536 Q. What operations did you conduct whilst you were a37 Navigator of patrol boats?38 A. We conducted several patrols, ranging from Cairns to39 Broome, of the Australian Economic Exclusion Zone, for40 boarding operations, conducting boarding, doing basic41 patrol work, being involved in suspected illegal entry42 vessel apprehension, as well as the normal training, in43 company training as well, to improve the skill level of the44 junior warfare officers.4546 Q. As the Navigator on board a patrol boat, what is your47 role? What is your primary purpose?

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TRAN.022.0005 R

A. The primary purpose is as a senior watch-keeper. TheExecutive Officer in a patrol boat is the seniorwatch-keeper, but the navigation officer spends a lot moretime on the bridge, generally. Their primary purpose is tobe on the bridge, to run the bridge team, to keep the chartoutfit correct and to assist in the training of the juniorwarfare officers.

Q. What sorts of things do you, as a Navigator, do toassist in the training of the junior warfare officers?A. I think the key is to develop the appreciation of themanoeuvring of ships at sea, and that includes visualsignalling but also recognition of when a ship isaltering - learning what is going to happen if you changecourse in comparison to the relative movement of anothership. It is called developing a seaman's eye and it is allabout appreciating the distances between ships at sea.When there are no other indications of how far somethingis, you just learn - if the horizon sits at this pointrelative to the guns on a patrol boat, it means it is atthis range, so you are really learning your environmentaround you.

Q. Once you completed your time as Navigator of aFremantle class patrol boat, you said that you went to Iraqa second time?A. That's correct.

Q. What was your function or your role during thatdeployment?A. I was one of five lieutenants, Coalition. There weretwo Australians, and our role was to train up the newIraqi Navy both in theory, so in the classroom, and Relveland rules of the road.

Q. What is "Relvel"?A. Relative velocity. As I mentioned before, one of thefundamentals of being a seaman officer is to have a goodappreciation of the relative movement of ships at sea.Additionally, we taught the Iraqis boarding operations,towing operations and how to manoeuvre with small ships.

Q. Did you complete any sea time in Iraqi vessels duringthis period?A. We did, sir. We outfitted the boats. We sea trial ledthem before we transited them from Jebal Ali Port to Iraq.Then we spent another five months training the Iraqis both

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Q. Is the Navy meteorology qualification the same as ordifferent from that gained from the Bureau of Meteorology?A. It is an identical qualification, sir, and a lot of

Q. This is all part of developing what you referred to asa seaman's eye?A. Developing the seaman's eye, being aware of the ship'sroutines and how to keep the ship safe.

in the classroom and at sea. Probably every second day, wewould be at sea for the entire day. Unfortunately, ourrules of engagement meant that we couldn't go on liveoperations, but all the training and theory was exactly aswe would have taught anyone.

Q. How long is that course?A. It is 11 months long. The Navy conducts nine and ahalf months, which is the full requirement, and then whilstour civilian counterparts are learning about bushfireforecasts and things like that, we do a sea phase to alignourselves with the military requirements of finding yourenvironment.

Meteorology.

you achieved at the end ofWhat is the qualificationperiod of training?A Postgraduate Diploma in

Q.thatA.

Q. Where did you post on your return from Iraq?A. I posted to the Bridge Training Faculty at HHAS Watsonand I was the Junior Warfare Application Course Phase 4Training Officer, which meant that I organised the coursesfor the trainees to go on before they went out to ships atsea. We would do daytime watches and night-time watches ina bridge simulator and we would change the weatherconditions and change the number of contacts to try todevelop these trainees' appreciation of how the ship wasgoing to handle and things that they had to think about inrelation to rules of the road and keeping the ship safe.

Q. After your time at the Bridge Training Faculty, didyou go on to any further training or specialisations?A. Yes, sir. After two years at the training faculty,I then specialised as a meteorologist through the Bureau ofMeteorology, which is the only course you can do inAustralia to make you legally entitled to give a forecast.That is conducted, as I said, through the Bureau ofMeteorology in Melbourne and it's a postgraduate course.

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TRAN.022.0007 R

EXHIBIT #109 STATEMENT OF LEUT SCOTT JAMES RIVETT

Q. By Len van Burgel?A. Yes. It is a good one, because he also refers to two

Q. Your role there remains doing forecasting?A. Correct, sir. I continue doing forecasts.

Navy meteorologists move on, after a career in the Navy, toserve with the Bureau of Meteorology.

Sir, I tender that statement.

Q. I want now to move to the issue of weather conditionsoff the WA coast in November 1941. First, were you askedto prepare a statement for the Commission of Inquiry?A. Yes, I was, sir. I have typed up a writtensubmission.

Q. What is your current posting?A. I'm still with the Joint Headquarters Operations, andthat's now located in Bungendore in the new JointHeadquarters.

CAPT McLAUGHLIN:

CAPT McLAUGHLIN: Q. First, I want to look at thesources you used in preparing the statement. Whatdocuments did you examine in relation to preparing thestatement?A. Sir, I was able to access whatever I wanted from thearchives. The key things I wanted to look at were therouting charts and anything pertaining to charts orrecordings of weather on the day, but the most useful wasa 2008 report by --

Q. On completion of this, where did you post and whatsorts of duties did you undertake?A. I then posted to Headquarters Joint Operations, wherewe continued to provide what used to be known as fleetweather oceanography forecasts but are now JointOperations, because we also provide weather impactinformation to troops in Timor and personnel in Afghanistanas well .

Q. Is this a copy of that statement? (Shown) Would youconfirm that it is a true and correct copy of yourstatement?A. Yes, sir. That's my signature. That's my statement.

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TRAN.022.0008 R

EXHIBIT #113 PAPER ENTITLED "BACKTRACKING THE LIFEBOATS ANDFLOATS - A METOCEAN VIEW" BY MESSRS STEEDMAN AND McCORMACK

1991 studies done on the weather of the day. So that wasthe key document.

EXHIBIT #111 DOCUMENT ENTITLED "REPORT ON THEMETEOROLOGICAL CONDITIONS NEAR 26S 111E FOR 17-28 NOVEMBER1941" BY MR JOE COURTNEY OF THE BUREAU OF METEOROLOGY

EXHIBIT #112 DOCUMENT ENTITLED "CLIMATOLOGY OF WEATHERCONDITIONS W.A. WEST COAST NOVEMBER 1941" BYMR BOB SOUTHERN

We would also like to tender the finalwhich is a paper by Steedman and

Q. You have mentioned two methods that van Burgel hasused here - a mean sea level pressure analysis and thepattern matching. Could you please briefly describe orexplain each of those methods and what they aim to achieveor what the outcome of applying those methods is?A. Yes, sir. In the past, and certainly continuingtoday, depending on the size of the town, post offices or

CAPT McLAUGHLIN: Sir, we would like to tender the paperby Len van Burgel and the preliminary studies done byCourtney, Southern, Steedman and McCormack, whichvan Burgel used.

CAPT McLAUGHLIN: Q. What does the van Burgel paper goto?A. Sir, the key elements are that it reviews the 1991studies and compares them for suitability and accuracy andit highlights the methods used, the key method being in oneof the studies attempting to extend a mean sea levelpressure field and extrapolate that from observations alongthe Western Australian coast, and the other being a patternmatching method. The pattern matching method has become alot more accurate, because we can now correlate that withsatellite data of known wind fields that matchcorresponding conditions that were recorded on the day.

CAPT McLAUGHLIN:of those papers,McCormack.

EXHIBIT #110 STUDY ENTITLED "AN ANALYSIS OF WEATHERCONDITIONS OFF THE COAST OF SHARK BAY IN NOVEMBER 1941" BYJL VAN BURGEL

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TRAN.022.0009 R

1 pubs every day would record the temperature, the pressure2 and the wind. If you know certain characteristics of a3 body of air, being its temperature, humidity and the4 pressure, and you also know at what height that observation5 was taken, called a station level height, you can use a6 hydrostatic approximation and convert that to a mean sea7 level pressure. You could convert it to what the pressure8 would be at a kilometre. It wouldn't matter. It is9 following the equation.

1011 Once you have all these points converted to a mean sea12 level pressure, you can then try to match these points,13 kind of like joining dot to dot, to a corresponding chart.14 So if we know 10 different points that all have different15 values, we try to find a chart of a mean sea level pressure16 analysis that has been done in the last 40 years and say do17 we have another chart that corresponds to these same18 pressures? If we can find one, we can be very certain, on19 a synoptic scale, which is a large scale, that this is what20 we would have expected to have seen on the day.2122 The scale of this also comes into point, because the23 smaller scale and more localised you become, the more24 variance there is and less certainty. You can have the lee25 effect of a mountain or friction or additional heating that26 you may not have been able to take into account, but as27 soon as you take it to a large scale, these little flaws28 and errors smooth themselves out and you are going to get a29 very accurate picture, certainly to within a few degrees30 and a few knots, as to what the wind conditions would have31 been at a given time.3233 Q. What were van Burgel 's next steps in using this MSLP34 analysis? What did he then do with that?35 A. He then basically did a computer search of the entire36 Bureau of Meteorology archives and their archive called37 ADAM. That records conditions across Australia for all the38 records that we have. He compared those, using computers39 to do the fast calculations, with the conditions known on40 the day and identified what he believed to be the mean wind41 conditions.4243 He backed this up using what are called the44 Navier-Stokes equations, which are equations governing the45 motion of compressible fluids. It is a couple of hundred46 years old basic theory, but he then said, okay, how do we47 apply this to our current problem, and they worked out that

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1 it was effectively a south-south-easterly wind. The fact2 that it is a southerly wind generally takes out some of the3 room for error, because you are looking only at a4 north-south component; you are not looking at an east-west5 component. So even if you have a pool of errors, they are6 elongated in north-south. There is less variance. So that7 actually made his work a lot easier.89 Q. So is this use of the MSLP and the following analysis

10 of the MSLP an accepted and relevant methodological11 approach to the problem at hand?12 A. Definitely. All the way through our seaman officer13 training, we get taught to look at a mean sea level14 pressure chart and, from that, infer the wind. It's called15 the geostrophic wind. That just means the wind in balance16 between the pressure and the movement of the earth. Most17 seaman officers, and certainly once they are qualified,18 would be able to look at a mean sea level pressure chart19 and identify what wind to expect. This is useful, because20 you can then plan ahead. So, yes, it is a valid method and21 the additional work that he did in correlating that with22 satellite derived winds, I guess, tied it in to what they23 expect the conditions were on that day.2425 Q. So, in your view, was this methodology applied26 appropriately in van Burgel 's study?27 A. It was appropriate, sir.2829 Q. What results did this analysis yield?30 A. It was a south to south-easterly wind, 15 to 25 knots.31 My assessment, from mean sea level pressures and also from32 synoptic conditions, by which I mean the expected33 conditions on the day, would have been a south to34 south-easterly wind at 17 to 22 knots. That is how I would35 have forecast it.3637 Q. I would like to move now to a general overview of38 weather conditions, and then we will come down into39 specific elements of the weather conditions. What was the40 general weather picture which applied in November off the41 coast of WA?42 A. Sir, we have what is known as the East Indian Ocean43 anti-cyclone, which is just a high pressure system, and we44 have a semipermanent coastal or inland trough, which starts45 at the Kimberleys, moves down to the Pilbara and then46 extends all the way down sometimes to Albany. That's a47 persistent feature of the Australian climatology. These

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THE PRESIDENT: Could we capture that image? If we can,I shall mark it as exhibit 114.

CAPT McLAUGHLIN: Q. Could we go to the third page ofthat document. It is at page 0141. If we scroll down just

two weather patterns interact to have a generally southerlyflow. That's the first component. That's the picture. Wehave the Western Australian coast --

Q. At what speed was the wind travelling?A. As I stated, 17 to 22 knots is what I would haveforecast, but the study found between 15 and 25 knots.I would say that 20 knots is a fair assessment.

Commission ofwind in the early

What does this

to the force. Youdescribes the wind in

We will call up a Beaufort's table,

THE PRESIDENT: Q. Is that throughout the year?A. The East Indian Ocean anti-cyclone is a round-the-yearevent; the trough not so much. That is generated byextreme heating. It is a heat-induced trough. But theEast Indian Ocean anti-cyclone is a permanent feature, sir.

Q. There is some evidence before theInquiry from Kormoran sources that theafternoon was south south-east 3 to 4.mean?A. The "3 to 4" would have referredhave a Beaufort's force system, whichterms of its effect on the sea.

CAPT McLAUGHLIN:RAN.002.0139.

Q. That is where the wind is travelling from?A. Yes. The arrow is pointing in the direction towardswhich the wind is going. I have done this because if youwere holding up your shirt - or your hair - it would beblowing in that direction.

CAPT McLAUGHLIN: Q. I want to move now to the morespecific weather conditions for 19 November 1941 andspecifically in the afternoon of that day. You havementioned wind, so let's begin with wind. Where was thewind from? Actually, could we put the template on thescreen? I may get you to illustrate on the template anddraw in the weather conditions as we go.A. The wind was from the south to south east, which isanywhere between 150 and 170 true bearing.

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a little, this is the Beaufort wind scale that is used bythe RAN and most Navies and most mariners to describe thewind. We were talking of a south-south-east 3 to 4. Socould you explain what the "3 to 4" means?A. The "3 to 4" there refers to a gentle, firstly, orthen a moderate breeze, and that's at the lowest scale ofwhat I would have assessed the wind to have been for theday.

Q. What is the upper limit of the wind at scale 4?A. At scale 4, the upper limit, and just of notegenerally, is about 15 knots, where you start to see anywhite horses. The sea criterion is fairly frequent whitehorses. So at the upper limit, you start getting whitehorses or capping of your sea waves.

Q. Could we now return to the template. So far, we havea wind from 160 at speed --A. The upper limit of force 4 was 16 knots in thatprevious document, and the findings of van Burgel were 15to 25. I believe it was 17 to 22.

THE PRESIDENT: Q. In CAPT Detmers' book, he wrote thatas the sunset and evening descended, the wind scaleincreased from 5 to 6. I take it that he would have beenspeaking, again, of the wind scale of Beaufort?A. In the force, sir, yes. That would have been based onthe appearance of the sea.

Q. And 6 has a velocity of 22 to 27?A. Yes, sir.

CAPT McLAUGHLIN: Q. We will now move on to the sea andswell. First of all, could you explain the differencebetween sea and swell in weather terms?A. The sea is the effect of the wind on the water whereyou are, whereas the swell is the effect of the wind on thewater surface somewhere else and the energy wave thentravelling to your position. So it is possible to have aswell from one direction and a sea from a completelydifferent direction.

Q. On this day, where was the sea coming from?A. The sea was from the direction of the wind, as I justsaid, so that's a south to south-easterly sea. A sea stateof between 17 and 22 knots, which is what I have stated itto be, would have been sea state 4, which is 1.25 to

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1 2.5 metres.23 Q. That 1.25 to 2.5 metres is a height in the sea state.4 Where is that measured from?5 A. You measure it from the base of the trough of the wave6 to the peak.78 Q. Could you mark the sea and the swell for us on your9 diagram?

10 A. The sea is from the same direction as the wind, and11 the swell is as a result of the East Indian Ocean12 anti-cyclone, which is a generally southerly swell up the13 coast, so I wi 11 put that.1415 Q. So the swell also is coming from a southerly16 di recti on; is that ri ght?17 A. Affirmative.1819 Q. What was the height of the swell?20 A. A moderate swell is the climatology. I have read no21 reports of any cyclones or anything that would have changed22 any of this, but it is about a 2 metre swell. There is a23 moderate swell expected for that time of year.2425 Q. There is some evidence before the COl from Kormoran26 sources that in the early afternoon, conditions included27 sea state 3, medium swell from south-west. Does this28 accord with your view?29 A. Yes, I would be happy to accept a south-westerly30 report. I would have said southerly as my first guess. If31 someone sai d, "Where do you expect the swell to come32 from?", in that part of the world I would say the south.3334 THE PRESIDENT: Q. One relevance of this material is35 that if Sydney, after the engagement, was in a sea state36 described as 4, then, according to the DSTO information,37 her prospect of surviving was nil, because of the damage38 suffered?39 A. Yes, si r. If you have a 2 metre swell and then on top40 of that you have up to a 2.5 metre wave, from peak to41 trough you can sometimes have 4.5 metres. I don't know42 what the draught of the Sydney was, but any damage near the43 waterline could sometimes have up to 4 metres of water44 pressure.4546 CAPT McLAUGHLIN: Q. I want to move on to visibility -47 firstly, visibility range. What was the visibility range

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Q. He was in the crows nest, I think.

"very clear".A. I would agree with that, sir.

Q. According to him, the vessel, when sighted, was about20 to 25 miles distant?A. That's completely plausible, sir. Most of ourrecommendations and our forecasts are for someone standingon the bridge of the ship, so if someone is higher up byanother 5 or 10 metres, they will have an extended range.

was locatedadd to orat a further

Kormoran lookoutpart of the shipdetect something

LEUT Bunjes described the weather asQ.

in these weather conditions?A. I would say 10 to 15 nautical miles, which is out toabout 30 kilometres. At that range, that's when you canstart identifying finer features and details. It is not tosay you couldn't see a mountain at 50 kilometres, butthat's a large object. To identify a mast against thehorizon or anything similar - 10 to 15 nautical miles.

Q. Does the fact that theabove sea level in a higherdetract from his ability todistance?A. The higher you are, the further you are away from anyeffects of the wind-blown spray, so you get bettervisibility if you are above that.

Q. How much cloud cover was there on the day?A. Again, based on the fact that it was on the leadingedge or the eastern edge of a high pressure system, I wouldsay one to two octres, or eighths, of the sky would havebeen covered with cloud, but because it is a high pressuresystem, you have a strong inversion, which preventsdevelopment of cumulus-type clouds, so there wouldn't havebeen any rain or anything about.

Q. There is some evidence before the COl from Kormoransources that Kormoran sighted Sydney's mastheads at33 kilometres, which is approximately 18 to 19 nauticalmiles. Would this accord with your view of the visibilityon the day?A. Yes, that's extremely likely. As I said, 10 to 15would be my standard expectation, and adding to thatbecause it is on the eastern side of a high pressure systemwhere the conditions are favourable for good visibility.

THE PRESIDENT:

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A. He would have had an even better range.

CAPT McLAUGHLIN: Q. I now want to move on to the impactof the sun and the moon on 19 November 1941. What time wassunset on 19 November 1941?A. It was at 19:05, based on the latitude and longitudewhere the Sydney was found. That time could change by 1 or2 minutes, depending if they were further north, south,east or west.

Q. How quickly would it have become dark after sunset?A. You have what we call civil twilight, which is whenthe sun is 6 degrees beneath the horizon. At that stage,you could still probably read a novel or something, but youwould certainly know it is getting dark. That occurs forabout 20 to 25 minutes, again depending on the latitude orlongitude, but at these latitudes it is not a significantdifference. I only make reference to that because if youare close to the South Pole, you are going to havepermanent twilight. But for these latitudes, it is about25 to 30 minutes.

The next phase is when the sun is 12 degrees beneaththe horizon. That's known as nautical twilight. We in theNavy use that as a good time to take our star observations,because you can still see the horizon, but it is gettingdifficult to read anything. You would certainly struggleto write down your observations. That's about another20 minutes later. We're now looking at 19:40, 19:50. Thenby 20:00, it would have been total darkness, and it wasalso a new moon, so only 1 per cent illumination.

Q. We will come to the moon in a moment. There is someevidence from a Kormoran source that they calculated thatdarkness would be at 19:00 hours. Does that approximatelyaccord with your view?A. Yes. You have 15 minutes per degree of longitude, soyour sunset is going to change depending on what longitudeyou are. The time that you are experiencing relative tothe sun versus the time you have set for your time zone iswhat that difference is.

Q. What was the bearing of the sun for sunset on thisafternoon?A. 248 was the azimuth.

Q. There is some evidence before the COl from Kormoran

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sources that Kormoran, at around 16:30, turned into the sunfull speed towards the sun 250 degrees. How does thisaccord with your view?A. Yes, the sun - over a few hours leading up to sunset,the bearing of it is going to change only to within 10 or15 degrees maximum. So anywhere between 260 and 245 wouldhave been generally in the direction of the sun.

Q. That would have been including at about 16:00, 16:30on that day, 19 November 1941?A. Yes, so a little bit further north, obviously, for afew hours before.

Q. But within a 10 to 15 degree spread?A. A 10 to 15 degree arc.

Q. What was the phase of the moon for 19 November 1941?A. A new moon, sir.

Q. What does this mean - a new moon?A. It means that, at night, there is no illumination.Obviously, the moon just reflects the light of the sun. Ina full moon, obviously you can sometimes read by that, butfor a new moon, it is only the stars that are going toprovide any illumination. Total darkness is what thatmeans.

Q. So no moonlight to aid visibility at night?A. No, sir.

Q. There is some evidence from a Kormoran source that,"Nights in this region were light, so light that oncevisual contact with an alien vessel had been established,it would not be lost." With respect to the night of19 November 1941, does this general statement accord withyour views?A. The nights are clear, but they are going to beilluminated only if you have a moon, if you have a lightsource.

Q. I now want to move on to some more specific effects ofthe conditions which we have discussed. The first is theweather relative to Kormoran. In particular, we will startwith the wind. If I could ask you to assume for thepurpose of this evidence, and draw on your template, thatthe Kormoran was steering a course of 260 and she was at aspeed of 14 knots.

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Q. Yes. That makes a slight difference?A. It makes a little bit of difference.

Q. Taking this relative wind, I want you to assume thatSydney is 10 degrees off being right astern of Kormoran, so

A. This is just a relative vector (indicating),obviously, because Kormoran, for the purposes of this,remains at the centre of the manoeuvring form.

THE PRESIDENT: Q. Could you do the same exercise withsome dotted lines for 240 degrees?A. For the course, yes, sir. And at 14 knots, sir?

In fact, at 20 knots, so you20 knots, that's the relativehave been flying for a course

Thank you.THE PRESIDENT:

CAPT McLAUGHLIN: Q. You have conducted a relative windcalculation. Is this a commonplace calculation or is thissomething that just Mets do?A. No, all seaman officers do it. When you are on thebridge, you use the same relative velocity principles forworking out how to close another ship or how to approachanother ship within 500 yards on a particular bearing. Itis called station-keeping. This is certainly commonplaceand I would expect that every officer of the watch would bedoing wind calculations at least every hour.

Q. Where was the wind relative to Kormoran if she wassteering a course of 260 at 14 knots?A. At 14 knots? If there was zero wind, the wind thatshe would experience would be from right ahead, because sheis driving into it. But the wind is at, I will say,20 knots from 160. The way the Relvel works, we have totake that into account. So the combined vector is therelative velocity, which is circled, sir. I will bringthat back to the centre of the ship. Someone standing onthe Kormoran at that course and speed, with a 20 knot 160wind, would experience a wind where I'm drawing this arrow,from this direction, the implication being that any flaghoist she is flying will be flying downwind. So that isthe relative position of the wind relative to Kormoran.

Q. Not a great difference?A. Not a great difference.can see that between zero andposition that the flags wouldof 260.

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Q. Would you highlight again the vector that would bewhere the flags were pointing or flying if Kormoran was at260 at 14 knots for Sydney?A. That vector (indicating).

at a relative of green 170 on Kormoran's ship's head.Let's use 260 as her course.A. Okay, so right ahead is there, right astern is there,and 10 degrees from right astern is where I have indicatedthe Sydney.

THE PRESIDENT: Q. 248?A. That would be azimuth of sunset. It wouldn't havereached that yet; it would still be in this area. So theflags, which are not transparent, would have been backlitby the sun, so they would be casting a shadow onthemselves, making them also more difficult to read.

Q. So how much of the flags would Sydney have been ableto see in that position?A. On the assumption that the flags were in a fullyvisible area, anyway, Sydney is looking towards the ship,so they would see maybe 60 per cent of the flags, butkeeping in note the sun at this point.

That area is where you have marked aQ.THE PRESIDENT:

CAPT McLAUGHLIN: Q. Would the presence ofsuperstructure or funnel or masts and the like aft of wherethe flag hoists were have any further effect on this?A. Definitely to obscure, but also the funnels themselveswould be emitting a lot of heat. You would have all seen ­well, I have - the heat haze effect of the bonnet of yourcar. You can see the heat haze. For a ship that ismanoeuvring at high speeds or certainly at maximum speed,the heat haze is significant and would also make it moredifficult to read flags that were on a distant side.

Q. Another assumption, another assumed or postulatedposition, is that Sydney may have been on a starboardquarter, so green 135, on Kormoran. Where would that havebeen in relation to the vector in which the flags wouldhave been flying?A. Firstly, "green" means the starboard and "red" is theport. "135" is 135 degrees to starboard from Kormoran' sship's head, which would be in that area (indicating) whichwould almost be looking down the line of the flags.

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1 circle at about 135 degrees?2 A. Affirmative, sir. That's position green 135.34 CAPT McLAUGHLIN: Q. From that positi on, 1ooki ng at the5 flags, you would have been looking at them --6 A. Almost end-on. You would probably have seen7 10 per cent of a poorly illuminated flag.89 Q. You spoke a moment ago about the bearing of the sun

10 relative to both Kormoran and Sydney in either the astern11 or 10 degrees off the astern position and around on12 Kormoran's starboard quarter. You mentioned the effect13 that the fact that they were looking into the sun would14 have on the flags. Would you explain that a little more?15 A. The sun would be forcing the flags to cast somewhat of16 a shadow on themselves. They are not cellophane, they are17 made of cloth which is not transparent to the sun, or not18 significantly transparent. So the colours of the flags19 woul d have been 1ooki ng 1ess bri ght, basi call y.2021 Q. At what inclination or height above the horizon at22 16:30 or 17:00 would the sun have been? Would it have been23 well above so that it wasn't casting back on the flags?24 A. It would have been about 20 degrees above the horizon,25 sir. I haven't done the exact calculation for it, but it26 is easy to do.2728 Q. So reasonably low to the horizon?29 A. Yes. 15 degrees is, generall y, taki ng your arm out,30 so 20 degrees is one-and-a-half hand spans above the31 horizon, starting to really fall down.3233 CAPT McLAUGHLIN: Sir, that concludes my questioning of34 LEUT Rivett.3536 THE PRESIDENT: Thank you.3738 CAPT McLAUGHLIN: At thi s poi nt, I wi 11 tender the39 completed diagram.4041 EXHIBIT #114 COMPLETED TEMPLATE WITH DIAGRAM AS DRAWN BY42 LEUT RIVETT4344 THE PRESIDENT: Q. What was the angle of approach at45 which you said 60 per cent of the flag would be visible?46 A. That would be from green 170, sir.47

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CMDR RENWICK: Sir, I just have one question, if I may.

THE PRESIDENT: Yes, CMDR Renwick.

<EXAMINATION BY CMDR RENWICK:

CMDR RENWICK: Q. You have given evidence about wherethe sun would be in relation to the horizon about 16:30 or17:00. What effect would the position of the sun at thattime have on viewing a daylight flashing lamp coming fromthe Kormoran?A. It would reduce your ability to easily see it, sir,because you are already looking generally towards the sun.If you are driving, you have sun glare issues with the suna reasonable distance above the horizon so to then try todiscern a flashing light, whether it is a 5-inch or 10-inchflashing lamp - you would see it, but it would impact onyour ability to easily see it, sir.

Q. Finally, in relation to both of the positions you havepostulated for the Sydney on that chart, what would be theeffect on viewing the silhouette of the Kormoran from theSydney?A. The same issue with the shadowing, casting shadowsupon itself, would apply. With the sun in that position,it would be harder to see the length of the shipaccurately, for example, because you couldn't make out asmany finer features on the ship to get a gauge for, "Oh,thi s shi pis thi s long; there is its funnel". You woul dsee the front, you would see the funnel, you would see theend - the stern - but all the finer details in betweenwould become a lot more difficult to see until you were atcloser range, by which I mean probably 2 nautical miles.

Q. There is just one other matter. Do you have yourstatement there?A. No, I don't have it, I am sorry.

Q. I will read out paragraph 11. You there say:

Additionally I assess that the maximumrange at which an experienced officer orsignalman could read flags in theseconditions would be 10,000 yards (5nH) fora flag hoist that you were expecting tosee, however it is more likely that with anunfamiliar flag hoist this would reduce

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significantly.

CAPT McLAUGHLIN: May LEUT Rivett be excused?

THE PRESIDENT: Yes, thank you, LEUT Rivett.

THE PRESIDENT: Thank you.

Is there anything arising out of that?

Thank you. I have no further questions,

affect the angle at which the flag flew?The relative position of the wind wouldn't

the wind or the ship changed.

Q. Yes?A. Yes, that would be to let the flags fly better in thewi nd, I bel i eve.

Are you assuming, in making that statement in paragraph 11,that the signal flags of merchant ships in World War IIwere the same size as those of warships at that time?A. Yes, I am, sir.

Q. But it may have improved visibility because of absenceof other structures or whatever?A. Yes, sir, it would have potentially freed those flagsaway from the superstructure to let them fly further,higher.

Ahlbach, Kormoran's yeoman of signals, drewthe halliards to the starboard side to makethe flags more visible

THE PRESIDENT: Q. If my recollection serves me right,there is some evidence from at least one of the Germansurvivors that following a signal from Sydney they in factdrew the flag hoist halyard to starboard, or drew the flagto starboard, I'm not sure which.A. Sir, to move the flags further to starboard?

CMDR RENWICK:si r.

Q. Would itA. No, sir.change unless

THE PRESIDENT:

CMDR RENWICK: Just to note, sir, that the reference,I think, to which you were drawing attention is at page 453of the Official War History, where it is stated:

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<THE WITNESS WITHDREW

Q. What was the first step in your training? Youcompleted your normal officer training but what primaryqualification did you then commence training for?A. I started life as a seaman officer before progressingto principal warfare officer training and subspecialisttraining in above-water warfare and gunnery.

My course was called EXAC - Executive OfficersApplication Course - very similar to JWAC, of which aprevious witness mentioned, where you go through yourprimary qualification skills in navigation, bridgemanship,ship-handling, environmental observations, which are thecore skills required of the seaman officer.

You progress through the formal part of the trainingin the classroom and on training ships, to go to sea togain what is known as your ticket, which is your BridgeWatch-Keeping Certificate, which is your formalqualification to represent the Captain and con the ship,which is to drive the ship through the water on behalf ofthe Captain and keep it safe in day and night, insingle-ship steaming or in company. One of the other keyskills of a Naval seaman officer, is to operate in concertwith other ships, other than just single-ship steaming from

[10.50am]

CAPT Bairstow, when did you join

I would like to call CAPT Bairstow.

<WARREN JAMES BAIRSTOW, sworn:

<EXAMINATION BY CAPT McLAUGHLIN:

CAPT McLAUGHLIN: Q.the RAN?A. 19 January 1981.

Q. So you completed a Bridge Watch-Keeping Certificatemuch as LEUT Rivett gave evidence of, along a similar sortof training continuum at the time?A. Yes, sir, it was under a different name, because itwas a little bit further ago, but the same basicprinciples: firstly you are taught how to be an officer;secondly, once you have those officer skills in leadershipand management, which is a continuum throughout yourcareer, you start your primary qualification training,which was, in my case, as a seaman officer.

CAPT McLAUGHLIN:

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1 point A to point B.23 Q. After qualification, in which ships did you serve as4 an officer of the watch?5 A. As an officer of the watch I gained my minor war6 vessel ticket, my first qualification, in a patrol boat,7 that was HHAS Gawler in 1984, before progressing to8 HHAS Swan to get what was then a full Bridge Watch-Keeping9 Certificate in a major fleet unit, so, basically, driving

10 small and then you progress to the larger classes of ship.1112 Q. Did you then serve on other ships in a sea-going13 manner prior to doing any further training?14 A. You have a period of what is called consolidation, in15 which you could go to another ship, so, if you term it, you16 are newly qualified, you have gained your qualification,17 but you need to practise those skills to gain the requisite18 experience. I did my consolidation training in the ship on19 which I got my major fleet unit qualification, my ticket,20 which was Swan, and then also went to Tobruk, a different21 class of ship, to further my officer of the watch time, and22 also one of my other duties there was as the gunnery23 officer, so my primary qualification was an officer of the24 watch and I had departmental duties as the gunnery officer25 of that ship.2627 Q. After some time at sea did you go into any further,28 more specialised training or more advanced training from a29 seaman perspective?30 A. On completion of my seaman officer training,31 experience at sea and consolidation training and32 watch-keeping experience, I progressed to principal warfare33 officer training at HHAS Watson. I commenced that in 1991.3435 Q. How long is the principal warfare officer training36 process?37 A. It has varied over the years, but in my case it was a38 year-long course, phase 1, which was principal warfare39 officer core skills, and then you did a second phase which40 was subspecialist, which, in my case, was gunnery and41 above-water warfare.4243 Q. Subsequent to this, where did you then post?44 A. On completion of being qualified as a Principal45 Warfare Officer (Gunnery), PWOG, I progressed to my warfare46 billets at sea in two ships which have now recently left47 the RAN, HHAS Adelaide and HHAS Canberra, and progressed

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1 through there as the gunnery officer. On board those2 ships, the role, whilst on watch, was AWO, Above-Water3 Warfare Officer, and also after time and experience, I took4 up the role as Operations Officer, which is normally given5 to the senior PWO - not always in rank but in experience -6 and then, during that time, I honed my skills as a7 single-ship PWO and also as a task group warfare officer8 PWO responsible for the fighting and direction of the9 individual ship and also a group of ships in a task group

10 on behalf of the Captain.1112 Q. On completion of your PWO time, what was your next13 series of training and what was your next sea billet after14 that?15 A. After completing my PWO billets at sea and my16 experience, I then went ashore and went to HHAS Watson as17 one of the instructors in the Principal Warfare Officer18 faculty and progressed through there as the gunnery19 instructor to the gunnery instructor directing staff and20 then also to Officer in Charge of the PWO faculty21 responsible for the delivery of principal warfare officer22 training in the RAN.2324 Following that time, I was selected for command of the25 Fremantle class patrol boat, HHAS Gladstone, of which26 I took command in mid to early 1999, and I finished my27 command of that patrol boat, which was based in Cairns,28 towards the end of 2000.2930 Q. Is there any specific training that you do before31 taking up command of a minor war vessel such as Gladstone?32 A. Before taking up a command of a minor war vessel and,33 in fact, a major fleet unit, you do what is called a CO -34 commanding officer - designate course, where you go35 through, from a commanding officer's perspective, the36 personnel and management regime for which you are37 accountable for your command. You also go through an38 update of the issues affecting operations and personnel39 from a Navy Headquarters perspective and a Fleet40 Headquarters perspective, and, importantly, you also go41 through and do a command navigation course, which is a42 level of supervision and a command aspect to navigation,43 which is built on your officer of the watch experience.4445 Q. Following your time in command of a patrol boat and46 command of HHAS Gladstone, you spent some time ashore.47 What was your next sea billet after that?

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A. My next sea billet after Australian Command and StaffCourse, staff course training and HHAS Cerberus, whereI was XO, I was selected for a major fleet unit command.I took command of HHAS Arunta based in Western Australia inFleet Base West and took command in July 2004.

Q. She is a WA-based major fleet unit?A. Yes.

Q. During your time in command, what type of operations,exercises did you conduct and whereabouts, in what sort ofwaters did you conduct them?A. The full experience of the waterways of the worldI was lucky enough to experience. Obviously, being a FleetBase West unit, I did a lot of work in and off the WesternAustralian coast, a very large amount of work up in thenorthern approaches around Christmas Island, in South EastAsia, the waters around Japan, the South China Sea and upto Vladivostok, and the waters in between on the way back.So I was quite lucky to get a broad experience of theenvironmental and the sea aspects in the world.

Q. On completion of your time in command of a major fleetunit, what was your next posting?A. My next posting was as the Commander, Minor War VesselSea Training Group. That is where you are in charge ofwhat is called Sea Training Group and our role is toconduct collective training, which is the training of theship's crew as small teams but as a whole crew of thatship. Rather than like individual training which is donein the classroom, we did our collective sea training at seaand assessed and helped train the ship to high levels ofperformance to take their platform to conduct operations asdirected by government.

Q. In your role as commander of the Sea Training Group,what were your specific or primary tasks? I understand youhad staff to do certain things, gunnery and navigation;what was your main focus upon?A. My main focus was upon the command team and thecommand interaction. Firstly, to achieve the mission orthe aim of a certain activity, but how that command teaminteracts with the environment around them, with otherships around them and what actual mission they have beentasked to do.

Also, it is to make sure that the whole training

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activity achieves its aim, which is to prepare that patrolboat for its mission, to be able to conduct training ofitself but also to be able to conduct whatever operationsor activities Fleet Headquarters or the Government directs.

Q. Finally, to conclude on this component, what is yourcurrent posting?A. My current posting is Deputy COMFLOT andCommander Australian Surface Task Group. The position inFleet Headquarters is a tactical warfare commander, as aCaptain that can be deployed or go to sea to take charge ofa major activity or a task group of ships as staff.

Q. I want now to move to the weather effects and commanddecision-making. You have heard the evidence of themeteorologist, LEUT Rivett. To make some weatherassumptions, for the purposes of giving your evidence wewill assume that the weather conditions are as explained byLEUT Rivett, and I will prompt you with those in a momentso that you can draw up your template and the like.

We will also make some relative position assumptions.If we could call up the template now, would you begin byputting Kormoran on a course of 260 at 14 knots. I willjust read out the wind and environmental information foryou. Wind from 160. Sea from approximately 160. Swellfrom a southerly direction.A. I will combine those in the squiggly line as the windand the sea.

Q. And a bearing of sunset at 248 degrees.A. Is there a magnitude to the wind?

Q. There is. It is 15 to 25 knots and a sea of 2 to2.5 metres. I will give you a relative wind, which was at020, 23 knots. I will give you some initial assumptions.We have evidence from Kormoran sources that Kormoran was ona northerly course and Sydney on a southerly course whenshe first detected Sydney, and that, upon detection,Kormoran turned away to a course of 250 or 260. At thatpoint, to close Kormoran, what would Sydney have to do?A. I suppose on this diagram I need to put where I thinkSydney was. Could you say again where - she was initiallysighted fine on the starboard bow when Kormoran was goingnorth-ish?

Q. Yes.

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THE PRESIDENT: Q. According to some German evidence,she was about 20 to 25 miles distance, 45 degrees off thestarboard bow?A. Yes. Kormoran is on 260. Sydney was to the north.Okay.

CAPT McLAUGHLIN: Q. What would Sydney have to do, whatwould a ship do, in such a situation if it needed or wantedto close Kormoran?A. From this position, from where, on this diagram, weplace Kormoran and Sydney, to close Kormoran's position itwould not be a case of just steering straight for the ship.As explained previously, there is what is called relativevelocity, and there would be a steering component ahead anda speed component to make sure - obviously, if something isfurther away, you need to go faster than it. So for Sydneyto close, she would have to steer towards Kormoran but in away that she closes the range without dropping further backin bearing, so for her to close Kormoran, based onKormoran's 260, she would have to steer somewhere to theright of 260 and have a different speed component to dothat.

Q. So a greater speed in order to try to close thedistance?A. Yes.

Q. Where, in normal practice in these weather conditions,noting the southerly winds and swell, et cetera, if youwere closing on a ship that you didn't know about, wherewould you tend to position your ship?A. It depends on the tactical situation, but from thatdiagram there - what was the question again, just to closethe ship?

Q. To close the ship, where would you be almlng toposition yourself as you closed the ship, on that othership?A. Well, from your speed advantage, you would try to bein her quarters initially, because that's where thestarting position is, and then from there you would have tomake an assessment of how much you would have to close,which would determine where you wanted to position theship.

Q. There is some evidence before the COl from Kormoran

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1 sources that Sydney, once she did close, stationed herself2 at around relative green 170, or 10 degrees from aft, and3 was closing slowly, showing a narrow silhouette. Would4 this accord with your experience?5 A. Yes, that would accord.67 Q. I want to address at this point a theory that has been8 postulated. Some theorists put forward a proposition that9 Kormoran was stopped in the water, that she was flying a

10 white flag. They then propose that perhaps Sydney was11 preparing to launch a boat to send over to Kormoran to12 investigate. Assume for a moment that this was so. In13 these weather conditions, where would an experienced seaman14 tend to position themselves if they were to launch a boat15 or were intending to launch a boat to send across to a16 stationary vessel?17 A. Given these weather conditions, what you would try to18 do is to what is called provide a lee for the launching of19 the boat. The lee is to protect, by using the ship's20 structure, the boat from both the wind and the swell. If21 you can imagine, you want to be able to launch your boat22 safely.2324 I would postulate here that Sydney, to provide a lee25 for the boat and to put the elements - to be up from the26 Kormoran - sorry, there are two factors. One is to provide27 the safety lee for the boat. Also - I will call Kormoran28 the target vessel here - you would want to have the boat29 going down-sea. The reason for that is that you want the30 journey to the target vessel to be as easy as possible for31 many tactical reasons, but the main one being that you want32 the boat to get there fresh, to be able to do its mission,33 without the crew on board being fatigued because of any34 weather conditions.3536 With those factors in mind - and I will assume that37 Sydney would still be trying to close Kormoran in some38 way - from this postulation, I would say that you would39 have the elements on the port side of Sydney and you would40 probably use the boat to starboard and you if were going to41 station Sydney to achieve a down-sea run, you would be42 around on the port side of Kormoran, which enables you (a)43 to provide a lee for the boat, if you launched a starboard44 boat, which is the right-side boat, to provide a lee for45 it, but also to allow that boat to have a down-sea run and46 to get to the target vessel with the minimum of fuss and47 fatigue on the boat crew .

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12 Q. Just to clarify and sum up, in that scenario you would3 go to the port side of Kormoran in order to put the sea on4 your own port side, to provide a lee for the launch of your5 starboard boat, and then send the boat down-sea towards the6 target vessel?7 A. Yes, depending on the situation and what you are8 trying to achieve. In that situation there, to launch a9 boat and to achieve those two things - provide a lee for

10 the boat and also to get the boat down-sea - Sydney would11 have to position itself somewhere here (indicating) on the12 port side of Kormoran.1314 Q. We will now return to our assumption that Kormoran is15 on 260 at 14 knots, so no longer stationary in the water.16 I now want to turn to the effects of the weather in17 relation to some of the tactical decision-making. We will18 start with signalling. We have heard some evidence to this19 effect already. Given a Kormoran course of 260, a speed of20 14 and a relative wind across the deck of 020, or relative21 green 120, 125-ish, assuming Sydney is at relative green22 170 on Kormoran, how easy would it be to read Kormoran's23 signal flags?24 A. I will just put on a secondary diagram. That's in the25 green 170 position. From that direction there, you would26 see the flags, and also, depending on range - I haven't got27 a range component of where Sydney is, where the flags are -28 but outside 5 nautical miles it gets pretty hard to read29 flags anyway. So, based on that diagram, if that range is30 greater than 5 nautical miles, there is an issue; there31 will be some difficulty in reading flags.3233 On the angle, they would not get a full view of the34 flags, but the angle of the flags on that relative wind -35 they would see a certain percentage. I suppose 50 to36 60 per cent of the flags would be seen. That's just a pure37 angle. Remember, range is also a big factor in this as38 well .3940 Q. Noting that all the different signal flags have41 different combinations of colour, would that 50 to42 60 per cent of the flag be enough for you, with certainty,43 to read those flags, assuming it was a clear view of those44 fl ags?45 A. For an experienced operator expecting a flag hoist,46 yes, depending on what flags they had hoisted. It wouldn't47 be easy, but you could discern those flags based on that

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1 angle. Remember, I'm not sure what range Sydney was at,2 but, based on that angle, with an experienced operator on3 the bridge, the yeoman or whatever, you could. It wouldn't4 be easy, but you could do it from that angle.56 Q. I would now add a couple of complicating features, and7 we will just bring up two photos quickly. Could I bring8 up, firstly, photo COI.006.0015.9

10 THE PRESIDENT: Whilst you are doing that, I will mark11 this image as exhibit 115.1213 EXHIBIT #115 CAPT BAIRSTOW'S DRAWINGS AND CALCULATIONS1415 CAPT McLAUGHLIN: Q. This is a close to beam-on view of16 Kormoran and you can see the superstructure where the17 bridge was and the funnel just aft of the bridge. I would18 now like to call up a second photo which gives a quarter19 view. Actually, before we do that, there is some evidence20 before the COl from a Kormoran source that the yeoman21 hoisted his response flags, his hoists, up on a stay22 situated aft of Kormoran's bridge but forward of the23 Kormoran funnel. Would you just bear that in mind for a24 moment.2526 Could I now call up photograph COI.006.0020. This is27 a picture of Kormoran. What relative perspective would you28 call that, if you were looking at Kormoran?29 A. That would be the starboard - I would be on Kormoran's30 starboard quarter.3132 Q. So Kormoran's starboard quarter. So this would not be33 too unlike a view that Sydney may have had if she was on34 Kormoran's starboard quarter or just fine on Kormoran's35 stern?36 A. Yes. But the range component here - that's quite37 close.3839 Q. That's quite close, yes. What would you estimate the40 range there to be, just in rough terms?41 A. 1,000 yards.4243 Q. So if Ahlbach, the yeoman, is hoisting his response44 flags aft of the bridge but forward of the funnel, from45 this position, would that make it more complicated or46 easier to read those flags?47 A. By looking at this quarter view, there are quite a few

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1 obstructions, if you are going to have flags on the2 starboard side. Obviously you have the bridge forward but3 you also have the funnel. Now, I'm not sure where the4 actual halyards - which are the lines that the flags are5 secured to - are, but there are some obstructions there6 which could affect the vision that you would have of the7 fl ags. Remember, I can see that there 1i ke that, at that8 range, but if you increase the range, you increase the9 difficulty.

1011 Q. Would the presence of the funnel cause any further12 issues - heat haze or smoke or anything like that?13 A. Well, by looking at that, there would be an exhaust14 and there would be quite a bit of heat. I don't know if15 they were blowing smoke or whatever, but there were quite a16 lot of factors, just with the funnel and the proximity of17 the heat source and haze to that starboard side where the18 flags are, that would have an impact on your ability to see19 those flags.2021 Q. Just to add into this the position of the sun, how22 would that also mix into this combination of factors?23 A. By looking down at that and onto the diagram, the sun24 would be beyond the ship and you are looking up-sun, into25 the sun, or the area where the sun is, and also that sun is26 in a similar position to where the flags may have been27 flying, that would certainly make it another order of28 difficulty in discerning what those flags are.2930 Q. Could we bring up the template again, please. Before31 leaving this aspect of signalling, given all of these32 factors, where could a ship perhaps read a hoist from33 Kormoran more clearly?34 A. If the relative position of the flags - you could35 either be ahead, or that quarter position by an angle could36 provide 50 to 60. If you wanted to increase that,37 obviously, you would want to come further around to port,38 from Sydney's perspective, so further around to the quarter39 on Kormoran, or you would go ahead and read them from40 forward. So what you are trying to do is to get the angle.41 If you can imagine the flat-screen TV over there, depending42 on what angle you are - obviously if you are facing it, it43 is easier to read the TV; the more acute your angle, the44 harder it is to discern. So Sydney would take into account45 those considerations. Further down the quarter or to go46 ahead - I see those as two the two options.47

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EXHIBIT #116 DOCUMENT BARCODED UKAA.002.0043, PAGE FROM A1943 ADMIRALTY DOCUMENT BEARING THE TITLE "DISGUISED ENEMY

Would this accord with your general appreciation ofvi s i bi 1 i ty?A. Generally, yes.

Admi ral tyGuidance onI wi 11 read

I tender that document.

Communication with SuspectsA problem that perpetually arises is thatof communication with a suspected ship.Though many merchant ships have shown amost satisfactory efficiency it is a hardfact that visual signalling cannot beguaranteed outside four miles, and manyCommanding Officers have felt a greattemptation to close to a satisfactoryvisual range after a tiresome period offrustration.

CAPT McLAUGHLIN:

Q. At this point, we will bring up in succession fourcontemporaneous documents from the World War II period andI will ask you to read some sections from those. CouldI call up, first of all, UKAA.002.0036 at page 0043 andcould we scroll down to the bottom paragraph,"Communication with Suspects". This is from andocument of 1943/1944, which is "Draft TacticalDisguised Enemy Raiders and Blockade Runners".the relevant section:

Q. Before moving on from the ability in such conditionsto read signal flags, you spoke of range. Could you pleasejust reiterate what the range bracket is within whichsignal flags could be read in similar weather conditions?A. In these weather conditions, if you look at where thesun is, if you take it to a normal, reasonably clear day,as a rule of thumb, 5 nautical miles is good. You wouldwant to be inside 5 nautical miles to see flags quiteclearly. Outside of 5 nautical miles it starts gettingharder. Taking into account, if you look there, therelative position of the flags and where the sun is and thehaze of the funnel, where the position of the flags is,range would definitely be, I would consider, a factor ofhow you would read the flags. Between 2.5 and 5 nauticalmiles - 5 nautical miles is getting out towards it, whichis 10,000 yards, give or take.

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1 RAIDERS AND BLOCKADE RUNNERS: CONDUCT OF HER MAJESTY'S2 SHIPS"34 THE PRESIDENT: This, of course, is after the event?56 CAPT McLAUGHLIN: Yes, sir.78 Q. Next we will call up UKAA.010.0084 at page 0088, at9 the bottom of this page. Sir, this document is a report of

10 proceedings by HHS Dorsetshire, dated 2 December 1941.11 I will just read the relevant part from paragraph 28, on12 the next page:1314 British and Allied Herchant Ships,15 independently routed, are frequently met at16 sea often hundreds of mi7es from the17 position where they ought to be on the18 plot. Their identity can only be19 established by signalling, which is20 extremely difficult outside a range of21 8 miles. In these circumstances the22 temptation to close to signalling distance23 (5 miles or less) is very great, especially24 if the course of the vessel to be25 identified is in the opposite direction to26 that on which the cruiser wishes to27 advance, and the more so if day7ight is28 runn i ng short.2930 Would this, in general, accord with your view,31 CAPT Bairstow?32 A. Yes.3334 EXHIBIT #117 DOCUMENT DATED 2 DECEMBER 1941, REPORT OF35 PROCEEDINGS OF HHS DORSETSHIRE3637 CAPT McLAUGHLIN: Q. The next document is NAA.074.0064.38 Can you read that, CAPT Bairstow? I have a printed copy if39 you need it.40 A. Yes, just paragraph 1?4142 Q. Yes. I wi 11 read paragraph 1. Thi sis a mi nute paper43 dated 31 December 1941, related to the safety of merchant44 shipping. It says:4546 ... I also concur that it is sometimes47 difficult to read flags at distances of

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CAPT McLAUGHLIN: I tender that document.

CMDR RENWICK: Might I inquire as to the author of thisdocument?

THE PRESIDENT: Somebody signed it "for the DSC". I can'tread the author's name. It looks like JAS Braum.

Again, would this accord with your views and experience?A. Yes.

Yes. I accept that.

THE PRESIDENT: The document dated 31/12/1941 signed "forthe DSC" , subject "Safety of merchant shipping", barcodedNAA.074.0064 will be exhibit 118.

one mile. It is also difficult to readdaylight flashing lamps if the ship is"up sun". These are exceptional cases andI consider that to be able to read flags ateven 3 miles is a step in the rightdirection.

It is sometimes very difficult to read aflag hoist at as little as a mile. Thewhole purpose of suggesting a daylight lampis that warships can identify ships from arange at which they are not tactically in adisadvantageous position, ie outside5 miles at least.

EXHIBIT #118 DOCUMENT DATED 31/12/1941 SIGNED "FOR THE DSC"WITH THE SUBJECT "SAFETY OF MERCHANT SHIPPING", BARCODEDNAA.074.0064

CAPT McLAUGHLIN: I guess the only link we can make isthat this is a document in response to the next documentwhich we will bring up, as to which we can determine theauthor. These are RAN documents.

CAPT McLAUGHLIN: Q. Finally, could we bring up documentNAA.074.0065. Again, this is paragraph 1. This document,sir, is the minute of 30 December 1941 from "DOD", referredto in the previous document. This document is signed by,as he would have been then, CAPT Dechaineaux. Leavingaside the reference, it says:

CMDR RENWICK:

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EXHIBIT #119 DOCUMENT DATED 30/12/1941 BARCODEDNAA.074.0065

THE PRESIDENT: That document was written, if I recallcorrectly, to address a response to a proposal byCAPT Dechaineaux that all merchant vessels be fitted withdaylight lamps so that they could signal from, I think,10 mil es.

THE PRESIDENT: Q. You certainly wouldn't launch a boatat 25 knots?A. If you take into account the ship's speed - and I'mnot sure on what procedures they used in those days - goingthrough the water at a rate of knots would make it very,very hard to launch a boat. In fact, I would hazard to say

CAPT McLAUGHLIN: Q. I want to now move on to weatherconditions and the effect they would have had on launchinga boat whilst under way. We've talked previously aboutlaunching a boat towards a stationary vessel. There issome evidence before the COl from a Kormoran source thatSydney actually approached on Kormoran's starboard quarter,that it may have had a port side boat outboard for launch.Could we bring up the template, please. In weatherconditions such as these, and given the course of bothships on approximately 260, how difficult would it havebeen to launch a boat on the port side, noting a speed,from Kormoran sources, that she was doing 14 knots, andSydney, in order to maintain station on her, would have hadto have been doing what speed?A. She would have to be doing faster. Without workingout, I would start at least 5 knots more or 10 knots more.You would want a definite speed advantage if you weretrying to close. In terms of the boat, I would just goback to the basic principles, to provide a lee to protectthe boat and its crew, and by protecting the boat, not justit banging against the ship's side, but actually theability to launch the boat safely. In those conditionsthere, if a boat was out on the port side, it would not beproviding a lee and, in those conditions there, yes, youwouldn't be providing a lee. So unless there was someother reason why you would have a boat out on the portside, that would not be the way that you would launch aboat.

We tender this document.CAPT McLAUGHLIN:

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1 at 20 knots you wouldn't launch a boat, period.23 CAPT McLAUGHLIN: Q. I now want to move on to the4 weather effects on timing and remaining daylight. There is5 some evidence before the COl from Kormoran sources that by6 17:15 Sydney had closed with Kormoran and had by then7 commenced signalling Kormoran to establish identity. Now,8 if sunset was at 19:05, and it was to be a moonless night.9 What impact would this have on a command appreciation of

10 any situation?11 A. The command appreciation in this case, noting that12 identification would have been done by visual means, the13 light starting to fade would certainly be a factor you14 would have to consider. The timing and the direction of15 the sun and also what range the two ships were apart would16 impact on the time remaining to complete the identification17 evolution and whatever evolutions might follow from that.18 So the setting of the sun would have been a time factor in19 terms of the decisions that would have to be made to20 conduct the evolutions, initially, of identification and21 whatever might follow.2223 Q. So identification would have been a preliminary, would24 it, to have determined the next step that you would have25 had to have taken in the remaining daylight?26 A. Yes. Not knowing what Sydney's ROE was, but I take it27 there that Sydney was trying to identify that vessel, so28 certainly after identification has been resolved or not29 resolved, but at least you have tried to identify, then30 that would certainly bring into account other actions,31 I would assume, after that.3233 Q. There is also some evidence before the COl that it was34 routine for German raiders, indeed, most merchant vessels,35 to steam at night not burning their navigation lights.36 Given the evidence as to the darkness of the night that was37 approaching, how easy would it be to maintain contact with38 or to maintain track on such a vessel like the Kormoran,39 for example, on a moonless night, given, of course, that40 Sydney had no radar?41 A. It would have been quite hard. I think the ship would42 darken themselves. There are many tactical reasons why you43 would do that. Also, another reason to actually darken the44 ship, whether you have your navigation lights on or not, is45 to make sure that if you have your navigation lights on and46 you darken your ship, then all you see is the navigation47 lights, and under the international rules, whatever they

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1 were back then, you could determine the aspect of a vessel.2 If you turned those navigation lights off and you were3 darkened, it would be pretty difficult to maintain a track4 of that vessel visually, without the aid of radar.56 Q. So not only would it be difficult just to see or7 detect the vessel, but are you saying that, without the nav8 lights, determining the aspect and, therefore, what her9 course and speed was so that you could try to match that in

10 order to not lose contact, would be more difficult?11 A. That would be very difficult, as I said, without the12 aid of radar, noting that navigation lights are there so13 that other ships, at night, can determine the aspect and,14 therefore, avoid collision.1516 Q. By "aspect", you are referring to a ship being able to17 detect what angle they are on the bow or on the stern?18 A. Yes, relative to you. Relative to you.1920 Q. Finally, then, I want to turn briefly to the issue of21 weather effects on discerning silhouettes. You have22 provided some evidence on the ability to read flags and23 just briefly on flashing light from up-sun. Given a sea24 state of 3 to 4 and given Kormoran's position relative to25 the sun, and, again, assuming Sydney's position is26 somewhere between the starboard quarter of Kormoran and27 right astern of Kormoran, how easy or difficult would it be28 to discern a clear silhouette, noting the position of the29 sun, amongst other things?30 A. It would be difficult to discern the silhouette, but31 also, from the perspective of the aspect of the vessel,32 when you look at the beam-on picture of the vessel, it33 tends to stand out. Once you start getting that angle,34 when the angle gets a lot more acute, it is hard to35 determine the actual positioning of the masts, the funnel,36 et cetera, of that ship. So if you take into account37 headi ng into the sun, the haze, 1ooki ng up- sun, so it is38 hard on the eyes as well, there would be some elements of39 difficulty in determining the visual aspect - sorry, not40 the aspect, but the silhouette of that vessel.4142 Q. In your experience, is it easier to discern a43 silhouette if the sun is behind you as you are looking44 towards the target vessel, or with the sun behind the45 target vessel, illuminating the target vessel?46 A. In terms of the conditions there, a visual47 recognition, if you are trying to discern what it is,

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<EXAMINATION BY CMDR RENWICK:

CAPT McLAUGHLIN: That concludes my questioning ofCAPT Bairstow, sir.

CMDR RENWICK: Q. Could we have brought up COI.006.0018,the picture, please. Sir, you will recall giving someevidence about this picture of Kormoran?A. Yes.

I would agree that it would be harder with the sun behindit to discern features, and the features that they wouldtake into account then to discern what sort of vessel itis, yes.

If she is oiling, it is probably

I have a couple of questions, sir, if

You can see the approximate scale up at the topright-hand corner. If we can close in a little bit, then,my question is this: would you agree with me that,assuming that that map and the times are accurate, the viewof the Kormoran that you have given evidence about on thephoto that I have shown you a minute ago would be the viewthat the Sydney would have had at approximately 5.15pm?A. At 5.15, it looks like the angle would be - justassuming that this diagram is correct and they are bothheading in roughly the same direction, that probably would

CMDR RENWICK: Q. Would you keep that image in yourmind, sir. Could I ask that BURN.001 .0014 be brought up,please. This is the map taken from the Official WarHistory. If you just look at that, sir, I would like youto assume that that map accurately depicts the relativepositions, at the designated times, of the Sydney and theKormoran. We will need to zoom out a little bit so thatCAPT Bairstow can see the scale in the top right-handcorner. This is from the second volume of Gill in theOfficial War History, the Australian Official History.

Q. I thi nk at T1261, 1i ne 41, you esti mated that therough distance to the ship in that picture was about1,000 yards or so - approximately?A. Yes, approximately. Probably less than that. Yes.

CMDR RENWICK:I may.

THE PRESIDENT:400 metres.

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THE PRESIDENT: No, it is not.

put Sydney a bit further around to starboard on thequarter.

CMDR RENWICK: It is further than 1,000 yards is theproposition.

Q. Yes. Could we go back to the photo, please.A. I reckon that's probably green 150, green 160.

A mile? A mile, a mile and a half, so 2,500

Q. But as far as the distance goes, the map depicts theKormoran further away from the Sydney than on the photo?A. Oh, yes. If I use the scale, it is probably 4 miles,I think, at 5pm, and obviously more than that as you goearlier in time, to 5 miles.

Q. At 5.15, it is not that close - it is not 1,000 yardseither, is it? It is much further than that?A. By the scale it would be a mile and a half, two and ahalf miles, which is sort of like 3,000 yards, give ortake.

THE PRESIDENT: Not very much, as I would read it.Putting a pen against it, at 5.15, I would have thought onthat scale it is about

THE WITNESS:yards.

Q. So it would be a little earlier on, perhaps closer to5pm, would it?A. I would have to have another look at the ship again.

THE PRESIDENT: Q. Did you say green 150?A. Yes, I'm just trying to estimate what her ship's headis relative to me, sir. I mean, that's on the quarter, butwithin plus or minus 10 degrees either side. Yes, roughly,on the quarter. So if we go back to the diagram.

CMDR RENWICK: Q. Yes. Could we go back to the map,please. So as far as the bearing goes, you would say it iscloser to 5pm than 5.15pm?A. Or before, yes. To me, it doesn't look like thatwould be 5.15pm, so it would be earlier than that and5 looks closer to it than 5.15.

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CAPT McLAUGHLIN: May CAPT Bairstow be excused?

<THE WITNESS WITHDREW

SHORT ADJOURNMENT

THE PRESIDENT: Yes, thank you very much, CAPT Bairstow.

Is that a convenient time?

Very well. We will take a short

Thank you, sir.

It is, sir.

The effluxion of time, the absence of the wrecks andthe absence of the battle site have provided fertile ground

THE PRESIDENT:adjournment.

THE PRESIDENT:

THE PRESIDENT: I shall mark a blank copy of the ship'slog which contains the various sea states and Beaufortscales as exhibit 120.

CAPT McLAUGHLIN: Sir, before concluding here, I have beenremiss at not tendering the Beaufort wind scale.

CMDR RUSH:

CMDR RUSH: Sir, it is proposed today and tomorrow andthen later on in January to call some people who haveprovided submissions to the Commission of Inquiry and whoput forward alternative theories.

I thought it might be of benefit, sir, to give somebackground in relation to theories, conspiracy theories andothers, that have come forward since the loss of Sydney on19 November 1941.

CMDR RENWICK:

EXHIBIT #120 BLANK COPY OF SHIP'S LOG CONTAINING VARIOUSSEA STATES AND BEAUFORT SCALES BARCODED RAN.002.0139 ANDFOLLOWING

When one considers it as a whole, the loss of Sydneyhas provoked extraordinary controversy and debate.Sensational claims have been put forward. Fraudulentaccounts, fraudulent documents and even fraudulentartefacts have been produced. The sensational has tendedto overwhelm sensible and reasoned discussion.

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In 1981, Mr Michael Montgomery published "Who Sank theSydney?" , and, sir, as you well know, he was called andgave evidence to the Commission of Inquiry in earlyDecember of last year.

for conspiracy theorists. It has produced those with agenuine desire to try to establish the truth of whathappened concerning the loss of Sydney, and some materialwould suggest that it has produced accounts from those lesswell motivated and those that live off unfounded innuendoand speculation in an effort to shock and in an effort togain attention.

The materials thus far obtained by the Commission ofInquiry indicate that, in the mid 1970s, a small group inWestern Australia formed the Sydney Research Group. Thecommon theme from the documents obtained by the Commissionof Inquiry in relation to the work of this group is thatthere should be a rejection of the official line, the Gillhistory, in relation to the loss of Sydney; a belief thatsignals had been sent from Sydney; assertions that, inbattle, Kormoran had breached the rules of warfare;disbelief that Sydney could approach so close to Kormoran;disbelief that Sydney could take so long to return fire;and bewilderment that there could be no survivors ofSydney.

Included in Mr Montgomery's list of controversialtheories was that an RAAF plane had sighted Kormoran on11 November 1941 between Fremantle and Geraldton and, as aresult, CAPT Burnett was aware of a raider; that Kormoranhad a Norwegian disguise and opened fire under a neutralflag; that CAPT Detmers told one of his interrogators ­that is the way Mr Montgomery referred to it - thatMAJ Schrader, who was in charge of the Tatura internmentcamp, that Kormoran had fired an underwater torpedo beforedeclaring herself; that Detmers' account of Kormoran's80-plus injured perishing when their life raft capsized isa fabrication designed to hide the extent of the damagewrought on Kormoran either before or during the exchange offire with Sydney; that Sydney crew were shot in the waterby Kormoran men using torpedo-powered motorboats and that

In excessloss ofthe

Authors concerning the account proliferate.of 20 books have been written in relation to theSydney. It has been suggested that seven are inprocess of production for publication in 2009.

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1 these boats were scuttled and had machinery removed and2 jettisoned while at sea or on the way to or near Red Bluff;3 that cryptograms produced by Dr List after the battle4 indicate that assistance was received from the Japanese and5 a Japanese submarine, and Sydney crew were taken prisoner6 on a submari ne, possi bl y the IJNI -124; that the 1i ghthouse7 tender Cape Otway found bodies, and its log was later8 tampered with, removing from its record all entries after9 8am on 18 November; and that there was an official cover-up

10 of enormous proportions.1112 This appears to be the first time that the Cape Otway13 was mentioned as locating bodies; the first time that it is14 alleged that the Kormoran was lying in wait for Aquitania;15 the first time that Kormoran survivors were, it was said,16 deliberately abandoned and that the loss of men in such17 circumstances was a lie of Detmers to hide the extent of18 damage to Kormoran; and the first time an author had19 suggested that there was involvement of a Japanese20 submarine.2122 All this appears to have metamorphosed into a claim23 made by Mr John Doohan, another Western Australian24 theorist, that Kormoran wounded had been taken on to Sydney25 and died when Sydney sank. Mr Doohan and others have26 picked up on the Montgomery theory of massive cover-up. As27 Mr Montgomery stated in his evidence, the magnitude of the28 cover up involves Australian, United Kingdom and USA29 Governments, the Royal Navy at the time and the Royal Navy30 continuing, and the Royal Australian Navy at the time and31 the Royal Australian Navy continuing.3233 In April 1984, Ms Barbara Winter published a book,34 "HHAS Sydney: Fact, Fantasy and Fraud". She chall enged35 much of what appears in Montgomery's work. Rather than36 quashing speculation, as she has stated she hoped, her37 attacks on Montgomery and the Sydney Research Group and38 others served to intensify debate and draw many otherwise39 passive observers into an increasingly acrimonious debate.4041 Controversy and conspiracy as to the location of the42 wrecks is another feature of debate since the mid-1970s.43 The fact that the wrecks are very close to the positions44 given by German survivors and thus many theories have45 proved to be spurious has, it appears, caused little46 re-evaluation by many of the conspiracy theorists.47

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1 Some took up a Montgomery theory that was put forward2 in the 1980s that Sydney limped into local waters off the3 Western Australian coast. It has been stated, and it was4 stated indeed, that a promising magnetic anomaly was found5 off the Zuytdorp Cliffs. In 1981, the Royal Australian6 Navy, with the Western Australian Maritime Museum,7 organised search in that area without any result and,8 indeed, eradicating the magnetic anomaly as being in any9 way associated with the loss of Sydney.

1011 A diver, Dwayne Sampey, found Sydney in a kelp bed off12 Dirk Hartog Island. He found skeletal remains. Three13 torpedo holes he found in the hull of Sydney. He found a14 grave ashore on Dirk Hartog Island.1516 In 1987, an RAAF Orion and HHAS Gera7dton looked into17 Sampey's claims. They located a grave site, which the18 Western Australian Maritime Museum subsequently excavated.19 Nothing was found.2021 Between 1981 and 2008, over 25 reports of wrecks or22 relics of Sydney in shallow water have been received by the23 Western Australian Maritime Museum, the Western Australian24 Maritime Museum being the body charged with protection and25 management of shipwrecks off the Western Australian coast.2627 That some reports found their way into the press via28 the finders added further interest from the public. The29 last example appearing after the two wrecks were found in30 2008 was an oar found much earlier at the bottom of the31 Zuytdorp Cliffs. It was headlined in the Geraldton press32 as being from HHAS Sydney, despite the proponents having33 received unequivocal advice from historical officers in the34 RAN that it could not have been so. This was preceded by35 front-page news in The West Australian and elsewhere across36 Australia claiming that HHAS Sydney had been located37 previously in 2001 near the Abrolhos Islands. This was38 followed again by further headlines not long after that39 Sydney had been located in the Shark Bay region in 2007.4041 The examples are an important pointer: they relate,42 firstly, to secrecy and inordinate rumours and, secondly,43 to the underlying reasons why controversies, conspiracies44 and false claims have been so prominent in the last decade.4546 One factor in the many claims was the sometimes47 innocent but often self-serving and occasionally fraudulent

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1 filling of the vacuum left by official inaction of2 CMDR Long's decision, after the War, to publish an account3 of the loss of Sydney.45 Speculative reporting over the last two decades has6 been a major driver in spreading controversy and conspiracy7 theories. Hundreds of press items of the nature I have8 described have appeared, most bordering on the sensational.9 Further, some journalists involved have become activists

10 and researchers in their own right, pushing and promoting11 theories and insisting on inquiries and other information12 being made available.1314 There were those who supported Port Gregory as a site15 for the loss of Sydney. Those persons around the16 Port Gregory area relied on oral histories that were17 obtained from local residents, who had, in some way or18 another, had these histories passed on to them by those who19 made observations on or around 19 November 1941. Again,20 others have claimed, as we have stated, not only magnetic21 anomalies that were investigated but other anomalies on the22 seabed off the Abrolhos Islands.2324 All this has led, time and again, to searches in an25 attempt to ascertain whether there could be said to be any26 certainty or any validity in the claims that were made.27 A number of conferences and inquiries have been held.2829 In 1991, the Western Australian Maritime Museum30 organised a conference that was attended by many persons.31 That conference followed and discussed the nature of the32 battle, the potential location of shipwrecks and weather33 and conditions. It discussed the German accounts of the34 battl e. But, in general terms, it fell away into35 acrimonious discussion at its conclusion. It resulted in36 the publication of a book by Tom Frame, which was recently37 republished I think at the end of last year.3839 In 1997/1998, the Parliamentary Inquiry was set up by40 the Department of Foreign Affairs and Trade. Its report,41 which largely accepted the German account of the battle,42 has been much derided by conspiracy theorists.4344 In 2001, the Sea Power Centre set up a conference in45 an effort to obtain some certainty as to the location of46 the wrecks. That, too, fell away, with many people putting47 forward many theories in what was described as acrimonious

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1 debate.23 More recently - and I mean towards the end of the4 1990s and into this decade - people have put forward5 theories that bodies were buried on the beach of Western6 Australia and that then, again, both the Army and the Navy7 were in charge of a massive cover-up in relation to the8 burial of those bodies.9

10 Letters alleged to have been written by soldiers11 involved in the burial of such bodies have been circulated.12 The letters, counsel assisting will submit to you, sir,13 reek of fabrication.1415 Those involved in those theories include Mr Angwin,16 from whom you have heard; Mr Samuels, from whom you will17 hear this morning; Mr Brett Christian, the publisher of the18 Subiaco Post; and others as well.1920 It is all eged that in 1941, apparentl y, around21 December 1941, an autopsy was carried out on a Sydney22 sailor. It is alleged that in relation to the autopsy, the23 Sydney sailor was recognised as a consequence of the body,24 ina putri d conditi on, sti 11 weari ng its Sydney- stenci 11 ed25 lifebelt. There is now evidence before the Commission of26 Inquiry from sailors who served on Sydney that lifebelts27 did not have any indication or stencilling of Sydney.2829 Along the way, there has been forgery. The Kitsche30 notebook, which was the subject of cross-examination of31 Mr Montgomery, was put forward as an authentic account of32 the battle by Kitsche, a survivor of Kormoran. It was33 purporting to be his diary. It was located, allegedly,34 under a house or in a cupboard of a wrecked house in Sydney35 soon after the Second World War. It now appears, at best,36 that it was an account from a journalist who was sitting on37 a bus travelling between Warrandyte and Melbourne, who38 heard people in the seat in front of him speaking of the39 engagement between Sydney and Kormoran.4041 Around 1980, WP Evans, formerly of the Australian42 Army, advised that he had found an HHAS Sydney kit bag on43 the beach north of Kalbarri containing a wooden box in44 which were authentic wartime memorabilia.4546 There was also a letter of proceedings, ostensibly47 typed by HHAS Sydney's last surviving officer, LEUT Elder .

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1 According to the Elder typescript, an hour after first2 sighting a Japanese submarine, Sydney came across the3 Kormoran, which was under a Norwegian flag; when4 challenged, Kormoran hoisted a Dutch flag and, after5 providing the flag hoist of Straat Ha7akka, hove to under6 threat from a suspicious Sydney; then, amongst other7 things, Kormoran opened fire with six salvos before8 surrendering to the then badly damaged warship; when in the9 process of sending an anti-scuttling party boat across,

10 Sydney was struck by a torpedo fired from Kormoran's11 underwater tube.1213 The bag, the box, its contents and the typescript were14 later proved by a team assembled at the Australian War15 Memorial, after expensive and considerable research, to be16 the result of an elaborate fraud.1718 The Christmas Island body has also been the subject of19 great suspicion as a consequence initially of the Royal20 Australian Navy denying that the body located on Christmas21 Island could have had any involvement with the loss of22 Sydney. It was a denial that was maintained by the Navy up23 until the Parliamentary Inquiry.2425 It is said by some theorists that the shrapnel, which26 has been located and examined by metallurgists, is not27 shrapnel at all, but it was a bullet. The theory, of28 course, was probably not assisted by a public press release29 of Mr Billson, the Assistant Minister for Defence, who,30 when the body was discovered, indicated in the press31 release that the skull of the body had a bullet located in32 the back of the head. The shrapnel which was located in33 the back of the head has been metallurgically examined and34 is not consistent with a bullet and its metallurgy is not35 consistent with any small-arms fire of the era.3637 It must be said that it appears throughout all this,38 for the years since the Second World War, Kormoran39 survivors have cooperated and spoken at length with40 conspiracy theorists and genuine researchers.4142 An example of the nature of the sensational and43 misleading and, on one viewpoint, fraudulent material that44 continues to pervade this arena was recently located by the45 Commission of Inquiry at the Naval and Maritime Museum at46 Ballina. In an article entitled "Half a Century of47 Silence, Unique Story of a Japanese Submariner in the

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1 Pacific War", an author purported to put forward an account2 of the granddaughter of a Japanese submariner.34 Sir, I might spend a little time in taking you to5 this. It is at WIT.024.0003. May I read extracts of the6 entire article. You will see that this is purported to be7 authored:89 Ny name is Nichiko Takahashi. I am a young

10 woman 25 years old. At the end of my11 studies at a university in Kyoto, where12 I majored in English, I took up a job with13 a Tourist Bureau. In 1995 I decided to14 leave Japan and spend six months or more in15 Austra7ia.1617 1995 was a special year for Austra7ians.18 It was the Year of Remembrance, marking19 fifty years since the end of the Pacific20 War. Anyone living in Australia, native or21 tourist, could not help being exposed to22 the mass of pub7icity, functions and23 parades commemorating the war.2425 If I can turn to page 2 and the second-last paragraph:2627 Ny thirst for knowledge of the Pacific War28 became insatiable. I spent most of my29 spare time at the State Library in Sydney30 where I delved into scores of books on the31 subject. Ny almost dany reading with the32 aid of my English-Japanese dictionary was a33 heavy task for me.3435 The next paragraph:3637 On one occasion an elderly Australian38 approached me in the foyer of the library39 to ask me whether I could translate some40 Japanese for him. His name was Peter41 Johnson. A retired teacher, he was doing42 research for a book he was writing on the43 Pacific War and had unearthed some44 propaganda leaflets in the Japanese45 language which needed translation. This46 I did willingly for him. I learned a lot47 from the exercise. We became friends and

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1 had many discussions. In case you think2 the English I write is too good for a young3 Japanese of limited experience, I must4 explain that all that I have written here5 has been checked and polished up by my6 senior friend, Peter.78 If I could ask that we turn to page 0006, in the middle of9 the page:

1011 One day my researcher friend was reading a12 book [WHO SANK THE SYDNEY by Hi chae 113 Hontgomery Cassells 1983] about the14 mysterious disappearance of an Austra7ian15 Naval vessel and the whole of its crew off16 the coast of Western Australia in 1941.17 Peter mentioned it to me. At first it18 seemed to be of little interest to me,19 because it happened in November 1941 more20 than two weeks before Japan began21 hostilities.2223 According to Peter: "The Austra7ian24 cruiser 'Sydney' had engaged the German25 Kormoran [an armed merchant ship] in a26 fierce battle at close range. Both ships27 were considerably damaged, but it was the28 German raider which surrendered. The29 surviving officers and crew had abandoned30 ship and were in the process of making31 their way in 7ifeboats towards the32 Australian vessel, when a seemingly33 inexp7icable thing took place. The34 'Sydney' was suddenly struck by a single35 well-aimed torpedo which set her ablaze.36 The German survivors saw her drift away.37 The cruiser disappeared from sight and was38 never seen again. "3940 It goes on over the next page, under the picture of the41 ship:4243 At first it might seem highly unlikely that44 it was a Japanese submarine, as the45 Japanese had not begun hostilities against46 Britain, America and Australia until47 18 days after this incident. On the other

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hand, British readers of the Japanese NavalCode knew full well that the Japanese Navalvessels were at this time already poised toattack and invade many areas in thePacific.

The alleged author, Ms Takahashi, then states:

The alleged involvement of a Japanesesubmarine seemed quite improbable to me.After what Peter had made me realise aboutthis cognitive dissonance, I had to admitthat I just didn't want to even considerthe possibility. I was happy to reject theidea.

Still, the thought about the possibility ofthe action of a Japanese submarine beforethe declaration of war remained embedded inmy brain.

The author then, over a number of pages, sir, sets out moreparticulars that she obtained from Peter Johnson concerningthe SydneylKormoran engagement.

She then indicates at page 0009, in the secondparagraph, that she had written to her grandfather, who sheindicated had been involved in the Japanese Navy. Then shesays:

Having no reply after three weeks, I wroteonce more, discreetly asking in typicallyJapanese style whether my recent letter hadarrived or not. Ten days later I receiveda letter from my grandfather asking meabout my health, urging me to take care ofmyself, describing the beautiful autumnweather and finally - just one sentence inreply to my vital question. He merely saidthat, during the war, he had been on dutyin the Pacific Ocean.

At the bottom of the page, Ms Takahashi indicates that shesecretly planned a campaign to find out more about theseevents from her grandfather.

At page 0010, at the bottom of the page, she states:

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12 Some weeks later, however, I made a fresh3 approach. It was the day after Grandfather4 had turned 80. I talked with him about5 life and longevity. He expressed his6 gratitude for such a long life. Without7 mentioning the war he even compared his8 life with the relatively short lives of so9 many of his contemporaries. He went on to

10 express his doubt that he had much more11 time on earth.1213 On the next page and the following pages, she sets out in14 detail the alleged conversation with her grandfather. At15 page 0013, in the second-last paragraph, this is stated in16 words attributed to her 80-year-old grandfather:1718 It is true that on November 19 1941 we were19 off the coast of Western Austra7ia. We20 were then witness to a great naval battle21 between a German and an Austra7ian ship,22 rather should I say witness to the end of23 that battle, when the German ship was24 ablaze and when the crew were abandoning25 ship. When I say we, I mean the officers26 who viewed the affair above through the27 periscope. The information was passed on28 to us like the reporting of the progress of29 a baseba 11 match.3031 What a position we were in. The gunfire32 had ceased. The Austra7ian cruiser, though33 badly hit, had won the battle. We were not34 supposed to be a player in this event, just35 a chance observer. Nevertheless, our36 Captain, for whom we had the deepest37 respect, must have come to a decision to38 participate. I believe the decision was39 based upon two things. One was that our40 country was already in partnership with41 Germany. The second was that we were42 itching for action. Why should we not help43 our partner Germany? The "Sydney" was a44 sitting target. One we77-aimed torpedo45 would finish her. Nobody would be any the46 wiser. The decision was made. The torpedo47 was fired from our vessel and the

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1 Austra7ian cruiser, mortal ly struck,2 drifted ablaze helplessly into the night.3 We shadowed its progress, until it was well4 away from the scene of the battle. As the5 vessel listed and began to sink, the6 surviving members of the crew were taking7 to the lifeboats and rafts. We surfaced8 and manned the guns. With deck gun and9 machine guns we sought out the life rafts

10 and slaughtered every 7iving soul in sight.1112 Our order was to see that there was not a13 single survivor. If anyone 7ived to tell14 the story, it would have jeopardised15 Japan's secret plans for attacks on Asia16 and Pearl Harbor. We were, of course, not17 yet at war with the United States and18 Austra7ia. All the next day we searched19 for wreckage and proceeded to sink it or20 fire it.2122 She goes on to give a further account of the rest of this23 man's War history in the Japanese Imperial Navy and24 concludes at page 0015, in the last paragraph:2526 As far as I know, I am the only 7iving27 survivor from our submarine. So I am the28 only one, I believe, who still knows what29 happened to the "Sydney" that night. I did30 my duty as ordered, but ever since peace31 came, I have looked back on our action with32 some regret and questioned the decision33 made by our Japanese Commander. I have34 nursed this secret for nearly fifty-four35 years now. I have never told anyone but36 you. I didn't ever want to tell anybody.3738 At the conclusion of the article on this page, there is a39 note to readers as follows:4041 The pub7ication of HALF A CENTURY OF42 SILENCE, with its sensational revelations,43 has been made possible only under strict44 conditions prescribed by Hichiko Takahashi45 of Japan, namely, that it may not appear in46 print in her native land while her47 grandfather was stnl a7ive, and that there

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EXHIBIT #121 ARTICLE ENTITLED "HALF A CENTURY OF SILENCE,UNIQUE STORY OF A JAPANESE SUBMARINER IN THE PACIFIC WAR"

Sir, that is the nature of some of the material that hasbeen put together over the years concerning Hf1AS Sydney.

The affidavit is at WIT.024.0001. Could I ask thatthe first page not be shown. I would like to go topage 0002. May I refer you to paragraph 9. Withoutreading it, sir, what Mr McAndrew details is that he hasbeen a person interested in the fate of Sydney and

Further investigations revealed that the author is aperson by the name of Alexander McAndrew. Staff of theCommission of Inquiry visited Mr McAndrew at his home inSydney and obtained an affidavit, he being unable to attendthe Commission of Inquiry due to infirm health.

I will mark that document exhibit 121.

must remain complete confidentialityconcerning the true identity of herself andher grandfather as we 11 as that of herAustralian researcher friend, PeterJohnson, who basically put the storytogether in Austra7ia. The names f1ichikoTakahashi and Peter Johnson which appear inHALF A CENTURY OF SILENCE, are pseudonyms.The story was submitted for publication by"Peter Johnson".

THE PRESIDENT:

As a consequence of the investigations of counselassisting and the Commission staff, it can be said that thestory is a total concoction. Nowhere in the paper, ofcourse, or in the article, is it stated that it is fictionor concoction. Indeed, on reading it and the explanationin the paragraph at its conclusion, it could be said thatthe author of the article has attempted to create somethingthat has an air of credibility, reality and truth. It isfar from that.

CMDR RUSH: When this article was provided to a member ofthe Commission of Inquiry, investigations were undertakenby the Commission of Inquiry in an attempt to ascertain whoMichiko Takahashi was and what was the substance of thematerial that had been produced in this article inconjunction with Mr Peter Johnson.

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EXHIBIT #122 AFFIDAVIT OF ALEXANDER McANDREW

I tender the affidavit, sir.

CMDR RUSH: Q. Mr Samuels, would you state your fullname to the Commissioner, please?

Sir, the first witness, for my part, who I desire tocall today is Mr Samuels, who is in the Commission hearingroom.

[12.35pm]<JOHN SAMUELS, sworn:

<EXAMINATION BY COMMANDER RUSH:

Nevertheless, it has been provided to the BallinaNaval and Maritime Museum under cover of a letter, andMr McAndrew attempts to explain its provision by sayingthat the letter stated that it was a story. That, hestates, is enough for any person, picking it up, to knowthat it was an account of fiction.

Then he goes on to state that he submitted the articleto the Sydney Morning Herald and the Canberra Times andthat it was only upon investigation by those newspapers andquestioning of Mr McAndrew, when he informed them that thearticle was fictional, that they refused to publish it.

CMDR RUSH: Sir, I read that for the sole purpose ofattempting to indicate the sort of material that counselassisting has been attempting to come to grips with whendealing with conspiracy theories and the like. It has beena difficult job. Nevertheless, we believe that we are in aposition to provide you with evidence and materialconcerning much of what has gone on and as briefly openedhere.

intrigued by it. In earlier parts of his affidavit, heindicates that he has disbelieved the accounts that havebeen provided through Gill and others and has preferredworks of Montgomery.

Nevertheless, in paragraph 9, he indicates that thearticle was never published, and although the article doesnot contain any text, that it is a work of fiction; thatit was never his intention that the article be viewed asfactual.

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A. John Samuels.

And your address?

Q. Your occupation?A. I'm a writer.

Q. Has that been your occupation for your life,Mr Samuels?A. Pretty well.

Q. I think I read somewhere that you have also describedyourself as a journalist?A. I have been a journalist, on and off, as they say.

Q. What is the nature of your journalistic background?A. Just general journalism and usually freelance.

Q. Is that newspaper journalism or television journalism?A. Newspaper.

Q. Mr Samuels, when did you develop an interest inrelation to the loss of HHAS Sydney?A. About 20 years ago.

THE PRESIDENT: Q. As a writer, is your interest inwriting fact or fiction?A. Fact.

CMDR RUSH: Q. What was it that created or brought aboutyour interest in the loss of Sydney?A. I think along with a lot of other people, I couldattribute that to the book by Michael Montgomery, "Who Sankthe Sydney?" I n fact, I often refer to Mr Montgomery asthe "godfather" of Sydney.

Q. Was it as a consequence of that interest that youpublished your book, "Somewhere Below"?A. As an eventual result of that, yes, although I mustpoint out, I don't, in any way, subscribe to most ofMr Montgomery's theories.

Q. Yet you refer to many of them in your book?A. Mmm-hmm.

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Q. And you assent to many of them?A. Yes.

Q. What do you mean that you don't subscribe to them?A. Times change. Information changes. The informationthat I have now is somewhat different than it was, say,20 years ago or even when I wrote the book in 1994/1995.

Q. The book was published, was it not, in 2005?A. 2005, sorry.

Q. So your views have changed, have they, since 2005?A. Mmm.

Q. I need to ask you, was it published - the copyright is2005?A. 2005. It was in an ongoing process of being written,Commander, for a very long time. It was published in 2005,but I had been writing it for probably six years.

THE PRESIDENT: Q. The copy I have says that it waspublished in 2007, although the copyright is 2005. Whichis correct?A. I have 2005. So it must have been published in 2007.

Q. Does that mean that your views have changed since2007?A. My views have changed in the last couple of months,si r.

CMDR RUSH: Q. In what substantive way have your viewschanged from those published in the book?A. Well, from the time of publishing the book, Sydney hasbeen found. We know a lot more now than we would have ifwe didn't have the wreck to be a guide for us. Forinstance, the decks fascinate me. They are not as burnedas I would have suspected they would have been. Thecondition of the ship was described by one expert as beingthe best condition of a shipwreck he had ever seen.

Q. Who was that?A. I don't remember.

Q. Where did it appear?A. In a newspaper. I would be able to recover it.

Q. What did that mean for you?

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A. Well, the story of a blazing ship, blazing stem tostern, as was told by the German survivors - drawings andpaintings that have been done since, admittedly, based uponthat description, "blazing stem to stern" - we see a shipthat wasn't blazing stem to stern; we see decks that looklike they were walked on yesterday.

Q. Have you read the report that was tendered last weekin this Inquiry from the Defence Science and TechnologyOrganisation and the Royal Institution of Naval Architects?A. I only had time to read part of it.

Q. How do you know what the damage to the ship was?A. Only by the photographs.

Q. How do you know what the damage to the ship was? Whatare you relying on?A. On photographs.

Q. What photographs in particular, in your view, show aship in remarkable condition? You have mentioned thewooden flooring of the decks. What else?A. And the paint.

Q. The paint of the ship?A. Mmm, there is paint everywhere.

Q. Did you see any burned paint?A. I can't say whether I did or I didn't.

Q. Perhaps I had better ask you: written on the back ofyour book, you describe yourself as an "intelligenceanalyst"?A. No, my publisher describes me as that.

Q. Didn't you have any say in what was written about youin your book?A. You have very little chance, Commander, of havinganything to say after you hand the book over. I was amember of APIO, which is an organisation with manydifferent members. At that particular time I had aninterest in terrorism and writing about it.

Q. Who is your publisher?A. Halstead Press.

Q. Halstead Press. What person did you deal with at that

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Q. What is his name?A. His name is Matthew Richardson.

organisation?A. With the boss of Halstead Press.

Q. Twenty. And where were they?A. The website.

Q. But you don't have any professional intelligenceski 11 s?A. No, none at all.

publishing things.

So in describing you as an "intelligencea piece of sensationalism from your

Q. How many photographs did you have the opportunity ofviewing?A. Perhaps 20.

Q. Are we to take it from the last answer that not onlyhave you been a journalist and a writer; you have also beenemployed by ASIO?A. No, I never said that. I said I was a member of APIO.

Q. And so your views are formed on your own observationsin relation to 20 photographs taken from the website?A. The observation that the decks and the paint are moreintact than I would have expected them to be if a ship was

Q. I beg your pardon. What is APIO?A. Australian Professional Intelligence association, orsomething.

CMDR RUSH: Q.analyst" that'spublisher?A. Well, it's

Q. What analytical skills in relation to the surveying ofwrecks did you bring to your observations of thephotographs of Sydney?A. Just what I can see, from what was originally said.

THE PRESIDENT: Q. According to the back of the book, itsays that you are a member of the Australian Institute ofProfessional Intelligence Officers?A. That's right. It is a group ofintelligence-interested persons. Some may work for ASIO,I don't know.

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ablaze from stem to stern.

Q. Did you think, before offering that sort of 0plnlon,that it might be an idea to have a look at the totality ofthe material that is available?A. No.

Q. Did you think that it might be a good idea to obtainsome expert advice in relation to what is depicted in thephotographs and video imagery?A. No.

Q. Because you are an intelligence analyst -­A. No, I never said that.

Q. -- and you can make up your own mind?A. You are saying that. I never said that.

Q. Why wouldn't you think it was a good idea to getexpert advice?A. Because every expert is going to have a differentopinion than the next expert, and the next expert will havea different opinion than that. There will be no generalconsensus.

Q. Well, we had nine experts sitting roughly where youare sitting for two days last week who reached consensus.Do you think it might be a good idea, before you offeropinion, from a non-expert point, to observe, read and takein what they have had to say?A. If I were going to put it in writing, I would do that.

Q. Mr Samuels, could we go to your book? Initially, Iwould like to take you to the prologue to the book, topage 7.A. Right.

Q. At the bottom of that page, you say:

But as we dismantle the legends and lies,the truth that emerges is unpalatable andshocking. It will outrage an entire nationand astonish the world.

The deceptions are unforgiveable - but thetruth is shattering!

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A. Mmm.

Q. Is what we are to read there the truth, or is it yourspeculation based on material that has come to your hand?A. I suppose it is a bit of both.

Q. At the top of page 7, you say:

Yet there is already an answer, yielded onland, to intensive research and historicalmethod.

A. Mmm-hmm.

Q. What you are outlining to the reader there is that, inrelation to the work that they are about to enter into, itis based on intensive research and historical method?A. Well, it was. There was an enormous amount ofresearch that went into this book.

Q. So my question is whether you would claim that what isset out in your book is based on intensive research andyour use of historical method to that research in reachingconclusions?A. Mmm-hmm.

Q. And that brings about what you have called the"shattering truth"?A. Mmm-hmm.

Q. Is that a little bit of exaggeration?A. I don't think so. I think it is not shattering truththat the Navy lied to the Prime Minister and the Cabinet in1942.

THE PRESIDENT: Q. In 1942?A. Yes, in 1942, sir. The head of the Navy - well, theChief of Staff of the Navy - we're talking aboutAdmiral Royal - deliberately told the Prime Minister anoutright lie, that a court of inquiry had taken place.No-one has ever come forward to say that it took place ..

CMDR RUSH: Q. Just to put some propositions to you fromyour book, Mr Samuels, the shattering truth involves this,does it: that the Sydney was sunk by a Japanese submarine?A. I can't prove it.

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Q. Did you speak to him after the finding of Sydney?A. No - oh, in relationship to other matters.

Q. Have you spoken to Mr Jack Wong Sue since that timeabout the loss or finding of Sydney?A. Yes, I have.

Q. Since the publication of this book?A. It wasn't until a long time after that book thatI spoke to him.

Q. When did you speak with him?A. I have been speaking with Mr Sue fairly often.I spoke to him two weeks ago.

the Sydney;in relation to the Sydney matter?

He offered the information aboutask him about it.

Q. The Sydney was found in March 2008.A. Yes.

Q. No,A. No.I didn't

They were subsequently ordered to go to Geraldton andhave a gun fitted to the ship. The ship was the largest,or the second-largest tanker, I think he told me, at thattime in the world. The gun was subsequently fitted andthen they were ordered to look for Sydney in the searcharea. He will be anxious to tell you this story in Perth.

Q. Is it that discussion with him that has persuaded youof what?A. That has persuaded me that there definitely was asubmarine there. Although, I must say, I would be thefirst one to say that I can't prove that it sank or hadanything to do with HHAS Sydney.

THE PRESIDENT: Q. Do you disavow that theory now?A. I don't disavow the theory since I've spoken to agentleman in Western Australia, sir. He is a well-knownAustralian, Mr Jack Wong Sue, former Australian militaryhero of Z Special Force, who was standing on the deck ­before he was in Z Special Force, he was standing on thedeck of a carrier which was carrying aviation fuel toAfrica. The first night out of Fremantle, during thewindow of opportunity for there to have been a submarinepresent during Sydney's demise, his ship was attacked bythis submarine - one night out of Fremantle.

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Q. So, insofar as there was any involvement of asubmarine in the sinking of Sydney, you now disavow that,although you maintain that there may have been a submarinein the area; is that your position?A. My stance on it now is that I still suspect, myself,that the submarine was involved somehow, and it's beingcemented by people like Mr Jack Wong Sue.

Q. Yes. How would he know?A. He was standing on the tanker, sir, that was attackedby the submarine.

Q. So because this man was standing on a deck of a tankerwhich was attacked by a submarine, you then jump to somesort of conclusion that that submarine must have beeninvolved in relation to the loss of Sydney?A. I didn't say that. I said I would be the first one

Q. What did you say?A. I said I would be the first one, sir, to say thatI can't prove that it had anything to do with Sydney atall.

Q. Do you have any concept of the notion of logic?A. Yes, of course.

CMDR RUSH: Q. Mr Samuels, you have, in your book,maintained that Sydney was hit by three torpedos?A. So said one of the Chinese laundrymen on board, yes.

Q. You rely on that in your book?A. Yes.

Q. Rather than, you say, the Chinese laundryman on board,you put forward that the three torpedos that were firedwere fired by a Japanese submarine?A. Correct.

THE PRESIDENT: Q. Do you maintain that position now ornot?A. In view of the finding of the wreck of Sydney, itwould appear - it would appear - at this moment in time asthough only one torpedo hit, so, therefore, I have toretract that idea of three.

Q. But do you maintain that the one which did hit, and

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Q. And that the German torpedo hit Sydney underneath

Q. Is that right?A. It could well have been.

Q. Do you believe it was?A. I believe it was, yes.

Q. No, it is not.A. I believe that the Sydney is partly buried in thesand.

Sydney

If you look at the pictures, you will see

It was only after the Japanese torpedos hitKormoran torpedoed Sydney.How do we know Kormoran fired a torpedo?

THE PRESIDENT:it is not.

Q.thatA.

Q. I want to detail the propositions: it was only afterthe Japanese torpedos hit Sydney that Kormoran launched herown torpedos?A. Say that to me again?

undoubtedly did hit, was fired by a Japanese submarine, ornot?A. I believe it could have been.

Q. What is the basis of that belief?A. The Chinese laundryman, to start with, who we justbrought up; the fact that we don't know what is underneathSydney, we haven't seen anything underneath the hull ofSydney. Some of Sydney is quite well buried in the sand.

Q. I am just recounting, I would suggest, what you havewritten in your book, Mr Samuel. Did you write that inyour book?A. If that's what it says, that's what I wrote.

CMDR RUSH: Q. You have also put forward the propositionthat Kormoran lowered a boat and it was on the way toSydney?A. Mmm-hmm.

Q. The three Japanese torpedos hit Sydney's bow - that'swhat you say, isn't it?A. Mmm.

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A and B turret?A. Mmm.

Q. That's what you have said in your book?A. Yes.

Q. Then that, later, I-58, the Japanese submarine,torpedoed Sydney againA. Mmm-hmm.

Q. -- after it had left the scene of the battle?A. Mmm-hmm.

Q. You put that?A. We now know that that is not absolutely so, is it?

Q. And somewhere, according to you in your book,something like 10 torpedos were fired at Sydney; correct?A. My assumption was at the time, yes.

Q. And then that the Japanese conducted what you describein your book as a criminal slaughter of the crew of Sydney?A. Mmm-hmm.

Q. Correct?A. Yes.

Q. That's what you wrote?A. That's what I wrote.

Q. And all this, you allege, was covered up; it has beencovered up since 19 November by Government and --A. No, I don't believe the Government was ever involved.

Q. The British Government, you allege, was involved?A. Mmm.

Q. Churchill was involved?A. Mmm.

Q. But not the Australian Government?A. Not the Australian Government.

Q. So Churchill was involved in the cover-up; is thatright?A. Yes, I believe so.

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Q. Admiralty was involved in the cover-up?A. Absolutely.

Q. And the Royal Australian Navy was involved in thecover-up?A. Absolutely.

Q. But the Federal Government was not?A. No.

Q. In your account, as you have indicated, you haverelied, in relation to torpedos, on one of the Chineselaundrymen that was in one of the German lifeboats and wastaken to Fremantle with the German prisoners?A. Mmm-hmm.

Q. Is that correct?A. Yes.

Q. Mr Samuels, the expert evidence that is before theCommission of Inquiry is to the effect that Sydney was hitby one torpedo?A. Mmm-hmm.

Q. Do you dispute that?A. If that is the expert evidence now, I accept it.

Q. And from your view of the photographs, did you see ornotice any torpedo damage to Sydney?A. Only the bow torn away.

Q. I am sorry?A. Only the bow torn away, Commander.

Q. No, I am talking about specifically did you notice orobserve any torpedo damage?A. Other than the bow torn away?

Q. Yes.A. Do you mean other than the bow torn away?

Q. From your observations, was there anything, when youlooked at the ship - you have spoken about your views andperceptions of what you saw - to suggest more than onetorpedo?A. No.

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Q. So do you say to the Commission, if you accept thatSydney was hit by one torpedo, that you recant in relationto the Japanese submarine?

Q. So who fired the torpedo?A. It's still my belief that it could have been fired bythe Japanese submarine.

Q. On what basis?A. On what basis for what?

Q. On what basis? What evidence can you put forward tosay that it was fired by a Japanese submarine?A. Well, I can say that there is no proof that Kormoranfired theirs.

THE PRESIDENT: Q. That's not really right, you know.We know that there were two ships engaged in a battle, andwe know that one was hit by a torpedo.A. Mmm-hmm.

Q. We know that the other one had torpedos, and we have anumber of witnesses, in the order of more than 10, who saythat torpedos were fired by Kormoran, so we do know thatKormoran fired torpedos, and we do know, on the basis ofthat evidence, that one of them hit Sydney.A. Mmm-hmm.

Q. What do you have to put in opposition to any of that?A. Who these witnesses are. Were they not once all theenemy?

Q. And so they should never be believed?A. Well, they are the only ones left to tell the story,aren't they, sir?

Q. And? What is the consequence of that?A. If they told an untruth then, they are probably stilltelling an untruth now.

Q. The problem that you have, if I may say so, is that wenow have some empirical proof.A. Well, I'm unaware of it.

Q. Well, it was presented here a week ago.A. Right.

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Q. Is that right?A. I believe so.

Q. Mr Shu Ah Fah at no time said that there was asubmarine involved?A. That's right. He never did.

Q. You are aware, are you not, that Sydney was incapableof firing three torpedos in a fan on the starboard side?A. I am, yes.

Q. The interrogation notes of Mr Shu Ah Fah indicate thathe saw Kormoran fire three torpedos?A. I believe he did, yes.

as being

would

Yet, nevertheless, you took Mr Shu's accountaccount that you would rely on?

I couldn't see any reason at the time why heali e about it.

Q. He was the person that you put forward as providingevidence of three torpedos, which you subsequently, in yourbook, say were fired by I-58?A. Mmm.

Q. Well, where do you think he got three torpedos from?A. At the time, I suppose, if I remember rightly,I thought that he would have seen the trail of individualtorpedos. As a consequence of having found the Sydney withthe bow torn off, perhaps all he saw was one almightyexplosion.

Q.theA.tell

Q. And you rely on his visual account of Kormoran firingtorpedos?A. Well, if you look at it from the point of view that hesaid that Kormoran fired them and he didn't see thesubmarine, I'm assuming that he saw the torpedos hit

CMDR RUSH: Q. You have indicated that you rely on thenotes of interrogation of Shu Ah Fah, the Chineselaundryman.A. Mmm.

Q. As I understand it, you rely on those notes inrelation to torpedos that were fired at Sydney; is thatcorrect?A. It is.

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Sydney, but he assumed that they came from the Kormoran.

Q. So that chain of assumptions you gain from what?A. From his observation.

Q. From his interrogation notes?A. Mmm.

Q. You haven't spoken to him, have you?A. No, of course not.

Where is the passage in the book?THE PRESIDENT:

Shu Ah Fah states raider fired threetorpedos in quick succession on cruiser'sstarboard quarter. These hit cruiserforward at about the same time as she wasstruck by raider's first salvo, and aterrific explosion fol lowed.

Q. I wonder whether we can have that enlarged.I want to read this paragraph with you, Mr Samuels.A. Where are we, Commander?

THE PRESIDENT: No, where is what Mr Samuels wrote in hisbook about three torpedos?

Q. The only thing that you had to go on - and I ask thatit come up on the screen, sir, BATT.006.0059 - was a noteof an interrogation of Mr Shu Ah Fah?A. But why would Mr Shu Ah Fah have lied about it?

Is that what you have relied upon, Mr Samuels?A. It could well be. I don't remember this particulardocument.

CMDR RUSH: At the bottom of the first page, the lastparagraph, if that can be brought up.

CMDR RUSH: What Mr Samuels wrote in his book is atpage 93, sir.

Q. It's on the screen in front of you: Shu Ah Fah'sstory of action conforms in general to that told bySBLT Bunjes and the sighting at 16:00 to the time ofopening fire. It varies considerably from that timeonward.

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Do you say that there is logic in that reasoning?A. There is.

Q. You quote it at page 93.A. Do I?

Q. And the other three torpedos were fired by theJapanese submarine?

Q. Under the photograph of your book, page 0093.A. Yes. Then I relied upon that document, yes.

the InquiryQ. What else was it?

other evidence, which I believethe late Pastor Ivan Wittwer.

So at the very beginning of the action, atthe same time as Kormoran's first gunnerysalvo, Sydney was struck by three torpedos.Yet Detmers tells us that Kormoran firedher first and only torpedos after ninesalvos from her guns and after turning to260 degrees - and then only two of them.Shu Ah Fah saw the three earlier torpedoshit Sydney with his own eyes. Unaware ofI-58's presence, and unaware that Detmersreported firing only two torpedos later on,Shu Ah Fah had to assume that the otherthree torpedos came from Kormoran.

Q. No doubt we will come to him, but he is not mentionedat this point in your book?A. No, that's not what I'm saying, sir. What I wouldhave said here was, if I was relying upon this only tointerpret that there was a submarine there, it would havebeen rather ridiculous and I wouldn't have done that, andI would have had other information to suggest that thesubmarine was there.

THE PRESIDENT:A. There washas seen, from

CMDR RUSH: Q. I will go on with the paragraph thatI have been reading from, Mr Samuels:

Q. What is it about that account that in any way permitsyou to interpret the involvement of a Japanese submarine?A. Well, it wouldn't have been just this that I wasrelying upon at the time.

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LUNCHEON ADJOURNMENT

A. Exactly.

Q. Shu Ah Fah was the laundryman?A. Mmm-hmm.

Q. Whereas the account that you rely on is that ofShu Ah Fah and that he saw Kormoran fire three?A. Three.

We will adjourn for lunch and resume at

Q. The laundryman, according to you, to rely on hisaccount, must have had a view of the battle?A. Well, he said he did.

Q. Yes, but the point is a somewhat different one. Ithas nothing to do with the presence of a Japanesesubmarine. What you have to say is that Shu Ah Fah saidsomething; he was absolutely wrong, although you say he wasright, and the torpedos came from somewhere else. Do younot follow that?A. No, I'm afraid I don't. I'm afraid I don't.

THE PRESIDENT:2 o'clock.

THE PRESIDENT: Q. I just don't understand. What youhave done in the paragraph just read to you is to say thatShu Ah Fah saw three torpedos hit Sydney. In the nextparagraph, you have said that he had no reason to lie, soI assume that you are saying that Shu Ah Fah was tellingthe truth. But then you make a jump and say "Well, he isactually wrong, because the three torpedos came from aJapanese submarine." There is no logic in that.A. I can see that still happening, sir. I'm not going toretract it. If he didn't know about the submarine, hewould have assumed that they came from the Kormoran.

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Q. But on what basis?A. Opportunity.

Q. But do you have any evidence of any positive naturethat there was?A. Not positive --

Q. Therefore one must have sunk Sydney?A. Well, not necessarily, but it was certainly worthwhileexploring, and it led me to the conclusion that there couldwell have been one involved.

THE PRESIDENT: Q. That can't possibly lead you to theview that there was a Japanese submarine involved in thisengagement?A. It would have been part of the reason, sir.

get your theorysubmarine from?

Mr Samuels, where did youinvolvement of a Japaneseit's that far back.

Q. Well, there may have been a lot of opportunities fora lot of people to do a lot of things. That doesn't meanthey did them. Is there any positive evidence of anynature at all that you can point to suggesting theinvolvement of a Japanese submarine, apart from the factthat you say people can't locate them?A. Montgomery had some arguments, some of whichI subscribed to then, some of which I dismiss now.I suppose that led me to conduct further investigation intoit.

Q. Or is it just the circumstance that you don't thinkpeople could account for them all?A. Well, I know they can't account for them all, eventhough --

UPON RESUMPTION:

CMDR RUSH: Q.that there was anA. Hard to say,

Q. Sorry?A. It's hard to say, it was that far back. From whatI remember, I thought it was highly suspect that it was17 days before Pearl Harbor. I thought it was even moresuspect that there was an insistence by all of the gurus ofsubmarine movements that it was quite impossible that allthe submarines had been accounted for. Now, all thesubmarines had not been accounted for, and that's a fact.

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THE PRESIDENT: Yes, I know.

... object appeared to be a submarinesteering west.

Q. Which one are you referring to?A. I'm having trouble seeing here, Commander.

THE WITNESS: And one of the submarines was reported asheading west.

Where are we?

It is SPC.006.0005.

THE PRESIDENT:

THE PRESIDENT: Q. Would you like it blown up a littlebit more?A. If you could, sir.

Q. What is it about this document that in any waysupports your theory?A. This document supports the fact that we havea submarine here heading west when they were all supposedto be heading east.

Q. This is something that you picked up fromMr Montgomery's book, is it?A. No. This comes from Mr David Kennedy.

Q. Mr Kennedy provided it to you for what purpose?A. As part of the support for my theory that a Japanesesubmarine may have been involved in the ultimate demise ofHHAS Sydney.

CMDR RUSH: Sir, it is on Summation. It is a signal of20 November 1941 indicating the suspected whereabouts ofsome Japanese submarines. I will perhaps come back tothat. It shows to submarines in the Pearl River Delta. Itshows submarines nowhere near the Indian Ocean, and one ofthe bearings is in fact in the middle of Africa.

Q. But having conducted that investigation, which you sayyou've now done, what evidence is there?A. I think the Inquiry has a document that you havereceived from Mr David Kennedy. I might hand a copy ofthat to CMDR Rush.

CMDR RUSH:

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Q. Somewhere south of the Philippines?

Q. Why not?A. Because it's not in the book.

Q. Did you do so?A. No.

Q. Did you think that that might be a good idea --A. This doesn't appear in the book, either, Commander.

Four lines from the bottom, sir.

Q. Heading west from where?A. I'm led to believe by LCDR Ean McDonald that it issomewhere south of the Philippines.

Q. Then where is the submarine?A. It's heading west, when all of these submarines weresupposed to be stationary or heading east.

Q. -- historical rigour, that it would be a good idea tolook at the bearing that the signal is referring to?A. I answered that.

Q. Did you by any chance, in adopting the historicalrigour that you referred to in the prologue, look at thebearing of the submarine that was heading west?A. No, I didn't.

Q. No, my question is a direct one. Do you think,adoptingA. Yes, I do.

Q. No, but you had the document. It is not in the book,but you have the document and you're purporting to put itforward to support your theory of Japanese submarineinvolvement in Sydney. That's the reason you've handed itto me?A. That's right.

CMDR RUSH:

Q. Do you think that it might be a good idea, before youuse a document to purport to support a theory that you arepropounding, to check where the submarine that is headingwest is initiating its course from?A. I'm led to believe from --

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A. Mmm-hmm.

Q. And you're led to believe that by whom?A. LCDR Ean McDonald.

Q. You mean LCDR Ean McDonaldA. Retired.

Q. -- from Western Australia, retired?A. That's right.

17 degrees north, 94 degrees east.THE PRESIDENT:

Q. That's your evidence. Does Mr McDonald havenavigation experience?A. Apparently.

Q. How did he advise you of that?A. I gave him the letter. He navigated the coordinates.

CMDR RUSH: Q. So Mr McDonald advised you that it wasoff the Philippines; is that right?A. That's right.

THE PRESIDENT: Q. Mr Samuels, I asked you, after somediscussion, if you had any positive evidence, and you saidthat you did. What you said you had was a document givento you by another gentleman, and you then produced thisdocument. It doesn't say that there was a submarine. Itspeaks of two coast watch stations in approximate positionswhich apparently are somewhere off Burma, or Myanmar, eastof an object appearing to be a submarine steering west.That's not positive proof of anything. Is that all youhave to support the notion that a Japanese submarine wasinvolved in the sinking of Sydney?A. I researched the submarine I-58. I came to theconclusion that when the I-58 encountered the two capital

Q. It is off Burma, north-west of Burma. Did you notthink that it might be a good idea, before you offered your0plnlon as to that somehow supporting an involvement ofthis submarine and before you put it forward as somehowbeing involved in the sinking of Sydney, to look up whereit was located on 20 November 1941?A. I never said I put this submarine as being involved inthe sinking of Sydney. I'm just saying that this is proofthat submarines can't be accounted for.

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ships - Prince of Wales, and the other name escapes me fora moment - and they only had a few torpedoes left. I can'tprove that I-58 was involved, either. This is entirely myown theory.

Q. Yes, I understand that, but I'm trying desperately tosee if there is any basis for it, of any type. You see,I have to write a report about all this, and you've comeforward, as I understand it, and you say that a Japanesesubmari ne was i nvol ved. So I woul d say to you, "What isthe basis for saying that?", and there is nothing you canproduce?A. Not of any concrete evidence, sir, no.

CMDR RUSH: Q. Mr Samuels, I want to conclude the matterI was dealing with before we adjourned for lunch. You areprepared to attribute an eyewitness account of the firingof torpedoes to Mr Shu Ah Fah; is that right?A. I was reminded over lunch that Mr Shu Ah Fah not onlyspoke English very well; he was also the quartermaster ofthe Eurylochus, one of the ships taken by the Kormoran, andhe could very well have been seen on the deck, because I'malso reminded that Detmers said so.

Q. Who reminded you of that?A. A person within the court.

Q. Who was that?A. Mrs June McCluskey.

Q. Who is that?A. (Indicating).

Q. How do you know that Shu Ah Fah spoke very goodEnglish?A. I believe - how do I know that? I have read it, thathe spoke English. It may have been in the Navy report.

Q. How do you know that he spoke very good English?A. Well, I don't.

Q. I ask you to go to page 91 of your book. In the thirdparagraph, you wrote there:

That statement has three interesting parts.Kormoran's crew for the most part could seenothing from their stations, because in

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a warship ready for action, few of the menare stationed on deck or in places thatcommand a general view.

So you state that very few of the Germans would have seenthe action, but you put forward that the laundryman wouldhave had a good view of the action?A. Well, I would have been taking a look. Wouldn't you?

Q. I'm sorry?A. I would have been taking a look to see what was goingon.

Q. You say that when this ship was at camouflage andattempting to prevent any form of identification fromanother warship, the laundryman would have been permittedto be on deck?A. Yes, but I also recall Detmers saying at some stage orother that he had deliberately done that as a ploy to getthem out there.

Q. And you would further say, I suppose, that not onlywas he on deck, but this eyewitness to the perfidy of theGermans was taken in the lifeboat and rescued by theGermans and landed in Australia?A. That's right.

Q. Did there strike you as being any form of unusualnessin the Germans doing that, taking a witness to theiractions and saving his life in their lifeboat?A. I don't have an explanation about it. I wasn't there.

THE PRESIDENT: Q. Mr Samuels, would you mind going topage 93. This is the matter I was addressing with youbefore the luncheon adjournment.A. Yes.

Q. This is the passage that was read to you, whichpurports to be a copy of what Mr Shu Ah Fah said in hisstatement, underneath the photograph?A. As far as I know, that is what he stated.

Q. According to that, Mr Shu Ah Fah said that Kormoranfired three torpedoes, which he saw, and those threetorpedoes hit. In the next paragraph, you say:

[He} had no motive to lie ...

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A. Yes.

Q. No, he's not. He said:

The Kormoran fired three torpedoes when thecruiser was on her starboard quarter.

Q. So how do you get from there to a Japanese submarine?A. It was my assumption that the submarine was there.

absolutely nothing to dosubmarines are concerned?

So Shu Ah Fah's evidence hasanything, so far as JapaneseBasically, none.

Q. Which is, according to him, that Kormoran did firethree torpedoes and they all hit Sydney, which you nowrej ect?A. Well, we know three torpedoes did not hit Sydney.

He's saying that. He's not making any assumption. He'sstating it as a fact.A. All right, my assumption is that they were fired froma submarine.

Q. So Mr Shu Ah Fah was wrong?A. In the torpedo count, yes.

Q. So when you say that he had no motive to lie, you arein fact saying that he is either mistaken or telling anuntruth?A. No, I think he was telling the truth.

Q. Yet before lunch, that was the only thing you couldpoint to relating to the existence of a Japanese submarinebeing involved in this engagement; and after lunch, youcome up with a document which relates to a submarinesomewhere off the Burmese coast.A. Only to demonstrate that submarines are not accounted

Q.withA.

Q. So do you accept the evidence of Mr Shu Ah Fah or doyou not?A. I can see where you're coming from, sir, that hestates that the Kormoran fired three torpedoes when thecruiser was on her starboard quarter. He is making theassumption that those torpedoes originated from theKormoran.

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for.

Q. That concerned the disguise of Straat Halakka, didn't

CMDR RUSH: Q. Mr Samuels, at page 66 of your book, atthe bottom of the page, you say this:

Q. Yes, and if they are all accounted for, it's anabsolutely sound argument. But if they are not allaccounted for, it doesn't mean that there was a submarineinvolved in the Sydney action?A. I would agree.

no.

is there anything that you canthe existence of the involvement

Two days before Kulmerland's departure fromKobe, Wenneker asked her commander,Captain Pschunder, to come to Tokyo andjoin him for afternoon tea at the mission.There Wenneker entrusted a hand-to-handdiplomatic pouch to Captain Pschunder, tobe given only to Captain Detmers ordestroyed without opening should there beany likelihood of it failing to reach him.Amongst other things, the pouch containedorders from the German Naval Attache tocollaborate with I-58 to sink the troopship AquHania.

What evidence do you have of that meeting and thatdiplomatic pouch?A. I'm not entirely sure I remember what the source forthat was, but part of it was something that Detmers wrotehimself, whether it was in his book or somewhere else,about very valuable information or very valuable documentshaving been delivered to him.

Q. So I ask you again:point to which indicatesof a Japanese submarine?A. Nothing solid, sir,

Q. But do you not see that inability to account forsubmarines doesn't mean that a submarine was involved? Doyou not understand that?A. No, but it has been used for many, many, many years,sir, as the catalyst for people to say there could notpossibly have been a submarine intervention - the fact thatthey're all accounted for.

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it?A. It may. I don't remember.

Q. Mr Samuels, what I want to suggest to you is that youdon't remember half the sources that it came from, becausethere are no sources?

Q. And do you say that that brings historical rigour tothe writing of your book?A. There's nothing wrong with the information that I hadat the time.

Q. What is the difference between making something up andmaking an assumption when you have no basis for theassumption?A. I don't know, sir.

Quitecame

Q. The bottom of page 66 and the top of

last part of that you can attribute to me

Q. In other words, it would be fair for usthat you put something in your book as a matterwhich you had absolutely not one scintilla ofsupport?

Q. You just made it up, didn't you?A. No, I didn't make it up. I made an assumption.I don't make up things, sir. I just make a calculatedassumption on what I'm told at the time.

CMDR RUSH:to concludeof fact forevidence inA. Yes.

Q. What information did you have at the time?A. You're asking about an old book now, Commander.frankly, I don't remember where half of these sourcesfrom.

THE PRESIDENT:page 67.A. Well, theonly.

Q. My question is very direct: you have assertedsomething as a matter of fact at the bottom of page 66 ­that, two days before, the Captain of the Ku7mer7and metwith Wenneker and was given a diplomatic pouch and told todeliver it to Detmers, and it said that Detmers was torendezvous with I-58 for the purpose of sinking Aquitania.What evidence do you have of what you put there as fact?A. You're asking for some old information here. Whatpage are we on, again? Is this 67?

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Q. I have written down CAPT Snook; bodies buried on the

A. There have been a lot of sources, Commander.

Q. Do you maintain that they're buried?A. I do, si r.

Q. And that some people buried them?A. I do, si r.

HowI wouldn't agree with that, but that's by the by.to distinguish it?I don't think there is a way, sir.

Q. Do you maintain that there are bodies on the WesternAustralian coast who are bodies from the Sydney?A. I do, si r.

Q.am IA.

Q. Let me get a list of all the things that you presentlyadhere to, because they're the ones that I will have todeal with. CAPT Snook?A. Yes.

Q. Is there anything in this book that you presentlyadhere to?A. CAPT Snook.

THE PRESIDENT: Q. It is not history. Whatever it is,it's not history. It is an assertion of fact which, asI presently understand it, you had no basis for asserting.A. I'll agree that it is only my assumption.

Q. Well, this is a fairly important piece of history thatyou have set out there, isn't it?

Q. Anything else?A. Definitely CAPT Snook and definitely our explorationfor the remains of Sydney sailors on the West Australiancoast.

Q. So if I am to do an analysis of this book, how am I todistinguish between that which is your assertion and thatwhich you say has some basis in fact?A. I think up until the time Sydney was actuallydiscovered in March last year, every book and every pieceof paper ever written about HHAS Sydney has had 90 per centassumption.

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Q. Well, are you content, then, if I disregard all inthis book save those two matters?A. I don't know if I would use the word "disregard", butcertainly I've changed my opinion about a great many thingsin there.

Q. You see, Mr Samuels, one can draw inferences fromestablished facts, but you can't give me any facts whichyou can establish even from which an inference could bedrawn, let alone direct evidence.A. The trouble is, sir, there has been so much of it overthe many, many years --

Q. So much of what?A. So much small pieces of this and that and somethingelse, that you cannot help but draw a certain opinion.There might be 20 things that say "yes" over here, and15 things that say "yes" over there. I put those thingstogether, but I will agree they're my own assumptions.

Q. Unless you can give me some factual basis for theseassertions - and to date you have not been able to do so ­I can see no basis on which I should waste my timeconsidering them.A. I cannot prove that a submarine interacted withKormoran. I cannot prove that a Japanese submarine, ora U-boat, for that matter, had anything to do with theultimate demise of HHAS Sydney.

What else is there, if anything?think they're certainly the two most importantI've been involved in in the last X amount of years.

beach.A. Ithings

Q. But the problem is that when we go to those bits, asyou call them, and I ask you what the factual basis forthem is, there isn't one, so they're not "bits"; they arejust speculation by somebody - it may not be by you, but bysomebody - and you then take speculation and heapspeculation on that. There is no kernel of truth in thebasic fact at all?A. I wouldn't say that. I would say that when you hearthe story from one person, it's one story, which you tendto disregard, but when you hear the same story froma number of different people, it's reasonable that you makean assumption from there that this is a possibility,a strong possibility.

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Q. I won't let you go without glvlng you the opportunity,Mr Samuels. I want to ask you just a couple of othermatters about --

CMDR RUSH: Q. What about the signals - Mr Lane inSingapore?A. Yes, Mr Lane.

Q. We don't have a Japanese submarine, to start with.A. Well, it would be difficult to carryon from there,wouldn't it, so I'll have to pass that one.

Q. Do you still adhere to that?A. Yes, absolutely. In fact, I have had a communicationfrom Mr Lane in the last few days. I'll just find thatcommunication.

is no evidence at all, unless you can provide methat Sydney was ever in the company ofThe evidence is quite the contrary, that after

Q. What about the previously expressed notion thatKormoran and the Japanese submarine were diverted togetherto sink the Aquitania - can I put that to one side?A. You can, sir.

Q. What about the notion that China Station sent somesignals to Sydney to diverge from Largs Bay and go andintercept, I assume, the Kormoran? What about that one?A. There is good reason to believe - and I don't rememberthe source of it, either, but it is there somewhere. Thesource of it is that someone gave a statement, who wasaboard Largs Bay, that Sydney left in a great hurry.

THE PRESIDENT: Q. Just before you do that, I want to beonce and for all satisfied that we understand the positionthat you are presently taking. I have noted CAPT Snook.I have noted bodies buried on the beach. I have now notedvoice signals from Sydney. Is there anything else?A. They would be the three I'd like to concentrate on,si r.

Q. Therewith some,Largs Bay.

Q. That is not the way either the law or history works,I'm afraid. Anyway, there are two matters you've raised sofar - CAPT Snook and bodies buried on the beach. Is thereany other?A. They're the two that most concern me, sir.

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Q. So you have examined the file, the Army records, ofCAPT Snook?

Q. Zealandia?A. Zealandia.

CMDR RUSH: Q. Would you turn to page 110 of your book,please. In the third paragraph, you state as follows:

Q. I'll put that to one side, then. Are there any otherthings that you wish to maintain?A. No, I'd like to concentrate on CAPT Snook, sir, ifI may, and the burials in Western Australia.

Very well.

she handed over Zealandia, she turned immediately aroundand went straight back towards Fremantle, unaccompanied.A. I was under the understanding that Largs Bay sightedthe Sydney and the other ship that you just mentioned, sir.

When Captain Laurence Snook was servingwith the Australian Army Hedical Corps, hewas ordered to perform an autopsy on a malebody. There wasn't anything unusual inthat for an officer who had done manyautopsies as routine. The only reallydisturbing aspect of this one was that thebody was from HHAS Sydney!

THE PRESIDENT:

Q. That's when they were going up towards Singapore. Theaccount you gave is a different one - about Sydneyseparating from Largs Bay after she had handed overZealandia.A. I may have made a mistake, then.

What evidence do you have to say that CAPT Snook routinelyperformed autopsies?A. His sister, who is the main source of thisinformation, whom he told that he had performed thisautopsy, assures me that he had performed many autopsiesbefore this, and no doubt he performed many autopsies afterthis. He was a very skilled man, even though he was anagriculturist. If you have a look at his file, sir, youwill find that he was promoted very quickly to assistantpathologist, if I remember rightly from the file. He wasa very skilled man, indeed.

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A. Mmm-hmm.

Q. Do they suggest anywhere that he was routinelyinvolved in autopsies?A. No, his file doesn't.

Q. CAPT Snook was not a medical doctor?A. No.

Q. Did he have any qualifications at all at the time hewas in the Army?A. I don't know.

THE PRESIDENT: Q. Pathologists don't normally conductautopsies.A. Yes, if hi s fil e appoi nted hi m as, hi s fil estates,assistant pathologist.

Q. What I said was that pathologists do not normallyconduct autopsies.A. No, I'll have to accept that, sir.

CMDR RUSH: Q. I suggest that the only evidence you haveof his sister is that he told her that on one occasion thathe had conducted an autopsy on a hippopotamus. Is thatwhat you've referred to as "routinely conductingautopsies"?A. I've never heard the hippopotamus story before.

Q. On what basis do you say that he routinely performedautopsies as an assistant pathologist?A. His sister told me.

Q. How does his sister come by that information?A. He told her the story of performing the autopsy ona Sydney sailor's body.

THE PRESIDENT: Q. Was that one sister who told you thator both?A. Yes, there were two sisters, sir, but he toldGrace Richardson, Mrs Grace Richardson.

Q. Is she the one who told you?A. She's the one who told me.

Q. Do you have some note of that?A. Yes, I do.

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CMDR RUSH: Yes.

Dear John,

Q. While you were present?A. No.

CMDR RUSH: Q. And who conducted the interview?A. Professor Bruce Horsfield.

I ask that CORR.016.0040 be put on the screen,

THE PRESIDENT: Professor Horsfield is the gentleman whogave evidence before Christmas, is he not?

Q. He conducted the interview of Mrs Richardson?A. That's right, under my instructions.

I believe that your story about the autopsyon the sailor at the old Hollywood RepatHospital stacks up and is the mostimportant and sensational revelation to

Q. Would you go to the bottom of that page. Do you seeit is an email from John McArthur to John Samuels of 22 May2006, which reads:

Q. Do we have that?A. You should have a DVD of it, provided byProfessor Bruce Horsfield.

Q. What was the purpose of the DVD?A. Bruce was here in Sydney - Professor Horsfield washere in Sydney. I wasn't. There was an opportunity tointerview her and record that interview. Subsequently, heconducted that interview.

Q. And you had correspondence with John McArthur in Perthconcerning the Snook autopsy, didn't you?A. There was something, yes.

CMDR RUSH:si r.

Q. You not only correspond with Professor Horsfield, butyou also, from time to time on matters concerning Sydney,correspond with Dr John McArthur in Perth?A. I do.

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emerge since Sydney's loss.

The problem as I see it is that there hasto be certainty that it is a Sydney person.All I need is your reassurance that theinformation you have is:

It was a body of a Sydney sailor and nota body of a German sai lorThe approximate date of the autopsy.

Does this bring back any memories for you, Mr Samuels?A. Vaguely.

Q. You replied to John McArthur, if we go to the topof page 0040, and also forwarded your reply toMr George Karlov. He is your publicist, is he?A. Yes, and agent.

Q. Sorry?A. And agent, Commander.

Q. In your email of 22 May 2006, you thanked John for hisemail :

and most importantly your observationthat Capt Snook's autopsy of a Sydneysailor did take place.

I would ask you to go down that email to approximatelyseven lines from the bottom of it:

... quell the truth about Sydney and thosewho seek the truth into the matter. DavidKennedy is persona non grata as far asI and a number of other people areconcerned, and I would appreciate yourcomplete silence as to anything you andI speak of in any way. Bruce Horsefield ismost trusted on the other hand, we trusthim in all things. There is more to knowas far as the Sydney body is concerned butin answer to your second inq regardingwhen ... my best guess is 2-3rd week ofDecember or even later, the cadaver semiadipocre and partial mummification inprogress with a 77 due respect to current,

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water temp and atmos temp on a descendingtj de schedu 7e.

Q. But you must have had a basis for --A. No, I had no basis at all. It was a terrible mistake.

Q. Well, when did the autopsy take place?A. Best guess, March/April the following year, '42.

You sent that letter to Mr McArthur?A. Mmm, made a terrible mistake in it, too.

That's all I can say.

be possible. You're writing aboutThat could hardlyvery topic?It was a mistake.

THE PRESIDENT: Q. You just made it up?A. No, I didn't make it up. I just made a terriblemistake. I was probably thinking of another date forsomething else.

Q. What's happened is that you have found out bysearching the Army records of CAPT Snook that he wasn't inthe country in the second or third week of December; isn'tthat the position?A. I had the records long before this email was sent.

Q.thisA.

Q. You have found out that CAPT Snook was not in thecountry in the second or third week of December?A. I knew that, yes.

Q. Well, what was the basis of your guess that theautopsy had been carried out in the second or third week ofDecember?A. Actually, just what I said to you. I said it wasa terrible mistake.

CMDR RUSH: Q. It's a mistake, which I suggest,Mr Samuels, is untruthful evidence?A. No. It's just a mistake.

Q. What was the terrible mistake?A. About the second or third week of December. I had notat that stage done the research that I have done now.Snook was not here in the second to third week of December.The body obviously came into his possession having alreadybeen buried at some earlier time.

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12 THE PRESIDENT: Q. I would like to have it established,3 as a start, that there ever was an autopsy?4 A. I believe there was.56 Q. I know you believe that there was, but I want to know7 the basis for it. Would you go back, please, to the letter8 you wrote to Mr McArthur. He says:9

10 I believe that your story about the autopsy11 on the sailor ... stacks up and is the most12 important and sensational revelation ...1314 Now if we go back to your response to that, you say:1516 Thank you for your email and ... your17 observation that Capt Snook's autopsy of18 a Sydney sailor did take place.1920 He didn't observe that at all.21 A. Agreed.2223 Q. Well, why did you write that? He hadn't confirmed to24 you that there had been any autopsy.25 A. That's what I wrote.2627 Q. Do you understand that it has no sequential logic at28 all? On your account to date, you have a sister of29 CAPT Snook telling somebody else, not you - apparently30 Professor Horsfield - on video that their brother, then31 dead, had said that he had carried out an autopsy on32 a Sydney sailor. You then wrote to Mr McArthur indicating33 that, and he wrote back to you, and you said that he34 confirmed to you that the autopsy had taken place, when he35 hadn't. Then you have sai d, "My best guess is that it took36 place in December", when (a) you didn't know there had been37 an autopsy and (b) you had no idea when it had taken place?38 A. The date, as I said, sir, is my mistake. The39 assumption that I put here, "Thank you for your email and40 most importantly your observation", yadda yadda yadda, was41 just an error of my way of writing this particular email.42 I don't see where this is relevant to the body at all.4344 Q. I'm very keen to see if there ever was a body on whom45 an autopsy took place. At present, I don't see any46 evidence that there was or that a pathologist would have47 been likely to have been carrying one out?

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A. Well, who else would have carried it out?

Q. "A belt", being a lifebelt or just a belt?A. A 1ifebelt.

CMDR RUSH: Sir, he returned to Australia not before23 May 1942, and he had departed for the Middle East on19 October 1940.

Q. Where did you obtain the information, then, that theydid?A. That they did, I had from ages ago, and I can't

When was CAPT Snook overseas?THE PRESIDENT:

Q. Quite.A. Then again, I also have information that says thata belt was issued to some sailors back in those days, aship's issue. It could well have had the ship's name onit.

Q. Precisely. Therefore, you say that there must havebeen one?A. No, I say there must have been one because CAPT Snook,to all intents and purposes, as far as I can determine, wassqueaky clean and had no reason to lie to his sister aboutit.

THE PRESIDENT: Q. So if he carried out an autopsy, thebody was more than six months old. Where do you say thisbody was found?A. I don't know where CAPT Snook got the body from, butit's quite clear that it was almost certainly buriedbefore.

Q. Why do you say that?A. Had it been exposed to the elements for that long, itwould be very doubtful if he could have made the statementthat he did that it had a Sydney lifebelt on the body.Now, I recently - well, not recently - came into possessionof information that perhaps the lifebelt didn't have theship's name on it.

CMDR RUSH: Q. Where did you obtain the information thatthe lifebelts didn't have the ship's name?A. I think I might have read it in the Inquiry's notes onthe internet.

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remember the source.

Q. You don't know?A. I don't know.

CMDR RUSH: We have what Professor Horsfield has providedus with, si r.

CMDR RUSH: Could we have document PTE.005.0055 on thescreen, please?

Do we have Professor Horsfield's

Mrs Grace Richardson.

Q. Do you see there the first page of the officer'srecord of service of Laurence Cecil Snook, and do you seethat his civilian employment at the time of his entry intothe Army was an agriculturist? Did you observe that,

THE WITNESS:

THE PRESIDENT: Overnight, someone might check and see ifthere is an interview with Miss Grace Richardson.

THE PRESIDENT:interviews?

THE PRESIDENT: Q. Why? Why would you assume that?A. So that they could account for them.

Q. Then the source that you refer to in relation to theirbeing on ships and in some way or another being stencilledwith the ship's name - what is that source?A. It was a written source. Perhaps it was in a book.Perhaps it was an article. There are a million Sydneyarticles. I don't remember it being anything other thansomething just in passing that I noted.

Q. You can't remember the source?A. I can't remember the source. I do remember what thesource - that it was written information and it said thatthere was an issue of ship's lifebelts. It would bea reasonable assumption, Commander, that those were issuedfrom the ship, therefore, the ship's name would be on them.

CMDR RUSH: Q. Isn't the evidence, Mr Samuels, ofsailors that they were issued with lifebelts on service atsea and that they carried the lifebelts with them from shipto ship? You don't know?A. Sorry?

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Mr Samuels, when you -­A. Yes.

Q. Are you familiar at all with agriculturistsundertaking autopsiesA. No, I'm not.

Q. It would appear, would it not, that Mr Snook'semployment, at least prior to him signing on on 1 June1940, had nothing to do with any form of medical science?A. It would appear so, yes.

Q. You maintain, do you not, that there was a sealedenvelope on the file --A. Yes.

Q. -- of Laurence Snook?A. Yes.

Q. And you had some communication, did you, with theholder of Army records in relation to what was there?A. Mostly George Karlov had that conversation, Commander.

Q. And has he informed you of that?A. Mr Karlov?

Q. Yes.A. Yes.

Q. You were informed that there was correspondence of1997 which had to remain in a sealed envelope under the3D-year rule?A. No, I've not heard that before.

Q. What have you heard?A. Just that there was a sealed envelope. I've neverknown what was in it.

Q. As far as it being sealed, did you understand why itwas sealed?A. I understood that, and I told LCDR Kerr that when heinterviewed me.

Q. What did you understand was the reason?A. No, what I said was I never understood the reason whyit was sealed. It contained something. I didn't know whatwas in there.

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Q. Did Mr Karlov not inform you of the results of hisinquiries?A. Only that the envelope has apparently gone missing.

Q. Could we bring up CORR.016.0048. Do you see there anemail from Pauline Maly to you, John Samuels, of 11 July2005.A. I don't remember this one.

Q. You were requesting further information in relation tothe file of Laurence Snook, weren't you?A. That's right, yes.

Q. She emailed you in these terms:

There is further information contained inthe envelope concerning Laurence CecilSnook, Service Number NX24732. Thisinformation has been placed in a sealedenvelope as the date range of 1997 fallswithin the closed period for information,it is less than 30 years old.

So you were directly informed of a sealed envelope in thedate range of 1997, which was closed because it was30 years old.A. Because it was 30 years old?

Q. It was less than 30 years old.A. Less than 30 years old, yes.

Q. You knew that?A. Well, the information here says I did, yes.

Q. Well, what did you make of that?A. I would have liked to have known what was in theenvelope, that it was necessary to seal it.

Q. Could we look at page 111 of your book. Could we godown just below the photograph to the paragraph where yousay:

It's no use looking in Captain Snook's Armyfile. Part of it was sealed up and removedin 1997, the year the Parliamentary Inquirybegan. A secrecy order was placed on the

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CMDR RUSH: Yes.

CMDR RUSH: Yes.

CMDR RUSH: Because it is correspondence that must be keptin relation to the files, as I understand it, sir.

THE PRESIDENT: Because it is 1997 correspondence, it hasto stay secret for 30 years?

Just while we have that page on the

Why is this still subject to any rule?

Q.

sealed envelope ensuring it could not beexamined by the Inquiry. Whatever it is inLaurence Snook's World War II career thatwas deemed to put our national security atrisk in 1997 won't be available forinspection till thirty years from thatdate!

Q. Sir, the Inquiry has obtained the correspondence thatis in the two letters. It still is affected by the 30-yearrule, but I can tell you what it is and I will tender itand ask that it be marked "Confidential". It is a letterof 4 September 1997 from Laurence Snook asking for a copyof his Army records, and it is a reply of 18 September 1997from Army career management, enclosing his records.I tender it.

EXHIBIT #CONFIDENTIAL 1 SEALED CORRESPONDENCE PERTAINING TOCAPT SNOOK'S SERVICE RECORDS, BARCODED EML.003.0106 AND0107

CMDR RUSH:

THE PRESIDENT:

THE PRESIDENT: Even a request for the date on which heenlisted and was discharged and his length of service?

THE PRESIDENT: That is, may I say, all it contains. Itwill be a confidential exhibit, 1. That is EML.003.0107and 0106.

What basis at all did you have for saying that our nationalsecurity was at risk as a consequence of what was in thecorrespondence?A. Why else can you imagine a former agriculturist havinghis file sealed up?

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screen, you there refer in the next paragraph to:

Snook's superior officer at HollywoodHospital in Perth was Colonel John Adey.Adey's file, for reasons unknown, cannot befound in the archives.

What was the significance of Adey's file?A. I should firstly point out, Commander, that Adey'sfile was not available to me when I asked for it but itlater reappeared again. I don't have an opinion about it.Col John Adey, so I'm told, couldn't stand Laurence Snook.I was hoping to see if there was anything in there thatmight shine some light on Snook.

Q. From looking at that file, were you able to determinewhat Dr Adey's movements were in --A. I never got Dr Adey's documents.

Q. You're not suggesting, are you, that Dr Adey wasinvolved in the autopsy?A. I don't know.

Q. He also was in the Middle East, wasn't he?A. I don't know. I haven't seen Adey's file, as I said.

Q. Could we have brought up document NAA.092.0025? Couldwe go to page 0028 of Dr Adey's file. Perhaps we could goto the third entry, May 1940. That is "2 Echelon,disembarked at Kantara, 18 May, Palestine." Do you seethat?A. Do I see that? Yes.

Q. Then if you go down to 17 September 1942, "Embarkedper 'Laconia', transhipped to 'Duntroon' at Bombay.25.3.42, India". Then, "Disembarked", "23 May". Then,"Mentioned in despatches, 30 June 1942". He also, clearly,was out of the country certainly in December 1941 and wellinto 1942. Correct?A. This "21.5.43 RGH" - is that

Q. Australian General Hospital.A. Oh, it's "AGH" , okay. Yes, I can see that.

Q. I suggest that for Adey or Snook to have been involvedin an autopsy, having regard to the dates, is nonsense?A. I don't believe so, Commander.

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THE PRESIDENT: Q. What we have at present so far asthe so-called CAPT Snook autopsy, as I understand it, isthis: you tell me that there is a disk or a tape of aninterview, something Mrs Richardson may have told toProfessor Horsfield?A. Mrs Richardson, sir, told me. I toldProfessor Horsfield.

Q. But I thought you said that it is recorded inProfessor Horsfield's interview?A. Professor Horsfield was here at Camden in Sydney.I was in Queensland. He seized the opportunity to film hersaying what she had to say.

Q. And have you seen that disk or tape?A. No, but I've seen the transcript of it.

Q. What did she say?A. She said that her brother, Laurence Snook, told herthat he had performed an autopsy on an HHAS Sydney sailor;he was - this is not word verbatim, sir - in a very sorrystate; his assistant left the room - I remember her sayingthat, that that's what he said - and that he was wearinga Sydney lifebelt.

Q. Right. That's what you put in your book at page 110.We do not know where this body was found?A. No, we don't.

Q. When it was initially found, who buried it, whoexhumed it, who required there to be an autopsy, or,indeed, whether an autopsy was carried out at all, apartfrom the fact that you say Mrs Richardson told you that onehad been. We know that CAPT Snook wasn't in Australia whenSydney was sunk and didn't come back here until May thefollowing year.A. That's right.

Q. So we're speaking of some period after May 1942.A. Yes, sir.

Q. Is there any other information that you have aboutthat?A. That is the end of what I know about CAPT Snook, sir,other than the fact that I add to that I fully believeMrs Grace Richardson's story.

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Q. Where is that note?A. In a file box at home somewhere.

Q. The what?A. The same.

Q. This publisher?A. Yes.

Q. Are we talking about 2005, 2006?A. I wouldn't remember, sir.

Sir, I tender the records of service of

Q. Halstead Press?A. Mmm-hmm, the same.

Q. How did you come to meet Mrs Richardson?A. Mrs Richardson is the mother of the publisher ofHalstead Press.

Q. So the lady who told you the story that ends up inthis book happens to be the mother of the publisher?A. Yes, that's right.

Q. When was that conversation?A. Too long ago to remember.

Q. It doesn't have the slightest relevance, no. But thefact that she is the sister of CAPT Snook may have somerelevance.A. It is a quirk of fate, but that's all it is.

CMDR RUSH:

Q. And we will find a transcript of this interview - didyou yourself make a note of what Mrs Richardson told you?A. The note would be associated with what's written inthe book, sir.

Q. No, I said did you make a note of what she told youwhen you had a conversation with her?A. Yes.

Q. And the mother happens to be the sister of the man whowas supposed to have conducted the autopsy?A. She's also the widow of the late Ombudsman of NewSouth Wales, sir, too. But I don't think that matters.

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CAPT Snook.

EXHIBIT #124 RECORDS OF SERVICE OF COL ADEY

EXHIBIT #123 RECORDS OF SERVICE OF CAPT SNOOK

Q. Who hardly went out where?A. Well, the Kormoran.

We have been through that.

And the records of service of Col Adey.

THE PRESIDENT:

Q. So you assumed, to start with, that Kormoran knew ofthe existence of the Aquitania, knew of her course?A. Sorry, sir, it could have been contained in the pouchthat came from Wenneker.

THE PRESIDENT: Q. That's just ungrounded speculation?A. It's my speculation, sir, yes. They hardly went outthere to run into the Sydney.

THE PRESIDENT: Q. Who is the publisher ofHalstead Press?A. Matthew Richardson.

Q. Mr Samuels, am I to understand from your last remarkthat because you think it is unlikely that the Kormoranwent out to encounter the Sydney, therefore she must havegone out to encounter the Aquitania?A. The Aquitania would have been a very attractivetarget, and I don't recall ever researching or looking atany other more attractive targets than Aquitania that wouldhave been out there.

CMDR RUSH: Q. Just to clarify that, you say on2 September 1941, when the Ku7mer7and sailed from Japan, itknew of the movements of Aquitania as they might occur inor around 19 November?A. It could have.

CMDR RUSH:

CMDR RUSH: Q. Mr Samuels, do you still hold to the viewthat Kormoran was directed to intercept Aquitania?A. I think it's a reasonable assumption. It has been theassumption of me and a lot of other writers that they wereout there to do something. Aquitania seems like a likelytarget.

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Q. On what grounds do you believe that?

Q. Do you know the speed that Kormoran was capable of?A. It was 14 knots, I think, something like that.

CMDR RUSH: Q. I just want to ask you about one thing atpage 39 of your book, Mr Samuels, about 10 lines from thebottom. You refer to:

Q. And you also allege, do you not, that Aquitania wasdeliberately delayed in Singapore?A. Mmm, so I believe.

That's just nonsense, it really is.

offhand.

Q. Do you know the speed that Aquitania was

THE PRESIDENT:

The persistent claim of many of Kormoran'screw that the raider's intended target wasAquitania is certainly more credible thanthe outrageous alternative that Kormoranlay in waH for Sydney . ..

Q. And Aquitania, around 24 knots. Would that make ita good target?A. It would if you had a Japanese torpedo, anda submarine to go with it.

Q. But without the Japanese torpedo, it's not a goodtarget?A. The Aquitania, no.

What references are you referring to when you say "thepersistent claim of Kormoran's crew that Aquitania was theintended target"?A. As far as I remember, some of Kormoran's crew - and itwas more than one, Commander - said that they were waitingfor the Aquitania, but Sydney rocked up first.

THE PRESIDENT: Q. I must say, I've read all of thosestatements, and I don't recall that at all. I may bewrong. My memory may be at fault. Can you point to anyparticular statement by any survivor that said that?A. Not offhand, sir, but I remember reading it.

CMDR RUSH:capable of?A. No, not

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Q. It is not reasonable to make an assumption unless you

Q. And no doubt, if you find anything, you'll inform us?A. I wi 11 .

A. Once again, something in the dim, dark ages. I readthat it was deliberately delayed in Singapore.

Q. That's unreasonable?A. I think it's totally unreasonable.

to inIs there one shred of evidence that's referredbook to support the proposition?Probably not.

Q. Yes.A. And I don't think the Kormoran would have put itselfin a position necessarily to be run over by a warship.

THE PRESIDENT: Q. Why is that?A. The Indian Ocean is a very big place, sir.

Q. You can't point to anything?A. No.

Q. Did you make it up?A. No.

Q.yourA.

Q. Are you suggesting that the Kormoran knew Sydney wasthere?A. Well, from what I have seen of what Detmers said,I think that he was fearful of another warship - I can'tremember the name of it. He made some remark to his crewthat there was another warship out there, but it certainlywasn't the Sydney. It is reasonable for me to assume, andI think it is for most people to assume, that Sydney wassent to intercept the raider.

Q. And Commander-in-Chief, Singapore Station directedSydney to engage with Kormoran?A. I think it's not only me as a writer, Commander, butI don't think the Australian public quite goes with theflow the Navy goes with, with things just happening the waythey did. I think that it's unreasonable to say thatSydney was heading back after escort duty in the SundaStrait and accidentally, in the middle of the Indian Ocean,ran into a raider.

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have some basis of fact for the assumption. You have none.A. No, it is only my assumption, I agree.

Q. Do you understand the difference between an assumptionand speculation?A. Yes, I do.

CMDR RUSH: Q. You referred to the career of CAPT Snookas supporting the proposition leading to credibility. Whatabout Admiral Sir John Collins?A. For all intents and purposes, he was a fine officer.

Q. Well, why did you insinuate in your book, as you referto, that he kept a long, dark secret concerning Sydney?A. Commander, have you read his book on Sydney?

Q. I'm asking you the questions.A. Well, I don't have an answer for it.

Q. Let's have a look at page 32 of your book.A. What page, Commander?

Q. Page 32. As a journalist, I take it, Mr Samuels, thatyou have a rudimentary knowledge of the laws of defamation?A. Mmm.

Q. You say at the bottom of the page:

Captain JA Collins was also present atChina Station Singapore in November 1941,when the ship he'd formerly commanded wassent raider hunting. It is difficult tobelieve that such a man could have been oneof the few privy to and charged to keepsilent the dark secret of HHAS Sydney'sfate, but with the facts as they stand, itis still harder to believe he could nothave known the truth.

So you insinuate that it is impossible to believe or hardto believe that he didn't know that Sydney had beendirected to engage with Kormoran?A. No, I don't think it is impossible to believe.I believe it is hard to believe that he didn't know, yes.

Q. What evidence, anything, do you have to support theproposition contained in that paragraph?

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THE PRESIDENT: Q. This is the story in your book?A. Yes. Yes, sir.

Q. Arthur Lane didn't work at China Station.A. At Tanglin Barracks, sir.

Q. It is full of factual impossibilities. Do yourecognise that?A. It's the story he told me.

Q. He belonged to the Manchester Regiment as a bugler atTanglin Barracks; is that right?A. That's right.

story that that's

I think it's at page 50 of your book.Q.

What's the nature of what he says?Just that he supports his originalhe heard.

Arthur Lane revealed that he couldclearly recall radio contact duringSydney's final minutes. At our request herecorded the fol lowing statement.

Q. Well, perhaps if you have it, I could be shown it?A. I will do. No, I don't have it. That's what I mean.I haven't printed it out.

Q. Can you do thatA. I didn't bring it with me. Yes.

Correct?A. Yes.

Q. I thought you said that you had a recent communicationfrom him. What's that?A. I have an email, but I actually haven't printed itout.

Q.A.what

CMDR RUSH:You say:

A. I think signals received by Hetty Hall at ChinaStation; I think Arthur Lane at China Station; I think itwas well known on the day exactly what was going on, andI find it hard to believe that the great CAPT Collins, whomI have a great deal of respect for - I find it verydifficult to believe he hadn't heard what was going on.

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Q. What would Eric Cooper know about the ability of

Q. Run by the Manchester Regiment; is that correct?A. If that's what's in there, that's what he told me.

Is that right?A. Yes, that's right.

Q. If you have a look at his statement to you, thesecond-last paragraph on page 50, where he says this:

he used to walk overAnd he says, as told to you, thatradio room at Tanglin Barracks?That's what he told me, yes.

Q. And what did you find?A. A mixed bag.

Later that same day among other messages onthe [vocal radio} was one which sounded7ike an Austra7ian voice. (1 had not metvery many Aussies at this time, so it couldhave been an American.). The voice soundedexcited as it repeated "She is going down""She is going down". At the same time thatthis was happening, he [the radio operator}informed me that a British warship had sunka German raider which at the time meantvery little to me.

Q. He was about 18 years of age; is that right?A. I don't know. I wouldn't be able to tell you.

Q. His job was to play the bugle at various times duringthe day at his barracks; is that right?A. Yes. Yes, that's right.

Q.to aA.

Q. No doubt, as a consequence of that you either knew orwould have examined the ability of Sydney to send sucha transmission?A. I did.

Q. Where did you go to look?A. Oh, the usual - Eric Cooper. There's piles of it,Commander. But there's no use asking me specificquestions. I don't have that good a memory.

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Q. So you accepted that?A. Yes.

Q. Even though you know it's impossible?A. I didn't say I know it's impossible. I said that the

Q. So you accepted the impossibility?A. I accept their word if they say it.

Q. No, it wasn't what?A. Capable of sending a voice radio message.

radio signals?Eric Cooper came to mind as somebody

about transmission of signals.

Q. So you knew that what this gentleman Mr Lane wastelling you was wrong?A. Not at the time.

Q. Going back to your prologue and the fact that youstate to your readers that you apply historical rigour inrelation to the statements that you make, what did you doto ascertain whether Sydney could send voice messages, asthis refers to?A. I would have, from memory - and I remember doing it -spoken to a number of people about different types of radiosets that were available at the time to Sydney, differentmasts that it may have had, was it capable of sending voicemessages. The general consensus was, no, it wasn't.

Q. That was the consensus of whom? Two whom did youspeak?A. Any number of people.

THE PRESIDENT: Q. Did you accept that consensus view?A. I'm afraid, in view of the persistence that Sydneycould not send voice radio messages, I would have to saythat, yes, in all probability it couldn't.

Q. When you wrote the book, you did?A. No, but the point of the matter is, the generalconsensus of people doesn't necessarily change my mind.Their idea of Sydney sending voice radio is that it wasimpossible. He says, and many other people have said, theyheard it. You can't shoot the messenger. All of thesepeople can't --

Sydney to transmitA. I don't know.who knew something

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general consensus of others is that it's impossible.

Q. But accepting that, as you said you did, you stillaccepted the words of people telling you something whichwas, in accordance with the view you had accepted, notpossible?A. That's right.

Q. Why?A. Because they can't all be lying about one thing.

Q. And if something is impossible, wouldn't you thinkthat the other story might be untenable, untrue?A. No.

Q. You wouldn't?A. No.

CMDR RUSH: Q. To ensure your journalistic integrity,did you have a look at his statement, as provided to you,for other anomalies?A. There was something about his pay book, if I rememberrightly, in Singapore.

Q. Before we get to that, may I take you to the nextparagraph on page 50:

It wasn't until after the war thatI learned that the ship was HHAS Sydney.It was now of some interest to me becauseit was just a few weeks previous to thesinking when during an off duty periodI went to the small cafe in BotanicalGardens Singapore, where service men oftenwent for a quiet drink (non-alcoholic) andto listen to music being played on therecord player. A group of sai70rs from theSydney had formed a singing group and theywere singing with the music.

You surely knew that Sydney wasn't in Singapore a couple ofweeks before 19 November?A. Yes, but Arthur is not a young man, either. He couldhave made a mistake in that particular zone. There's noneed to discount the whole story.

Q. When was Sydney in Singapore?

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A. I have no idea.

Q. No idea?A. I have no idea.

Q. He goes on, doesn't he, to talk about that?

The leader was a young man about my agenamed Kni 11 ...

There was no person on the Sydney called Knill, was there?A. As far as I remember, no.

Q.... and I got him to sign my pay book justin case he became famous. Ny pay book isnow with the Singapore history museum

Then he goes on to talk about the armament of Sydney and hetalks about the Kormoran crew surrendering, abandoningship, and that's all material that he has come intopossession of after the war; is that right?A. That last part, Commander, say that to me again? Whatdoes he come into possession of after the war?

Q. I'll withdraw the question. If you go to page 51, inthe middle of the page, you say this:

When I questioned Arthur Lane to test hisexact recollections he had further insightsconcerning matters he had not been askedabout before.

And you quote him:

Sydney wasn't under radio silence inSingapore waters. In fact there was ani nci dent. The same s i nging lads I'd met atthe cafe on an earlier visit to Singapore(it had to be them) put out a song overHNAS Sydney's radio, and they werereprimanded for it by the shore station andthat would have been not much short of48 hours before she was sunk.

You must have felt that that was sheer and utter nonsense?A. As I said before, you can't shoot the messenger.

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Q. But you are the historian; you're the journalistapplying historical rigour. You must have felt that thatwas absolute nonsense?A. These are Arthur Lane's words. They're not mine.

Q. But you are attempting, as you said in your prologue,to write a reputable book; correct?A. Mmm.

Q. You must have appreciated that what you were referringto there was absolute nonsense?A. Yes, but this is Arthur Lane's story in his own words,the same as Mrs Richardson's story is her own words.

Q. I see, so anyone that puts a story in their own wordshas some form of credibility as far as John Samuels isconcerned; is that it?A. Yes. I see the better part of people and I see thebetter part of what they have to say.

Q. Would you say that that's impossible?A. What's impossible?

Q. What is written there, about singing over the ship'sradio.A. Well, if they didn't have voice radio, Commander, thenthey couldn't have done it, could they?

Q. Even allowing for that, are you seriously saying thaton a ship that you allege is directed by C-in-C China toengage with a raider, and with a Captain who is aware ofa raider in the area, 48 hours before an engagement, somemembers of the crew have somehow got into the wirelessoffice to sing a song over the radio? Is that what you'resaying?A. That's Arthur's story.

Q. That's Arthur's story?A. That's Arthur's story.

Q. And John Samuels, just because it's his story, puts itout there?A. I didn't say I support it.

Q. Well, why did you put it in your book?A. Because it's Arthur Lane's story.

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Q. And, again, you would know that to be nonsense,wouldn't you?

Q. Well, that's what you have put in your book.A. Well, if that's what it says, that's what he said.

EXHIBIT #125 LETTER FROM ARTHUR LANE TO THE DAILY MAILDATED 5/6/1998, BARCODED PINQ.SUBS.016.0116

Q. It was tendered before the Parliamentary Inquiry; itwas a letter of Arthur Lane of 5 June 1998.A. And what did it say?

I tender that letter, sir.

Q. It is document PINQ.SUBS.016.0116. As you look at it,does that ring a bell?A. I don't ever recall having seen this before.

Q. Were you aware of that?A. I don't know. If you tell me what it says, I might beaware of it; I might not be.

Q. In your prologue to your book, instead of saying thatit was the result of intense research and historicalrigour, why didn't you say that you were just reciting whatstories people were giving to you?A. Well, it was remiss of me not to do that, wasn't it?

CMDR RUSH: Q. You were aware, at the time you wroteyour book, of a letter that Arthur Lane had written to theDaily Mail in London in 1998, weren't you?A. Refresh my memory.

CMDR RUSH: Q. Just coincidentally, according to thestatement that Arthur Lane gave to you, he was present atTanglin Barracks when the so-called Japanese Winds messagewas received and decoded by personnel from the ManchesterRegiment?A. Is that what he says?

THE PRESIDENT: Q. And even when you knew those storiescouldn't possibly be true?A. That's not entirely correct either, sir. I wasn'tthere. I don't know. The bottom line to everything isthat none of us was there and none of us know.

CMDR RUSH:

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THE PRESIDENT: 2007.

Q. Then why did you accept it in 2005?

THE WITNESS: Because I probably didn't know more about itin 2005.

Q. Yes. Do you accept it now?A. No, I don't accept it now.

I don'tany

Q. Are you maintaining that they saw bodies in the sea ornot?A. It doesn't matter if they saw bodies in the sea.

A. I may not have at the time.

Q. It goes to the credibility of a person you arereferring to in your book, if, on 19 November, he says,"I was coincidentally at the Manchester radio office whenthe Winds message was decoded." Do you accept that?A. Do I accept it now?

Q. But you do now?A. The Winds message is always very chaotic.know what to make of it. I don't think it's ofconsequence whatsoever.

THE PRESIDENT: Q. It does, if they did.A. The movements of Cape Otway - according to themerchant shipping movement cards, it left Darwin on17 November at 10.25 via lighthouse; Broome, 23 November;then to lighthouse at Cossack, the 27th; Geraldton,3 December, arrived at 05:30, departed at 10:00 hours;Fremantle, arrived 4 December.

CMDR RUSH: Q. You are a theorist who supports theproposition that Cape Otway came across bodies 23 daysafter Sydney had vanished?A. No. Actually, there's another one that I cancategorically state: let's not discuss it any further.I'll cave in entirely on that. I don't think it mattersone iota whether they saw bodies in the sea or not.

CMDR RUSH: Q. I suggest that it arrived in Fremantle on6 December?A. Well, I'm wrong, then.

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Q. It didn't leave Fremantle after that, did it, untilthe next year?A. Yes.

THE PRESIDENT: Q. So where did the bodies come fromthat you say are buried on the coast?A. I believe they just came ashore, sir, with thecurrents and the tides.

Q. When was that?A. There's no way to know. I wouldn't put a date on it.I think I have tried at various stages to put a date on it,but it would be an unknown date.

Q. Whilst you've read the log, do you maintain that Otwaysighted bodies in the water off the Western Australiancoast?A. I don't think they could have.

with what it did everyFebruary.

Which is entirely consistentover December, January, intoMmm-hmm.

Q. What do you mean, "the Hol y Grai l"?A. Well, it is the grail. The grail simply meanssomething which is extremely important, and I consider thisto be the most important aspect of the Sydney.

Q. So what's your basis for saying that there are bodiesburied on the beach of Western Australia?A. The story has been circulating, as LCDR Kerr knowsfrom LCDR Vic Jeffrey RANR in Western Australia. The storyis one that goes back to a time we can't find; it has beengoing on that long. There have been people before who havelooked for it. The story has gained its own momentum, forwant of a better term. It is my belief that they came

CMDR RUSH: Q. Mr Samuels, in January 2005, youmade a DVD recording where you were interviewed byMr David Kennedy, and in the course of that recording yourefused to discuss with him what you referred to as theHoly Grail concerning events about Sydney. What's theHoly Grail?A. I consider the Holy Grail to be finding the remains ofthe men who came off the Sydney, however many it is, andthere's no way to know that, either, any more than there isto know at the moment exactly where they are.

Q.yearA.

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Q. What accompanied the pictures?A. Nothing. That was typical of Bruce.

Q. How did he send the pictures to you?A. Just in an envelope.

Q. Could we have a look, please, at PTE.005.0066?A. Bruce Jolly. Sorry, I couldn't remember his name.

ashore. It is my personal belief. I don't have any proofat this moment either way, but I shall continue the searchthat I began.

So what is the relevance of it?Q.

Q. So you have some originals without that, do you?A. No, I only got a copy in the first place, sir. That'sa copy of a copy of a copy.

THE PRESIDENT: Q. Did they arrive with "Bruce Jolly picAug 07" on them or did you put that on there?A. No, I actually put that on there.

Q. Who's Bruce Jolly?A. The late Mr Jolly owned a tyre service in Geraldton.He had been looking for what we're discussing for a very,very long time. He sent these pictures back in 2007, noexplanation. He became very sick after that and diedactually two weeks before LCDR Kerr came and saw me.

Q. You say that he sent these pictures with noexplanation?A. No explanation. He was very "reds under the bed".

CMDR RUSH:

Q. Apart from it being a story, what other material isthere, if anything, to support this proposition?A. There was a piece of timber which you will be able toobtain from Max Kramer. There was a tooth at one stage,human, which was sent back to Mr Jeffrey - I'm just tryingto think of his correct name. It will come to memomentarily, sir. He had been looking for a very longtime - he and his son and a few other people. They hadcome across - apparently, I say - a cranium. They had comeacross a skull. I had pictures of these at one stage,which I have provided Navy with. What they mean, there isno point in asking me. I never got an explanation as towhat they mean.

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Q. So what did you do with it?A. I sent it back to him.

Q. So did it come in the same envelope?A. No.

Q. What about PTE.005.0062?A. That's the tooth.

Q. Where did that come from?A. This was sent back to Mr Jolly as well.

Mr Joll y di ed?Two weeks

It says that the forensic photo was2007.time or perhaps just a little bit

Q. So you must have communicated with him asa consequence of him sending you a tooth?A. Yes, I did, and as I told LEUT Kerr, "Reds under thebed". The man wouldn't talk to me over the phone.

Q. He sent you the tooth?A. Yes. That is my photograph.

Q. And it was just the photograph?A. No. He sent me the tooth.

Q. So this came in a different envelope?A. Yes, in a different envelope.

A. I don't know. This is what I said, Commander.I don't know what it means or where it is. I would love toknow where it is. And there's another one, as you wellknow, of a cranium.

Q. When did that come?A. There may be a date on it, is there?

Q. I think you referred to LCDR Jeffreys having seen thetooth?A. I never said that.

THE PRESIDENT: Q.taken on 16 NovemberA. Around the same1ater.

CMDR RUSH: Q. So when is it that you sayA. CMDR Kerr came to see me in September.before that, perhaps three weeks.

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Q. You don't know?

Q. Did you make them up?A. No.

Q. So you sent it back to him?A. Mmm-hmm.

Q. Sorry, NTBR.A. NTBR. I don't know.

There was no explanation, as usual, from

Q. But did he send you a covering letteris a tooth, which I found in a skull

Q. NTPR - NTBR.A. NT - what is it?

Q. Well, where did you get them from?A. I talked to him over the phone briefly. That's all hegave me. Other than that, he wouldn't - he basicallybelieves that everyone is in the Government employ, or hedid, shall we say, while he was alive.

Q. Well, where did those notes in the bottom come from?A. They are mine.

Q. What were you saying about LCDR Jeffreys?A. In relationship to what?

Q. So where's the tooth now?A. It went back to Mr Jolly. Mr Jolly's dead.

Q. Why, if he sent it to you?A. It's quite illegal, even under the circumstances, asLCDR Kerr indicated to me, that I would be forgiven forkeeping forensic evidence. We've taken nothing away fromthis area and I don't intend to.

Q. The tooth.A. I never said anything about LCDR Jeffreys inrelationship to the tooth.

CMDR RUSH: Q. What's the location referred to?A. I don't know. They were coordinates that he gave me.

THE PRESIDENT:sayi ng, "Thi sburied" --A. No, sir.Bruce.

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A. I don't know. I wrote down what he told me.

THE PRESIDENT: Q. I'll bet it stands for "Not to berevealed" .A. "Not to be revealed".

CMDR RUSH: Q. So you don't make anything of it?A. I don't make anything of it. It's a tooth.

THE PRESIDENT: Q. You see, the problem with the bodieson the beach is that this theory all stems from bodiesbeing found by Cape Otway. We now know that's nonsense.A. Yes, sir, but, as I said, I don't think Cape Otwaymatters in the story, whether they came ashore or not.

Q. Well, you have to have somebody finding the bodiesbefore you can bury them. That's the problem.A. Yes, but --

Q. It was said that they were found by Cape Otway andsent away, and then someone went up north, found all thebodies and buried them. If Cape Otway didn't find them,who did?A. It's a fact that we don't know, sir.

Q. We don't even know that there were any bodies, apartfrom speculation, which, as presently advised, doesn't havethe slightest basis in fact, particularly after last week'sevidence that if bodies sank near the site of the sinkings,they would not re-arise.A. Yes, I saw that, but I think the evidence was given bya Defence scientist.

Q. And what's wrong with that?A. I didn't find anything wrong with it. I just thoughtthat he hadn't allowed for the fact that there are enormouscross-currents, including the two north and south currents,present in the Leeuwin Current. It's not likely that manyof these bodies floating on the surface for the amount oftime that Mr - I cannot find his name here. The gentlemanthat gave evidence - expert evidence, anyway - hadn't takeninto account the fact that maybe they didn't get to thebottom before they joined the other current.

Q. That's your theory, is it? Is this a new one? Isthere any basis for that at all?A. Yes, there is.

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Q. Yes. (Handed to the Commissioner). What is thissupposed to be?A. It's to demonstrate the eddies

Q. No, where did you get it from?A. It's from a website, a Government website orsomethi ng. It mi ght be the CSIRO.

Q. What do you say you derive from that?A. That there are so many eddies there and they're allgradually pushing towards the West Australian coastline.

THE PRESIDENT: Q. That's the spaghetti formation, isit?A. Yes. I don't think it had anything to do with tide

Could we look at PTE.005.0042.

Q. Is there? Have you studied at depth the currents?A. I have had a very, very intensive look at the currentsand the eddi es in parti cul ar. In fact, if I may, si r,there's a chart here that you might find interesting.

Q. Does it have any bearing on the exhibit that has justbeen tendered? Is it related in any way?A. Actually, I have a theory that it was winds more thananything else, wind currents.

Q. Is that your diagram, Mr Samuels?A. No, not mine. It was sent to me by someone. I wouldbe able to find out who sent it to me. It was a long timeback, when the Sydney was first discovered.

CMDR RUSH:

THE PRESIDENT: Well, they're not. In any event, I'llpass it down to counsel. I had better have it marked as anexhibit, I think, now that it has been produced. It'sa print-out from a website showing the level and surfacecurrent, 25 February 1996; altimetric sea level and surfacecurrent, 25 February 1996; sea surface temperature seasonalanomaly, 25 February 1996. What one makes of it I don'tknow, but it will become exhibit 126.

EXHIBIT #126 OF PRINT-OUT FROM WEBSITE SHOWING LEVEL ANDSURFACE CURRENT, 25 FEBRUARY 1996; ALTIMETRIC SEA LEVEL ANDSURFACE CURRENT, 25 FEBRUARY 1996; SEA SURFACE TEMPERATURESEASONAL ANOMALY, 25 FEBRUARY 1996

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movements or anything like that.

CMDR RUSH: Sir, I have no other questions on that matter,but I do want to come back to the tooth.

Q. It came from where?A. It came from Mr Jolly.

Q. Could we look at EML.002.0023.A. Do you intend using anything from this document,Commander?

you know where it is?Oh, yes, same as the top of

LEur Kerr: SoJohn Samuels:that skul l.

LEur Kerr: So you know where they are?John Samuels: Yes. It's not a question ofknowing where they are, it's a question ofnot disturbing anything and God knows whatelse we might be disturbing forensicallyspeaking.

A. That's right.

LEur Kerr: Now you're left with a pictureof a tooth and you don't know where it isthough.John Samuels: I can get it again.

Q. I intend to read some of it to you and then ask youa question.A. I haven't signed this document.

Q. You have referred to your meeting with LCDR Kerr, andas I understand your evidence here today, you have saidthat you don't know where the tooth came from.A. If I said that, I was wrong. It came from Mr Jolly.

Q. I'm not interested in whether you have signed it.I can play it to you, if necessary, Mr Samuels. This isa transcript of an interview conducted by LCDR Kerr withyou. I'm going to the second question:

Q. But apart from that, you don't know where it camefrom?A. No, no idea.

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Q. Continuing:

I've had a real education over the last3-4 years about forensics and you don'ttouch anything.

LEur Kerr: When you say you know wherethey are, how have you pinpointed?John Samuels: GPS.

Q. You can't remember what you said a couple of minutesago?A. I'm trying to read what you have got on the screen.

back, Commander, so I canNo, what you say -­Would you mind scrollingit?

Q. You can't remember?A. I can't remember unless you scroll back. If you cando that, I can tell you what I meant.

Q. Do you say, Mr SamuelsA. I can't remember.

Q.A.read

Q. What did you say?A. Roll back, scroll back.

What you have just told the Commission, if we're to compareit with what you told LEUT Kerr, is a lie?A. No, it's not a lie at all. You're misconstruing whatI said.

LEur Kerr: And would you give us the GPSlocation?John Samuels: I can do.

THE PRESIDENT: Q. Let me just ask you this: do youknow where the tooth is?A. The tooth, I assumed when I answered LEUT Kerr, wouldhave been with Mr Jolly's son, who accompanied him on mostof his tours into the sand dunes, for want of a betterterm. I've subsequently spoken to his son. He instructedme to speak to his mother. I have not spoken to hismother.

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Q. Well, you said, as I interpret what's on the screennow:

LEUT Kerr: When you say you know wherethey are, how have you pinpointed?John Samuels: GPS.

A. GPS.

Q. Had you pinpointed the location of either the skull orthe tooth with GPS?A. I think it has been misconstrued. The GPS, Bruce'sson would have taken at the time.

Q. And who is Bruce's son?A. Actually, I think his name is Joe Jolly.

Q. Is he in Western Australia?A. He's in Western Australia, yes, sir.

Q. Is it your understanding that he knows where the skullis?A. It's my understanding that he probably knows where theskull is.

Q. I thought you said that's what you thought his fatherwould have told him?A. I would assume that's what his father would have toldhi m.

CMDR RUSH: Q. I was asking you questions about thenotes of location on the photograph. At the bottom ofpage 1342, at line 26, you were asked this:

Q. Well, where did those notes in thebottom come from?A. They are mine.

Q. Did you make them up?A. No.

Q. Well, where did you get them from?A. I talked to him over the phonebriefly. That's all he gave me. Otherthan that, he wouldn't - he basicallybelieves that everyone is in the Governmentemploy, or he did, shall we say, while he

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was a7ive.

Q. When you said that you haven't signed it --A. Sorry?

I'm not sure, I must say, what we would dowith it, we're not about to run out therewith picks and shovels ...

That GPS, in my mind, was where we are looking, not whereBruce Joll y was 1ooki ng. It is my mi stake. I have no ideawhere Mr Jolly was looking.

Issi r.please,Could we have a look at PTE.005.0053,a letter received by you, Mr Samuels?No. It was received by my publisher.

Q. Mr Karlov?A. My publisher.

Q. Who is your publisher?A. Halstead Press.

Q.thatA.

Q. Addressed to you?A. Addressed to Halstead Press. It was sent on fromHalstead Press.

Q. When I took you to it, you said, "I haven't signedit." What was the relevance of that?A. There's mistakes all through it.

CNOR RUSH: Q. What's the locationreferred to?A. I don't know. They were coordinatesthat he gave me.

In connection with your sworn testimony to the Commissionthat you didn't know the coordinates and what you toldLCDR Kerr, that you were aware of the GPS position, how doyou explain that?A. What it says here is misconstrued, all the way I havesaid it, or I didn't understand LCDR Kerr's question in thefirst place. When I answered LEUT Kerr's question, "Whenyou say you know where they are, how have you pinpointed?","GPS" , "And would you give us the GPS location?", "I cando", I agreed to do it, and LEUT Kerr asked:

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CMDR RUSH: Q. This is a letter that was sent on to you?A. From Halstead Press.

Q. Have you any document, any evidence at all, to supportthe proposition that you have just put forward?

Q. What did you make of this letter?A. Not much, to tell you the truth.

Q. And it was sent on to you?A. It was sent on to me, yes, sir.

Could we just go to the top of the pageThank you.

Q. Why not?A. I think it's too complex.

Q. So who's "Mr Samwells"?A. Apparently me.

CMDR RUSH: Q. What happened to the bodies that you saywashed up on the coast of Western Australia?A. I believe that a militia army unit was seconded torecover them from a lower level of the beaches; they wereconsequently buried in a mass grave. I don't believe thatthere is one mass grave, and I don't believe that there aretoo many mass graves, but these bodies wouldn't have comeup necessarily in a convenient little group. There arebound to be isolated graves here and there.

THE PRESIDENT: Q. You think it's a fake?A. Yes, I do. I don't think it's a fake necessarily,sir, but it's someone who may not be telling us all thetruth or may be telling us part of the truth but coveringup the rest. I don't know what to make of it, but I don'tbuy the story that this fellow was present at a cemetery inthe middle of nowhere. I forget exactly where it was. Itwas somewhere in Western Australian, up north inland. Itwould have been a long way to take the remains of someone,keeping in mind that they didn't want to be seen doing it.

THE PRESIDENT:for a minute.

Q. What was the militia unit?A. I have no idea. I only suspect that - I think it was22 Construction Company I told LEUT Kerr. I had a reason ­I can't remember the reason, but I had a reason to thinkthat maybe they were involved. Maybe they're not.

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Q. Yes.A. No, there's no other evidence at all .

THE PRESIDENT: Q. That means that there is no evidence,full stop.A. Basically, si r, that's what it means, yes . It's

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1 A. I did have, on a burnt-out computer, from some2 research a fellow did for me in Canberra. Hence I got3 22 Construction out of it.45 Q. So who is that person?6 A. I can't even tell you that. It was someone I employed7 in Canberra on the shortlist of researchers down there.8 From memory, it cost me $500.9

10 Q. So you have made no attempt to get back to the person11 who prepared that at the cost of $500?12 A. His end result of it was that he had looked at13 22 Construction Company and he found that there were great14 gaps in the files, if I remember correctly, but I may not15 be remembering it exactly.1617 Q. No, but my question was a different question. You're18 saying to the Commissioner that you have made no attempt to19 get in touch with the person who conducted that research20 for you at a cost of $500?21 A. No.2223 Q. Why not?24 A. After I got the answer I needed, that was it. There's25 no more to know.2627 Q. But wouldn't gaps in a file tend to make you, on the28 basis of what we see and somewhere below, very inquisitive29 about the role of the Construction Company?30 A. Yes, but I've been inquisitive before, Commander. It31 was like the sealed envelope in Snook's file. You've32 managed to get a hold of it because of who you are.33 I can't get a hold of it because of who I am.3435 Q. So apart from the results of research that you haven't36 followed up on a burnt-out computer, which showed gaps in37 the record, you think, of a militia Construction Company,38 is there any other evidence at all that you can point to to39 support what I suggest to you is a sensational proposition?40 A. That the bodies are buried ashore?41424344454647

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a good-faith thing, from my point of view. I can't seewhat else could have happened to them.

Q. That was explained last week, but you don't acceptthat. Would you mind just having a look at pages 138 and139 of your book.A. Yes, sir.

Q. It's thi s Cape Otway matter.A. Page 138 you say?

Q. Pages 138 and 139. The top picture on page 138 hasthis caption:

The lighthouse ship Cape Otway reportedbodies floating in the sea to the RAN andwas ordered to abandon her station and1eave the area.

You, as I understand you, now accept that that is false?A. False or neither here nor there is what I think.

Q. It's either true or it's false. Whether it's here orthere is another question. Is it false or is it true?A. I'd say it's false.

Q. Further down on that page, it says in the second-lastparagraph:

On December 12th 1941 the watch aboardCape Otway sighted bodies floating at thefoot of the cUffs.

Do you now say that that's false?A. Yes.

Q. Go over the page to page 139. You address themaster's logbook. You say that it doesn't require a teamof Scientific Branch specialists to tell you that it hasbeen doctored.A. Do you want me to respond to that, sir?

Q. Yes.A. I know there's a number of logbooks. However, thelogbook I sighted in Perth years ago suggested to me, whenit was ended off on the 18th or something, that it hadeither been doctored or possibly altered. So at the time

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I subscribed to the idea that it could have been altered,as was Montgomery's concept as well, and I went withMontgomery's concept.

Q. But you now know that that's false?A. Yes.

Q. You then go on to say:

The need to doctor the log stemmed fromwhat the ship's officers recorded, afterthe search was over, on December 12th 1941.

Do you now say that's false?A. Yes, I do.

Q. You then go on:

Cape Otway reported by radio to the Navythat she was on station

And that's false, is it not?A. Well, it's not false. It's the way it's written.

Q. It's wrong?A. It's wrong, but it's not false.

Q.... and that bodies were floating at thesteps of the Zuytdorp Cliffs.

And that's false?A. Yes. That's what I just said.

Q.The Navy ordered the master of the ship toleave the area immediately.

And do you accept that's false?A. That's right.

Q.Cape Otway's presence ...

We now know that Cape Otway wasn't present; do you agree?A. Agree.

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are well estab7ished facts ...

Q.

Q.

Q. Whether it's right or wrong, it has a caption:

indeed,Either that bodies in fact came ashore or,anyone buried any bodies; do you agree?I agree.

Q.thatA.

Bodies were sighted from Cape Otway on thearid Coast of Western Australia.

and the bodies in the sea sighted byher 0 ffi cers --

And you accept that that's false?A. Yes.

. .. that have been addressed time and againby many researchers.

Q. If I may say so, it is only all of that falsity whichleads to the start of this notion that there are bodieswhich came ashore and which were buried. Without all ofthat falsity, there is not a skerrick of evidence thatthere were any bodies that came ashore, unless you are ableto give me some.A. As I said earlier, sir, I have absolutely no proofthat the bodies came ashore, any more than I have proof, asI've agreed, that Cape Otway mayor may not have seenbodies. I agree, I believe now that they did not seebodies in the sea. But I don't think that still takesanything away from the fact that these bodies could wellhave come ashore.

Q. I'm talking about a skerrick of evidence, rather thanyour belief.A. I don't have any evidence as such, no.

you now accept that there were none

Then at the foot of the page, you have a picture.A. Which is the wrong picture, sir, I might add.

So that's false?A. That's false.

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Q. I would like, if you wouldn't mind, to

Q. Where does that woman reside?A. In South Australia now.

Q. The Wittwer letter.A. The Wittwer letter. You have it.

Q. I understand the Wittwer letter. Apart from theWittwer letter, is there any other evidence at all?A. Not as such, no, sir.

anyAnd you have no evidence of any sort at all thatregiment or corps was involved in any burying?Only from the Wittwer letter.

Q.ArmyA.

CMDR RUSH: Q. Why might LCDR Jeffrey be able to shed1i ght on it?A. Because I believe he has heard the same story, and hemay even well know the woman herself.

THE PRESIDENT: Q. What is her name?A. Her first name is Enid, but I cannot for the life ofme think of her second name. It has been a long time sinceI wrote it down. When LCDR Kerr came to see me, I saidthat I would re-contact her. I have not been able tore-contact her. In fact, the address I may have for hernow could be wrong, too. However, some light may be ableto be shone on this by LCDR Vic Jeffrey.

THE PRESIDENT: Q. How did she come to be in touch withyou?A. She contacted me, I can't say before or after theWittwer letter. It must have been before the Wittwerletter, I believe, from memory. She understood that I waslooking at a story concerning bodies buried ashore fromHHAS Sydney, told me what her father had said and offeredto come forward should there ever be a Royal Commission,which, of course, sir, is yourself. As a consequence ofthat, I haven't been able to contact her.

CMDR RUSH: Q. There is one other, is there not,Mr Samuels, that you refer to in your book - a woman youhave spoken to, who indicated that her father was involvedin the burial and would only speak to a Royal Commissioner?A. That's right.

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A. I'll make every effort, sir.

Q. Thank you. Mrs X's name is what?A. Grace Carr.

Q. I have a copy of it, I think.A. No, you don't, Commander. I only got it yesterday.

Q. You can provide me also with details of her address?A. Immediately.

Thank you. They are the matters, sir.

Q. -- who informed you that she had a neighbour at onestage who was a survivor of Sydney?A. Here is Mrs X's testimony, Commander.

THE PRESIDENT: Q. Would you mind going, please, topage 21 of your book, the second-last paragraph. It says:

CMDR RUSH: Q. Thank you. Perhaps I can obtain themfrom you once we adjourn.A. Absolutely.

THE PRESIDENT: Q. You might also, if you wouldn't mind,forward on the email that you say you received fromMr Lane?A. Absolutely, sir. I'll make a note of it.

CMDR RUSH:

Q. We can't find Enid in South Australia, I'm afraid.We'll need a bit more information than that.A. I believe, while we're on the subject of not findingthings, too, sir, that there was a problem here late lastyear of finding Mr Jack Kendle, who wished to give evidenceto you concerning tally bands. I have contacted Mr Kendle,and I have his details for you.

CMDR RUSH: Q. There is one other matter, Mr Samuels.You conducted an interview that was recorded on DVD witha person by the name of Mrs X --A. Yes.

Q. And there should be no problem in your providing theCommission of Inquiry with the full details of Enid inSouth Australia?A. When I get home, I can do it, yes.

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Q. Then over the page at page 22, you write:

A. Yes, I remember the "Do nothing" part. That's why I'msure it was Arthur Lane who provided me with that.

The Admiralty took some time to respond,and when they did, simply sent the signal"Do nothing".

Captain Burnett commanding HHAS Sydney hadfound his quarry alright, with assistanceand orders directly provided by theC-in-C China Station.

signal, and so farYou can't shed any

Q. Again, we have seen, I believe, all the signals, andthere is no such signal. Do you have any evidence ormaterial which would suggest that there was?A. None at all.

On the 19th [this is 19 November} the sameAdmiral Layton, as signals were received bySingapore from HHAS Sydney in distress,sent advice to the Admiralty in London.

Q. It would have to have been sent byas I'm aware, there is no such signal.more light than that?A. Not at the moment, sir.

Q. Then it says:

What are the signals that you are speaking of which you saywere received by Singapore from Sydney in distress?A. I believe I was referring to the Hetty Hall situation,si r.

Q. But then it goes on and says that advice was sent toAdmiralty from, apparently, C-in-C China. How do you knowthat?A. From memory, I believe that this information came fromArthur Lane. I don't remember if I have it noted, but I amsure I do have it noted. How he knows, I can't answer.

That's suggesting that C-in-C China directed Sydney to goand search for, find and presumably destroy Kormoran.There is no such signal in relation to that. There werea lot of signals which suggest quite the opposite. Do you

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We also know that, earlier on ...

Q. You also say:

Q. Would you go, please, to page 47. You say:

Q. If you look at the screen:

what I have here is correct.

have seen all the intelligence information andsignals, if not them all. I don't know thatWhat's the basis of your knowing it for

I have not seen anything to suggest that. Do you have anybasis for that statement?A. What line was that on, sir?

We also know that, earlier on, the RANcommand had acknowledged there wasa submarine acting in tandem withHSK Kormoran off the West Coast ...

have any information at all which would support thatstatement in your book?A. Not that I can recall.

We know for a fact that the RoyalAustra7ian Navy - RAN - advised there wasno raider activity off the west coast ofAustralia at that time ...

Q. No doubt. But what's the source of it?A. I don't recall.

Q. It could be someone's speculation?A. I think it was more than that, sir.

It is the third-last paragraph on page 47.A. I actually think - if I give this (indicating) to you,Commander, can you make a copy of it, because I havewritten notes allover the back of it in reference to whatI have to give you. It's directly relevant to this, sir.

Q. You'll need to provide any material that you havewhich relates to that, if you can.A. Absolutely.

I believe Imost of thefor a fact.a fact?A. I recall having read that

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CMDR RUSH: Sir, there are two matters, just one forMr Samuels.

EXHIBIT #127 COPY OF ARTICLE IN AMERICAN MAGAZINE SUBMITTEDBY MR SAMUELS

THE PRESIDENT: You, as a journalist, should know that.I had better mark that, I suppose. I'll have a copy madeof it and I shall mark it as exhibit 127.

. .. the RAN command had acknowledged therewas a submarine acting in tandem withHSK Kormoran off the West Coast.

the question I askedsome journalist whoKormoran wasWhat you wrote was:

This is some article --Q.

Q. Mr Samuels, have you fully complied with the summonsin relation to the production of documents?A. Yes, I have.

Q. But a newspaper article is not a basis for a statementof fact.A. Well, I based the statement on that.

THE PRESIDENT:A. Yes.

CMDR RUSH: Sir, we haven't gone quite as quickly asI thought we might go today. I would ask that a warning begiven in relation to discussion of evidence outside theCommission of Inquiry.

A. What I said, sir, was that in the same vein, the sameperiod of time, I believe there is a newspaper article,which I probably can find and I will find --

Q. -- in an American magazine from New York.A. Exactly. I think the reference to the thing you justmentioned, sir, about the HSK Kormoran being in the companyof a submarine, I believe, was in the same period of timeand it was ascribed to the RAN. I may actually be able tofind the original source.

Q. But that has nothing to do withyou. This article purports to be bypurports to assert the fact that theaccompanied by a pocket battleship.

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CMDR RENWICK: No questions from me, sir.

<THE WITNESS WITHDREW

THE PRESIDENT: Yes.

THE PRESIDENT: Are there any questions?

Yes. Thank you, Mr Samuels.

Yes, very well.

We can start at 9.30, sir.

THE PRESIDENT:

THE PRESIDENT: Shall we start a little earlier tomorrow,or is that inconvenient?

THE PRESIDENT:

AT 4.20PM THE COMMISSION WAS ADJOURNEDTO TUESDAY, 20 JANUARY 2008 AT 9.30AM

Q. Mr Samuels, I should warn you that you must notdiscuss the evidence that you have given today with peopleoutside. They may have to give evidence, and it isimportant for me to be able to judge this evidence fresh.A. Right.

CMDR RUSH:

CMDR RUSH: May Mr Samuels be excused, subject to theprovision of those items?

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#

#109[1]-1238:34#110[1]-1239:9#111 [1]-1239:13#112[1]-1239:17#113[1]-1239:25#114[1]-1250:41#115[1]-1261:13#116[1]-1263:46#117[1]-1264:34#118[1]-1265:30#119[1]-1266:10#120[1]-1271:10#121 [1]-1283:17#122[1]-1284:27#123[1]-1327:3#124[1]-1327:7#125[1]-1337:33#126[1]-1344:28#127[1]-1358:33

$

$500[3]-1350:8,1350:11,1350:20

'42[1]-1317:47'Duntroon' [1] - 1324:35'Laconia' [1] -1324:35'Sydney' [2] - 1279:24,

1279:34

o

0002[1]-1283:450006[1]-1279:80009[1]-1280:260010[1]-1280:470013[1]-1281:150015[1]-1282:240028[1]-1324:280040[1]-1316:160043[1]-1263:210088[1]-1264:80093[1]-1299:50106[1]-1323:410107[1]-1323:450141 [1]-1242:47020 [2] - 1257:36, 1260:2005:30 [1] -1338:4107 [1] - 1340:40

1

1 [9] -1246:7,1246:31,1254:38,1264:40,1264:42,1265:35,1321 :9, 1323:40,1323:43

1,000[4]-1261:41,

1250:22, 1251:817 [8] - 1241 :34, 1242:28,

1243:21, 1243:46,1301:10,1304:15,1324:34, 1338:39

17-28[1]-1239:14170[6]-1242:19,1249:1,

1250:46, 1259:2,1260:22, 1260:25

17:00[2]-1250:22,1251:917:15 [1] - 1267:618[7]-1234:27,1245:11,

1273:9,1279:47,1323:20, 1324:30,1332:2

18th [1] - 1351:4619 [19] - 1232:41, 1233:22,

1242:12,1245:11,1246:4, 1246:5,1247:10,1247:17,1247:35,1253:11,1271 :37, 1275:19,1281:18,1294:32,1319:14,1327:46,1334:42,1338:9,1356:1

1940[3]-1319:14,1321:10, 1324:29

1941 [30] - 1233:22,1238:22,1239:10,1239:15,1239:18,1242:12,1246:4,1246:5,1247:10,1247:17,1247:35,1264:10,1264:34,1264:43, 1265:36,1271 :37, 1272:35,1275:19,1276:20,1276:21, 1279:16,1279:19,1281:18,1302:9, 1304:30,1324:38, 1327:44,1330:30, 1351 :30,1352:12

1942[7]-1290:34,1290:36,1290:37,1319:13,1324:34,1324:39, 1325:40

1942" [1] -1324:371943[1]-1263:471943/1944[1]-1263:2419705[1]-1272:151980[1]-1276:4119805[1]-1274:21981 [4]-1253:11,

1272:28, 1274:5,1274:21

1983[1]-1279:131984[2]-1254:7,1273:331987[1]-1274:1619905 [1] - 1276:41991 [4]-1239:1, 1239:30,

1254:33, 1275:291994/1995[1]-1286:71995[2]-1278:13,

1278:171996[7]-1234:1,1344:23,

1344:24, 1344:25,

1344:29, 1344:30,1344:31

1997[8]-1321:31,1322:21, 1322:26,1322:46, 1323:5,1323:19,1323:20,1323:29

1997/1998[1]-1275:391998[2]-1337:16,

1337:201999[1]-1255:2619:00 [1] - 1246:3519:05 [2] - 1246:6, 1267:819:40 [1] - 1246:2919:50 [1] - 1246:2919th [1] -1356:1

2

2 [11] - 1244:22, 1244:39,1246:8, 1251 :33,1257:34,1264:10,1264:34,1278:25,1300:35, 1324:29,1327:44

2,500[1]-1270:452-3rd [1] - 1316:442.5[5]-1244:1,1244:3,

1244:40,1257:35,1263:14

20[21]-1242:30,1245:41,1246:16,1246:29,1248:10,1248:14,1248:28, 1248:29,1250:24, 1250:30,1258:3, 1267:1,1272:10,1285:26,1286:7,1288:39,1288:45, 1302:9,1304:30, 1311 :30,1359:28

2000 [1] - 1255:282001 [3]-1235:8, 1274:37,

1275:442004 [1] - 1256:52005 [13] - 1286:9,

1286:10,1286:12,1286:16,1286:17,1286:18,1286:22,1286:24, 1322:8,1326:17,1338:17,1338:22, 1339:24

2006[3]-1315:40,1316:23,1326:17

2007[7]-1274:39,1286:22, 1286:24,1286:27,1338:19,1340:25,1341:19

2008 [5] - 1238:44,1274:21, 1274:30,1291 :35, 1359:28

2009[2]-1232:41,1272:12

20:00 [1] - 1246:3021 [1] - 1355:4621.5.43 [1] - 1324:40

TRAN.022.0129 R

22 [12] - 1232:42, 1241 :34,1242:28, 1243:21,1243:30, 1243:46,1315:39,1316:23,1349:42, 1350:3,1350:13,1356:37

23 [5] - 1257:36, 1319: 13,1324:36, 1338:25,1338:39

24 [1] - 1328:34240 [1] - 1248:21245 [1] - 1247:6248 [3] - 1246:45, 1249: 19,

1257:3125 [17] - 1241 :30, 1242:29,

1243:21, 1245:41,1246:16, 1246:21,1257:34,1258:3,1266:43, 1274:21,1278:10,1344:23,1344:24, 1344:25,1344:29, 1344:30,1344:31

25.3.42 [1] -1324:36250 [2] - 1247:2, 1257:4026[1]-1347:33260[15]-1247:6,1247:46,

1248:6, 1248:31,1249:2, 1249:9,1257:24,1257:40,1258:5, 1258:21,1258:22,1260:15,1260:19,1266:22,1299:35

265[1] - 1239:1427 [1] - 1243:3027th [1] - 1338:4028[1]-1264:11

3

3[9]-1242:34,1242:36,1243:3, 1243:4, 1243:5,1244:27,1265:5,1268:24, 1338:41

3,000[1]-1270:333-4 [1] - 1346:530 [10] - 1245:3, 1246:21,

1265:36, 1322:23,1322:27,1322:28,1322:30, 1322:31,1323:30, 1324:37

3D-year [2] - 1321 :32,1323:16

30/12/1941 [1]-1266:1031 [1] - 1264:4331/12/1941 [2]-1265:26,

1265:3032 [2] - 1330:20, 1330:2333[1]-1245:1139[1]-1328:5

4

4 [16] -1237:9,1242:34,

L-----.19/1/09 (22) ------~-----1Transcript produced by Merrill Legal Solutions

Page 130: COMMISSION OF INQUIRY INTO THE LOSS OF HMAS SYDNEY II … · 2009-08-02 · Executive Officer in a patrol boat is the senior watch-keeper, but the navigation officer spends a lot

1242:36,1243:3,

1243:4,1243:5,1243:10,1243:11,1243:19,1243:47,

1244:36,1244:43,

1268:24,1270:26,1323:19,1338:42

4,20PM [1] - 1359:27

4,5 [1] - 1244:41

40[1]-1240:16

400 [1] - 1269:25

41 [1]-1269:19

45 [1] - 1258:3

453 [1] - 1252:35

47 [2] - 1357:5, 1357:43

48 [2] - 1335:44, 1336:33

5

5 [16] -1232:30,1243:25,1245:45,1260:28,1260:30,1263:7,

1263:8,1263:9,

1263: 14, 1263: 15,1264:23,1265:47,1266:28,1270:22,

1270:28,1337:20

5-inch[1]-1251:165,15[4]-1269:45,

1270:22,1270:30,

1270:425,15pm[3]-1269:44,

1270:19,1270:21

5/6/1998 [1] - 1337:34

50 [7] - 1245:5, 1260:35,

1260:41,1262:36,1331:38,1332:17,

1334:26500 [1] - 1248:41

51 [1] - 1335:26

55 [1] - 1232:30

5nM [1] - 1251 :44

5pm [3] -1270:5,1270:19,

1270:27

6

6 [5] -1234:26,1243:25,1243:30,1246:13,

1338:4560[5]-1249:16,1250:45,

1260:36,1260:42,

1262:3666 [3] - 1308:22, 1309:5,

1309: 1467[2]-1309:12,1309:15

7

7 [2] -1289:35,1290:7

8

8 [1] -1264:21

80[1]-1281:4

80-plus [1] -1272:43

80-year-old [1] - 1281 :16

Sam [1] - 1273:9

9

9[2]-1283:45,1284:6

9,30 [1] - 1359:23

9,30AM [1]-1359:28

90[1]-1310:16

91 [1] - 1305:42

93 [3] - 1298:26, 1299:2,

1306:3494[1]-1304:15

A

1314:21, 1333:23,

1333:44,1338:11,1338:12,1338:14,1338:15,1338:17,

1351:4, 1351 :20,

1352:39, 1353:5,

1353:24accepted[6]-1241:10,

1275:41, 1333:28,

1333:43, 1334:4, 1334:5

accepting [1] - 1334:3access [1] - 1238:40accidentally [1] - 1329:24accompanied [3] -

1340:36, 1346:42,

1358:15accord [10] -1244:28,

1245:12,1246:36,1247:3,1247:35,

1259:4, 1259:5,1263:40, 1264:30,

1265:8accordance [1] - 1334:5

According [6] - 1245:40,1258:2, 1277:1,1279:23,1288:16,

1306:43according [6] - 1244:36,

1294:17,1300:10,

1307:27,1337:36,

1338:37account [32] - 1240:26,

1248:11,1262:44,1263:10,1266:44,1267:30, 1268:36,

1269:3, 1272:9,1272:42, 1275:2,

1275:41, 1276:31,1276:36, 1278:1,

1282:22, 1284:23,1295:11,1297:19,1297:20, 1297:43,

1299:8, 1300:3,

1300:11,1301:26,1301:27,1305:17,1308:3,1313:10,

1318:28,1320:11,

1343:42accountable [1] - 1255:37accounted [7] - 1301: 13,

1301 :14, 1304:33,1307:47,1308:9,

1308:11,1308:13

accounts [4] - 1271 :42,1272:4, 1275:33, 1284:2

accuracy [1] - 1239:31accurate [3] - 1239:37,

1240:29, 1269:41

accurately [2] - 1251 :27,

1269:31achieve[6]-1234:41,

1239:44, 1256:41,1259:41, 1260:8, 1260:9

achieved[1]-1237:41

achieves [1] - 1257:1

acknowledged [2]-

1357:31,1358:17

acrimonious [3] ­

1273:39,1275:35,

1275:47acting [2] -1357:32,

1358:18action [9] -1280:18,

1281:42,1282:31,1298:33, 1299:29,1306:1,1306:6,1306:7,

1308:14actions [2] -1267:30,

1306:30activists [1] - 1275:9activities [2] - 1234:38,

1257:4activity [4] -1256:42,

1257:1,1257:12,1357:9

actual [4] - 1233:37,

1256:44, 1262:4,

1268:35acute [2] - 1262:43,

1268:34ADAM [1] - 1240:37

add[5]-1245:20, 1261:6,

1262:21, 1325:46,

1353:17added [1] - 1274:28

adding[1]-1245:15

additional [2] - 1240:25,

1241:21Additionally[2]-1236:40,

1251:41address [7] - 1233: 10,

1259:7,1266:3,1285:3,

1351:37,1354:27,

1355:40addressed[1]-1353:13

Addressed [2] -1348:44,

1348:45addressing [1] - 1306:34

Adelaide [1] - 1254:47

Adey [5] - 1324:4,1324:12,1324:20,1324:45, 1327:5

ADEY [1] - 1327:7

Adey's [7] - 1324:5,1324:8, 1324:9,

1324:17,1324:18,

1324:25, 1324:28

ADFA[I]-1234:6

adhere [3] - 1310:24,

1310:28,1312:11

adipocre[1]-1316:46

adjourn [2] - 1300:34,

1355:12adjourned[1]-1305:16

ADJOURNED [1]­

1359:27adjournment [2] -

1271 :25, 1306:35

ADJOURNMENT[2] ­

1271 :27, 1300:37

Admiral [3] - 1290:39,1330:10,1356:2

Admiralty [5] - 1263:23,

1295:1, 1356:4,

1356:12,1356:25

TRAN.022.0130_R

ADMIRALTV [1] - 1263:47

admit [1] - 1280:12

admittedly [1] - 1287:3

adopting [2] - 1303:4,

1303:19advance [1] - 1264:27

advanced [1] - 1254:28

advantage [2] - 1258:40,

1266:29advice [5] - 1274:33,

1289:9, 1289:20,1356:4, 1356:11

advise[1]-1304:12

advised [4] - 1276:42,

1304:17,1343:27,

1357:8affair[1]-1281:26

Affairs [1] -1275:40

affect [2] - 1252:22,

1262:6affected [1] - 1323: 16

affecting[1]-1255:38

AFFIDAVlT[I]-1284:27

affidavit[4]-1283:40,1283:43, 1284:1,

1284:25Afghanistan [1] -1238:10

afraid[5]-1300:32,1312:2, 1333:24, 1355:3

Africa [2] - 1291 :8,

1302:13aft [5] - 1249:27, 1259:2,

1261:17,1261:22,

1261:44afternoon [5] - 1242:13,

1242:34, 1244:26,1246:44, 1308:28

age [2] - 1332:2, 1335:8

agent[2]-1316:18,

1316:21ages[2]-1319:47,1329:1

AGH [1] - 1324:43

ago [11] - 1250:9, 1253:24,

1269:43, 1285:26,1286:7,1291:22,1296:45,1319:47,

1326:15,1346:36,

1351:45agree [12] - 1245:38,

1269:1, 1269:40,1308:15,1310:9,

1310:19,1311:32,

1330:2, 1352:45,1353:36, 1353:46,

1353:47Agree [1] - 1352:46

agreed [2] - 1348:17,

1353:35Agreed[1]-1318:21

agriculturist [3] - 1313:41,

1320:47,1323:12

agriculturists [1] - 1321 :4

ahead[7]-1241:20,

1248:8, 1249:3,

1258:15,1262:35,1262:39, 1262:46

Ahlbach [2] - 1252:38,

'-------, 19/1 /09 (22) ----'-------2--

Transcripl produced by Merrill Legal Solulions

Page 131: COMMISSION OF INQUIRY INTO THE LOSS OF HMAS SYDNEY II … · 2009-08-02 · Executive Officer in a patrol boat is the senior watch-keeper, but the navigation officer spends a lot

TRAN.022.0131 R

3( 2)

1261:43 1252:22, 1260:33, 1248:40, 1250:44, 1334:43, 1335:29, assisting [3] - 1276:12,aid [4] -1247:28,1268:4, 1260:34,1260:37, 1272:23, 1281:3 1336:5,1336:13, 1283:28,1284:31

1268:12,1278:32 1261:1,1261:2,1261:4, approached [2] -1266:18, 1336:47,1337:15, associated [2] - 1274:9,aim [3] -1239:44, 1262:35, 1262:40, 1278:38 1337:20,1337:37, 1326:4

1256:42,1257:1 1262:42, 1262:43, approaches [1] - 1256:17 1356:15,1356:30 association [1] - 1288:13aimed [2] - 1279:35, 1268:17,1268:33, approaching [1] - 1267:37 Arthur's [3] - 1336:37, assume [13] - 1247:44,

1281:44 1268:34, 1269:45 appropriate [1] - 1241 :27 1336:39, 1336:40 1248:46,1257:18,aiming [1] -1258:37 Angwin [1] - 1276:15 appropriately [1]- ARllCLE[2]-1283:17, 1259:36, 1267:31,air[2]-1240:3,1283:34 anomalies [3] - 1275:21, 1241:26 1358:33 1269:31, 1299:40,

Albany [1] - 1241 :46 1334:21 approximate [3] - article[17]-1277:46, 1300:18,1312:39,

alcoholic [1] -1334:35 ANOMALY[I]-1344:31 1269:38, 1304:40, 1278:6, 1282:38, 1320:10,1329:43,

Alexander [1] - 1283:38 anomaly [3] - 1274:4, 1316:10 1283:20, 1283:24, 1329:44, 1347:28

ALEXANDER [1]- 1274:8, 1344:25 approximation [1]- 1283:30, 1283:33, Assume [1] -1259:12

1284:27 answer[6]-1288:7, 1240:6 1284:7,1284:9, assumed [5] - 1249:37,

Ali [1] - 1236:46 1290:9,1316:43, April [1] - 1273:33 1284:12,1284:16, 1298:1, 1300:24,

alien [1] - 1247:33 1330:18,1350:24, Aquitania [18] - 1273:14, 1320:26, 1358:2, 1327:36, 1346:41

align [1] -1237:37 1356:16 1308:37,1309:9, 1358:13,1358:22, assuming [7] - 1252:3,

alive[3]-1282:47, answered [3] - 1303:24, 1312:30,1327:14, 1358:25 1260:21, 1260:43,

1342:36,1348:1 1346:41,1348:14 1327:17,1327:30, articles [1] - 1320:27 1268:25, 1269:41,

allege[4]-1294:31, anti [5] - 1241 :43, 1242:6, 1327:31, 1327:33, Arunta[1]-1256:4 1269:46,1297:47

1294:35,1328:43, 1242:9,1244:12,1277:9 1327:37,1327:45, AS[I]-1250:41 assumption [23] -

1336:31 anti-cyclone [4] - 1241 :43, 1328:10,1328:15, ascertain [3] - 1275:25, 1249:14,1249:37,

alleged [7] - 1273:14, 1242:6, 1242:9, 1244:12 1328:19,1328:27, 1283:22, 1333:8 1260:14,1294:19,

1276:10,1276:20, anti-scuttling [1] - 1277:9 1328:34, 1328:41, ascribed [1] - 1358:9 1307:9,1307:17,

1276:22,1280:7, anticipate [1] -1233:3 1328:43 ashore [13] -1255:16, 1307:19,1307:36,

1280:9,1281:14 anxious[1]-1291:18 arc[1]-1247:15 1255:46,1274:14, 1309:20, 1309:22,

allegedly [1] - 1276:33 AnywaY[1]-1312:2 Architects [1] -1287:10 1339:16,1340:1, 1309:25, 1309:26,

Allied [1] -1264:14 anyway[3]-1249:15, archive [1] - 1240:36 1343:14,1350:40, 1310:9,1310:17,

allow[1] - 1259:45 1260:29, 1343:41 archives [3] - 1238:41, 1353:29, 1353:31, 1311:45,1318:39,

allowed [1] - 1343:36 AO [1] - 1232:25 1240:36, 1324:6 1353:34, 1353:39, 1320:7,1327:15,

allowing [1] -1336:30 apart [6] - 1267: 15, area[13]-1249:15, 1353:45, 1354:41 1327:16,1329:47,

almighty [1] - 1297:28 1301 :42, 1325:33, 1249:21, 1249:44, Asia[2]-1256:18, 1330:1,1330:2,1330:4

almost [3] - 1249:45, 1343:26,1345:14, 1249:47,1262:25, 1282:15 assumptions [5]-

1278:31,1319:20 1350:35 1274:7,1275:16, aside[1]-1265:39 1257:17,1257:22,

Almost [1] - 1250:6 Apart [2] - 1340:5, 1354:9 1291 :18, 1292:5, ASIO [2] - 1288:9, 1288:20 1257:36,1298:3,

alone[1]-1311:23 APIO [3] - 1287:40, 1336:33,1342:18, aspect [11] - 1255:42, 1311:32

alright [1] - 1356:40 1288:10,1288:12 1351 :18, 1352:37 1262:31,1268:1, assures [1] - 1313:38

altered [2] - 1351:47, appear [8] - 1282:45, areas [2] - 1234:9, 1280:4 1268:8,1268:13, astern[6]-1248:47,

1352: 1 1283:7,1286:44, arena[1]-1277:44 1268:16,1268:31, 1249:3, 1249:4,

altering [1] -1236:14 1292:43,1303:10, argument[1]-1308:12 1268:39, 1268:40, 1250:10,1250:11,

alternative [2] -1271 :32, 1321:8,1321:11 arguments [1] - 1301:44 1313:31,1339:38 1268:27

1328:11 appearance [1] - 1243:28 arid[1]-1353:22 aspects [1] - 1256:21 astonish [1] - 1289:43

altimetric [1] -1344:23 appeared [2] - 1275:8, arise [1] - 1343:30 assembled[1]-1277:14 AT[2]-1359:27,1359:28

ALTIMETRIC[I]-1344:29 1302:44 arises [1] -1263:29 assent [1] - 1286:1 atmos[1]-1317:1

America [1] - 1279:46 appearing [2] - 1274:29, arising [1] - 1252:32 assert[1]-1358:14 Attache [1] - 1308:35

American [1] -1358:5 1304:42 arm[1]-1250:29 asserted[1]-1309:4 attack [1] -1280:4

AMERICAN [1] - 1358:33 application [1] - 1234:16 armament [1] -1335:19 asserting[1]-1310:8 attacked[3]-1291:10,

American.) [1] -1332:23 Application [2] - 1237:9, armed[1]-1279:25 assertion[2]-1310:7, 1292:11,1292:15

amount [4] -1256:16, 1253:32 arms [1] - 1277:35 1310:12 attacks [2] - 1273:37,

1290:18,1311:3, applied [2] - 1241 :25, Army [12] - 1276:6, assertions [2] - 1272:21, 1282:15

1343:39 1241:40 1276:42,1313:26, 1311:12 attempt [4] - 1275:25,

AN [1] -1239:9 apply [3] -1240:47, 1313:46,1314:11, assess [1] - 1251:41 1283:22,1350:10,

analysis [6] - 1239:42, 1251 :25, 1333:6 1317:37,1320:47, assessed [2] - 1243:7, 1350:18

1240:16,1240:34, applying [2] - 1239:45, 1321 :21, 1322:44, 1256:32 attempted [1] -1283:33

1241:9,1241:29, 1336:3 1323:20, 1323:21, assessment[3]-1241:31, attempting [5] - 1239:33,

1310:11 appointed[1]-1314:16 1354:3 1242:30, 1258:43 1284:30, 1284:31,

ANALYSIS [1] - 1239:9 appreciate[1]-1316:37 army [1] - 1349:32 assist [2] - 1236:6, 1306:15,1336:7

analyst [3] - 1287:33, appreciated [1] - 1336: 11 arrive [1] -1340:39 1236:10 attempts [1] - 1284:20

1288:28,1289:13 appreciating[1]-1236:17 arrived [4] - 1280:34, Assistance [1] - 1235:21 attend [1] - 1283:40

analytical [1] - 1288:32 appreciation [8]- 1338:41, 1338:42, assistance [2] - 1273:4, attended [1] - 1275:30

AND[9]-1239:25, 1233:12,1233:36, 1338:44 1356:40 attention [2] -1252:35,

1239:26,1261:13, 1236:11, 1236:39, arrow[2]-1242:22, assistant [4] - 1313:42, 1272:7

1264:1,1271:11, 1237:15,1263:40, 1248:15 1314:17,1314:31, attractive [2] - 1327:31,

1323:44,1344:28, 1267:9, 1267:11 artefacts [1] - 1271:43 1325:23 1327:33

1344:29 apprehension [1] - ARTHUR [1] - 1337:33 Assistant [1] - 1277:29 attribute [3] - 1285:35,

angle[16]-1250:44, 1235:42 Arthur[13]-1331:2, assisted [1] - 1277:28 1305:17,1309:16

approach[5]-1241:11, 1331:8,1331:41, Assisting [1] - 1232:33 attributed[1]-1281:16

,19/1/09 2Transcripl produced by Merrill Legal Solulions

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Aug [1] - 1340:40 1316:27,1317:15, Base [2] - 1256:5, 1256:15 BEARING [1] - 1263:47 bewilderment [1]-

Aussies [1] -1332:22 1317:46,1318:3, baSe[1]-1244:5 bearingS[1]-1302:13 1272:25

Australia [31] - 1233:31, 1318:10,1318:17, baseball [1] - 1281 :29 Beaufort [4] - 1243:1, beyond [1] - 1262:241234:18,1237:29, 1318:24,1318:31, based [20] - 1233:28, 1243:26,1271:4,1271:7 big [2] -1260:37,1329:311240:37,1256:4, 1318:34,1318:37, 1235:3, 1235:5, BEAUFORT[I]-1271:11 billet [3] - 1255: 13,1272:16,1274:36, 1318:45,1319:16, 1235:13,1243:27, Beaufort's [2] - 1242:37, 1255:47,1256:11276:6,1278:15, 1324:21, 1324:46, 1245:28, 1246:6, 1242:40 billets[2]-1254:46,1278:20,1279:16, 1325:3, 1325:21, 1255:27,1256:4, beautiful [1]-1280:37 1255:151279:46,1281:19, 1325:32, 1325:33, 1256:7,1258:20, became [5] - 1235:32, BiIIson[1]-1277:291282:18,1283:6, 1326:38 1260:29,1260:47, 1278:28,1278:47, bit [12] - 1247:11, 1248:25,1291:3,1304:9, autumn [1] - 1280:37 1261 :2, 1281 :39, 1335:16,1340:26 1253:24,1262:14,1306:25,1313:18, available [5] - 1275:12, 1287:3, 1290:4, become [6] -1239:36, 1269:33, 1269:39,1319:12,1325:35, 1289:5, 1323:5, 1290:17,1290:22, 1240:23, 1246:11, 1270:1, 1290:5,1339:41,1339:43, 1324:10,1333:12 1358:27 1251 :32, 1275:9, 1290:31,1302:41,1347:18,1347:19, aviation [1] - 1291:7 basic [8] - 1234: 19, 1344:26 1341 :20, 1355:41349:31,1353:22, avoid[1]-1268:14 1234:26, 1235:24, bed[I]-1274:11 bits[2]-1311:34,1311:361354:20,1355:3, award [1] - 1234:23 1235:40, 1240:46, bed"[2]-1340:31, blank[1]-1271:61355:17,1357:10 awarded [2] - 1234:27, 1253:24, 1266:31, 1341:39 BLANK[I]-1271:10

Australian[53]-1233:16, 1235:7 1311:40 beg [1] -1288:12 blazing [4] - 1287: 1,1233:47,1234:4, aware [9] - 1237:21, basis [28] - 1293:8, began [4] - 1279:20, 1287:4,1287:51235:5,1235:39, 1272:36,1297:15, 1296:9,1296:10, 1282:5,1322:47,1340:3 Blockade [1] - 1263:251239:35,1241:47, 1336:32,1337:14, 1296:12,1296:25, begin [2] -1242:14, BLOCKADE [1] - 1264:11242:3,1256:1, 1337:23, 1337:25, 1301 :35, 1305:7, 1257:23 blowing [2] - 1242:25,1256:16,1257:9, 1348:10,1356:19 1305:11, 1309:25, beginning [1] - 1299:29 1262:151269:36,1273:23, AWO [1] - 1255:2 1310:8,1310:13, begun [1] - 1279:45 blown [2] - 1245:24,1273:28,1273:30, azimuth [2] - 1246:45, 1311:11,1311:13, behalf [2] - 1253:43, 1302:401273:31,1274:3, 1249:20 1311:35,1314:30, 1255:10 Bluff[I]-1273:21274:5,1274:6, 1317:14,1317:20, behind [3] - 1268:43, board [5] -1235:46,1274:18,1274:23, B 1317:21,1318:7, 1268:44,1269:1 1255:1, 1259:33,1274:25,1274:35, 1323:9, 1330:1, belief [6] - 1272:20, 1292:30, 1292:351275:29, 1276:41, 1339:40, 1343:28, 1293:8, 1296:6, boarding [4] - 1234:36,1277:14,1277:20, Bachelor[1]-1234:7 1343:46, 1350:28, 1339:47,1340:1, 1235:40, 1236:401278:37,1279:14, backed[1]-1240:43 1357:14,1357:36, 1353:42 boat [50] - 1233:28,1279:23,1279:32, background [2] - 1271 :35, 1358:25 believes [2] - 1342:35, 1235:4,1235:18,1281:21,1281:32, 1285:18 BATT.006.0059 [1]- 1347:46 1235:46, 1236:2,1282:1,1283:4, backlit [1] - 1249:22 1298:13 bell [1] - 1337:28 1236:20, 1236:25,1288:13,1288:17, BACKTRACKING [1]- battle[15]-1271:47, belonged[1]-1331:11 1254:6, 1255:25,1291:4,1294:41, 1239:25 1272:22, 1273:3, below [2] - 1322:41, 1255:27,1255:45,1294:42,1295:4, badly [2] - 1277:8, 1275:32, 1275:34,

1350:28 1257:2,1259:11,1310:34,1310:38, 1281:33 1275:41, 1276:32,

Below[1] -1285:40 1259:14,1259:15,1313:26,1324:42, bag [3] -1276:42, 1279:26, 1281 :20,

belt[3]-1319:33,1319:37 1259:19,1259:20,1329:20,1332:21, 1277:13,1332:40 1281:23,1281:33,

beneath[2]-1246:13, 1259:21, 1259:25,1339:10,1344:17, Bairstow[12] - 1233:25, 1282:4,1294:11,

1246:23 1259:27,1259:28,1349:26,1357:8 1233:26, 1233:33, 1296:18,1300:11

benefit [1] - 1271 :34 1259:32, 1259:40,Australians [2] - 1236:32, 1233:36, 1253:3, battleship [1] - 1358: 15

Best [1] - 1317:47 1259:43, 1259:44,1278: 17 1253:9, 1264:31, BAY [1] - 1239:10

best [4] -1276:35, 1259:45,1259:47,authentic [2] - 1276:31, 1264:38,1269:7, Bay [6] - 1274:39,

1286:39, 1316:44, 1260:5, 1260:9,1276:44 1269:34, 1271 :14, 1312:38,1312:43,

1318:35 1260:10,1266:15,author[8]-1265:13, 1271:16 1312:47,1313:3,

bet [1] - 1343:3 1266:16,1266:19,1265:22,1273:18, BAIRSTOW[I]-1253:5 1313:11

better [10] - 1245:24, 1266:23, 1266:30,1278: 1, 1280:7, BAIRSTOW'S [1]- beach [7] - 1276:5,

1246:1,1252:19, 1266:32, 1266:34,1280:22,1283:33, 1261:13 1276:43,1311:1,

1287:31, 1336:19, 1266:35, 1266:38,1283:37 balance[1]-1241:15 1312:3,1312:23,

1336:20,1339:47, 1266:40, 1266:42,author's[1]-1265:17 Ballina[2]-1277:46, 1339:41,1343:11

1344:20, 1346:43, 1266:47,1267:1,authored [1] - 1278:7 1284:18 beaches [1] - 1349:33

1358:30 1277:9, 1293:22,Authors [1] -1272:9 bands [1] - 1355:8 beam[2]-1261:15,

between [19] - 1234:26, 1311:17autopsies [10] - 1313:30, banging [1] - 1266:33 1268:32

1236:17,1241:16, boats [4] - 1233:35,1313:35,1313:38, Barbara [1] - 1273:33 beam-on[2]-1261:15,

1242:19,1242:29, 1235:37,1236:45,1313:39,1314:4, barcoded [1] -1265:27 1268:32

1243:35, 1243:46, 1273:11314:15,1314:20, BARCODED [6] - 1263:46, bear[1]-1261:23

1247:6,1248:29, BOB [1] -1239:191314:27,1314:31, 1265:31,1266:10, bearing [12] - 1233:20,

1251:31,1256:19, bodies [40] - 1273:7,1321:5 1271:11,1323:44, 1242:19,1246:43,

1268:26, 1272:35, 1273:13,1276:5,autopsy [28] - 1276:21, 1337:34 1247:5, 1248:41,

1276:37,1276:39, 1276:8, 1276:11,1276:22,1313:27, Barracks[4]-1331:9, 1250:9, 1257:31,

1281 :21, 1309:24, 1310:37,1310:38,1313:38,1314:25, 1331:12,1332:10, 1258:20,1270:18, 1310:12,1330:4 1310:47,1312:3,1314:35,1315:27, 1337:38 1303:6, 1303:23, Between [2] - 1263:14, 1312:23, 1338:25,1315:44,1316:10, barracks [1] - 1332:6 1344:40

1274:21 1338:30, 1338:32,

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1338:34,1339:10, books [2] -1272:10, 1325:20 1239:10, 1239:15, 1248:35, 1249:26,

1339:14,1339:40, 1278:30 brought [6] - 1269: 14, 1239:18, 1239:26, 1250:4, 1250:33,1343:10,1343:11, bordering [1] -1275:8 1269:28, 1285:32, 1250:41,1251:5, 1250:38, 1252:44,1343:16,1343:22, boss [1] - 1288:2 1293:10,1298:20, 1253:7,1269:12, 1253:3,1253:7,1253:9,

1343:26,1343:29, Botanical [1] - 1334:33 1324:27 1284:44, 1358:34 1258:8,1261:13,

1343:39,1349:30, bottom [20] - 1263:22, Bruce [10] - 1315:4, 1261:15,1263:44,1349:36,1350:40, 1264:9, 1274:30, 1315:7,1315:16, C 1264:6, 1264:31,1351:16,1351:31, 1280:43,1280:47, 1316:39,1340:20, 1264:37,1264:38,

1352:29,1353:2, 1289:38,1298:19, 1340:22,1340:37, 1265:11,1265:19,1353:28,1353:31, 1303:2, 1308:23, 1340:39, 1342:24, C-in-C[4]-1336:31, 1265:34, 1265:38,

1353:34,1353:36, 1309:5,1309:14, 1348:24 1356:12,1356:42, 1266:4, 1266:8,1353:37,1353:38, 1315:38,1316:31, Bruce's [2] - 1347:12, 1356:44 1266:13,1267:3,

1353:45,1353:46, 1328:6,1330:27, 1347:15Cabinet [1] - 1290:33 1269:6,1269:7,

1354:41 1337:11, 1342:26, bugle [1] - 1332:5 cadaVer[1]-1316:45 1269:34, 1271 :3,

Bodies [1] - 1353:21 1343:43,1347:32, bugler[1]-1331:11 cafe [2] - 1334:33, 1271:14,1271:16,

body [21] - 1240:3, 1347:36 built [1] - 1255:43 1335:39 1272:36, 1272:38,

1274:24,1276:23, bound [1] - 1349:38 bullet [3] -1277:27, Cairns [4] - 1235:3, 1310:25,1310:29,

1277:18,1277:20, bow[9] - 1257:44, 1258:4, 1277:31, 1277:34 1235:17,1235:38, 1310:33,1310:47,

1277:30,1277:31, 1268:17,1293:43, Bungendore [1] - 1238: 15 1255:27 1312:3,1312:22,

1313:28,1313:32, 1295:30, 1295:33, Bunjes [2] -1245:36, Cairns-based [1] - 1235:3 1313:17,1313:34,

1314:36,1316:8, 1295:37,1295:40, 1298:34 calculated [2] - 1246:34, 1313:47,1314:7,

1316:9,1316:42, 1297:28 BUREAU [1] - 1239:15 1309:21 1317:37,1317:42,

1317:11,1318:42, box [3] -1276:43, BUreaU[6]-1237:27,calculation [3] - 1248:36, 1318:29,1319:5,

1318:44,1319:17, 1277:13,1326:12 1237:30, 1237:46, 1250:25 1319:10,1319:19,

1319:18,1319:19, bracket [1] - 1263:3 1238:2, 1240:36,CALCULATIONS [1]- 1323:44, 1325:3,

1319:26,1325:28 brain[1]-1280:20 1278:131261:13 1325:35, 1325:45,

Bombay [1] - 1324:35 Branch [1] - 1351 :39 Burgel [6]-1238:46, calculations [2] - 1240:39, 1326:43, 1327:1,

bonnet [1] -1249:31 Braum [1] - 1265:17 1239:5,1239:7, 1248:44 1327:3, 1330:8, 1331 :4

book [77] -1243:23, breached [1] - 1272:22 1239:28, 1239:41, Camden [1] - 1325:12 Captain [17] - 1234:44,

1273:33,1275:36, breeze [1] - 1243:6 1243:20 camouflage [1] - 1306:14 1235:12,1235:28,

1278:42,1279:12, Brett [1] -1276:17 BURGEL [1] - 1239:11 camp [1] -1272:41 1253:42, 1253:44,

1285:35,1285:40, Bridge[9]-1234:19, Burgel's [2] - 1240:33, campaign [1] - 1280:44 1255:10,1257:11,

1285:45,1286:7, 1234:23,1234:27, 1241:26 Canberra [5] - 1235:5, 1281:36,1308:27,

1286:9,1286:32, 1234:42, 1237:8, burial [3] - 1276:8, 1254:47,1284:13, 1308:30, 1308:31,

1286:33,1287:32, 1237:24, 1253:20, 1276:11,1354:16 1350:2, 1350:7 1309:6, 1313:25,

1287:37,1287:39, 1253:40, 1254:8 burials[1]-1313:18 cannot [7] - 1263:33, 1322:44, 1330:29,

1288:16,1289:33, bridge [14] - 1234:45, buried [20] - 1276:5, 1311:15,1311:16, 1336:32, 1356:39

1289:34,1290:19, 1235:11,1236:4, 1293:12,1293:15, 1311 :29, 1324:5, caption [2] - 1351 :13,

1290:22,1290:44, 1236:5,1237:13, 1310:41,1310:44, 1343:40, 1354:23 1353:19

1291 :24, 1291 :25, 1245:44, 1248:39, 1310:47,1312:3, capable [3] - 1328:28, capture [1] - 1242:43

1292:28,1292:32, 1261:3,1261:17, 1312:23,1317:12, 1328:31,1333:13 car[1]-1249:32

1293:39,1293:40, 1261 :22, 1261 :44, 1319:20,1325:31, Capable[1]-1333:17 cards [1] - 1338:38

1294:4,1294:17, 1262:2 1339:15,1339:41, Cape [16] - 1273:7, care [1] - 1280:361294:22,1297:33, bridgemanship [1]- 1342:22, 1343:22, 1273:12,1338:25, career[5]-1238:1,1298:17,1298:23,

1253:34 1349:34, 1350:40, 1338:37,1343:12, 1253:28, 1323:3,1298:25,1299:5,

briefly [6] - 1239:43, 1353:29, 1353:46, 1343:13,1343:20, 1323:21, 1330:81299:18,1302:23, 1268:20, 1268:23, 1354:41 1343:22, 1351 :9, Carr[1] - 1355:381303:10,1303:30, 1284:35, 1342:33, Burma [3] - 1304:25, 1351:15,1351:31, carried [7] - 1276:21,1303:32,1305:42,

1347:44 1304:41 1352:19,1352:43, 1317:15,1318:31,1308:22,1308:43,

bright[I]-1250:19 Burmese[1]-1307:46 1352:45, 1353:21, 1319:1,1319:16,1309:30,1309:36,

bring [13] -1248:12, BURN,001,0014 [1]-1353:35 1320:15,1325:33

1309:41,1310:11,1261 :7, 1262:30, 1269:28 capital [1]-1304:47 carrier [1] - 1291:7

1310:15,1310:23,1263:18, 1265:21, burned [2] - 1286:36, capping [1] - 1243:15 carry[1]-1312:34

1311:6,1313:22,1265:34, 1266:20, 1287:28 capsized [1] -1272:43 carrying [2] - 1291 :7,

1320:25,1322:40,1267:30, 1288:33, Burnett [2] - 1272:36, Capt[2]-1316:27, 1318:47

1325:27,1326:5,1316:12,1322:6, 1356:39 1318:17 case [7] - 1253:29,

1326:34,1328:5,1331:25 burning [1] - 1267:35 CAPT [82] - 1232:34, 1254:37,1254:40,

1329:5,1330:13,brings [2] - 1290:27, burnt [2] - 1350: 1, 1233:1, 1233:6, 1258:13,1267:11,

1330:15,1330:20,1309:35 1350:36 1233:24, 1233:26, 1279:1,1335:16

1331:31,1331:38,Britain [1] - 1279:46 1233:33, 1233:36, cases [1] - 1265:3burnt-out [2] - 1350: 1,

1333:35,1334:22,British[4]-1264:14, 1350:36 1233:44, 1233:46, Cassells [1] -1279:13

1335: 15, 1335: 16,1280:1, 1294:35, 1238:32, 1238:36, cast [1] - 1250:15

1336:8,1336:46,bury [1] -1343:17

1332:27 1239:4, 1239:21, casting [3] -1249:23,1337:2,1337:15, burying [1] - 1354:3

broad [1] -1256:20 bus [1] -1276:371239:28, 1242:11, 1250:23, 1251 :24

1337:43,1338:9,Broome [2] -1235:39, 1242:40, 1242:46, catalyst [1] - 1308:7

1351:6,1354:14, bushfire [1] - 1237:361338:39

1243:23, 1243:33, categorically [1] - 1338:281355:46,1357:2 buy [1] - 1349:24

1244:46, 1246:3,brother [2] - 1318:30, BY [11] - 1233:44, caused[1]-1273:45

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cave [1] - 1338:29 1236:5,1240:13, 1239:17 1347:31, 1348:3, 1256:4, 1256:5,

ceaSed[1]-1281:32 1240:15,1240:17, close [25] - 1235:18, 1349:10, 1349:30, 1256:10,1256:23,

Cecil [2]-1320:45, 1241:14,1241:18, 1246:19,1248:40, 1354:13, 1354:31, 1256:40, 1256:41,

1322: 18 1251 :21, 1344:5 1257:41,1258:10, 1355:11, 1355:25, 1256:42,1257:14,

cellophane [1] - 1250:16 chartS[2]-1238:42 1258:12,1258:18, 1355:43, 1358:36, 1267:9, 1267:11,

cemented [1] - 1292:8 check [2] - 1303:14, 1258:20, 1258:25, 1358:43,1359:11, 1306:3,1357:31,

cemetery [1] -1349:24 1320:36 1258:34,1258:37, 1359:13,1359:23 1358:17

cent[7]-1246:31, checked [1] - 1279:5 1258:43, 1259:1, CO [1] - 1255:33 Command [2] - 1233:26,

1249:16,1250:7, chemistry [1] - 1234:11 1259:37, 1261 :15, Coalition [2] - 1235:20, 1256:1

1250:45,1260:36, Chief [2] -1290:38, 1261 :37, 1261 :39, 1236:31 commanded [2]-

1260:42,1310:16 1329:17 1263:36, 1264:22, Coast [3] - 1353:22, 1233:27,1330:31

Centre [1] - 1275:44 China[10]-1256:18, 1266:30, 1269:39, 1357:33,1358:19 commander [3] - 1256:36,

centre [2] -1248:3, 1312:37,1330:30, 1270:30, 1272:23, COAST [2] - 1239: 10, 1257:10,1308:26

1248: 13 1331:1,1331:2,1331:8, 1273:43, 1279:26 1239:18 COMMANDER [1]-

CENTURY [3] - 1282:41, 1336:31,1356:12, closed[4]-1258:38, coast [19] - 1233:30, 1284:44

1283:8,1283:17 1356:42, 1356:44 1267:6, 1322:22, 1238:22, 1239:35, Commander [32] -

Century [1] - 1277:46 Chinese [5] - 1292:30, 1322:26 1241:41,1242:3, 1233:25, 1256:25,

CerberUS[1]-1256:2 1292:35, 1293:9, cIOSer[4]-1251:33, 1244:13,1256:16, 1257:9,1282:33,

certain [6] - 1240:2, 1295:12,1297:2 1270:4,1270:19, 1274:3, 1274:25, 1286:18,1287:38,

1240:18,1256:38, Christian [1] - 1276:17 1270:22 1279:16,1281:19, 1295:33, 1298:30,

1256:42,1260:35, Christmas [4] - 1256:17, cIOSeS[1]-1258:19 1304:40, 1307:46, 1302:38,1303:10,

1311:29 1277:18,1277:20, closing[2]-1258:31, 1310:35,1310:38, 1309:41,1310:1,

certainly [19] - 1239:46, 1315:34 1259:3 1339:11,1339:15, 1316:21,1320:7,

1240:29,1241:17, Churchill [2]-1294:38, cloth [1] - 1250:17 1349:31,1357:9 1321 :22, 1324:9,

1246:15,1246:27, 1294:44 cloud [2] -1245:27, coastal [1] - 1241 :44 1324:47,1328:18,

1248:42,1249:33, circle [1] -1250:1 1245:31 coastline [1] - 1344:17 1329:17,1329:19,

1262:27,1266:42, circled [1] - 1248:12 clouds [1] -1245:33 Code [1] - 1280:2 1330:15, 1330:21,

1267:13,1267:28, circulated [1] - 1276:11 CMDR [95] -1232:33, cognitive[1]-1280:12 1332:44, 1335:23,

1267:30,1301:31, circulating [1] - 1339:42 1232:38, 1233:1, COl [8] -1244:25,1245:9, 1336:27,1341:1,

1311:2,1311:8, circumstance [1]- 1251:1,1251:3,1251:5, 1246:47,1258:47, 1345:20, 1346:25,

1319:20,1324:38, 1301 :25 1251 :7, 1252:8, 1261:20,1266:17, 1350:30, 1355:32,

1328:10,1329:42 circumstances [3]- 1252:34,1265:13, 1267:5, 1267:33 1355:35,1357:45

certainty [5] -1240:24, 1264:21,1273:17, 1265:24, 1269:9, COL006,0015 [1] - 1261:8 Commander-in-Chief[1] -

1260:42,1275:26, 1342:15 1269:12,1269:14, COL006,0018 [1]- 1329:17

1275:45,1316:4 civil[1]-1246:12 1269:27,1270:17, 1269:14 Commanding [1]-

Certificate [7] - 1234:20, civilian [2] - 1237:36, 1270:38, 1271:1, COL006,0020 [1]- 1263:35

1234:23,1234:27, 1320:46 1271 :22, 1271 :29, 1261 :26 commanding [3] -

1234:42,1253:20, claim[4]-1273:22, 1275:2, 1283:20, coincidentally [2] - 1255:34, 1255:35,

1253:41,1254:9 1290:21, 1328:8, 1284:29, 1284:46, 1337:36,1338:10 1356:39

certificate [1] - 1235:11 1328:15 1285:32, 1286:31, Col[2]-1324:12,1327:5 commemorating [1]-

cetera [2] - 1258:30, claimed [1] - 1275:20 1288:27,1290:43, COL [1] - 1327:7 1278:23

1268:36 claiming [1] - 1274:36 1292:28, 1293:21, Cole [1] - 1232:25 commence [1] -1253:15

chain [1] - 1298:3 claims[5]-1271:41, 1297:1,1298:19, collaborate [1] - 1308:36 commenced [2] - 1254:33,

challenged [2] - 1273:34, 1274:17,1274:44, 1298:25, 1299:26, collective [2] - 1256:28, 1267:7

1277:4 1274:46, 1275:26 1301 :3, 1302:6, 1302:8, 1256:31 comment[2]-1233:33,

chance [3] -1281 :35, clarify [2] - 1260:2, 1302:20, 1303:2, Collins[3]-1330:10, 1233:37

1287:38,1303:4 1327:43 1304:17,1305:15, 1330:29,1331:4 Commission [22] -

change [9] -1236:14, class [3] - 1236:25, 1308:22, 1309:29, collision[1]-1268:14 1233:18,1238:23,

1237: 13, 1237: 14, 1254:21, 1255:25 1312:7,1313:22, Colonel [1] -1324:4 1242:32,1271:31,

1246:7,1246:38, classes [1] -1254:101314:23,1315:6, colour [1] - 1260:41 1272:14,1272:17,

1247:5,1252:24, classroom [4] - 1236:33,1315:30,1315:36,

colours [1] - 1250:18 1272:30, 1276:25,

1286:5,1333:37 1237:1, 1253:39,1317:32,1319:12,

combination [1] - 1262:22 1277:45, 1283:21,

changed [7] - 1244:21, 1256:311319:40,1320:13,

combinations [1]- 1283:22, 1283:28,

1252:24,1286:12, clean[1]-1319:71320:33, 1320:41,

1260:41 1283:39, 1283:41,

1286:26,1286:28, clear [5] -1247:37,1323:26, 1323:32,

combine [1] - 1257:28 1284:39, 1295:21,

1286:32,1311:8 1260:43, 1263:6,1323:37,1323:47,

combined [1] - 1248: 111296:1,1346:16,

changes [1] - 1286:5 1268:28,1319:201326:47,1327:5, 1348:8, 1354:43,

COMFLOT[I] -1257:8chaotic [1] -1338:4 clear" [1] - 1245:37

1327:13,1327:43, 1355:16,1358:461328:4,1328:27, coming [4] - 1243:43,

characteristics [1]- clearly [4] -1262:33, 1244:15,1251:10,COMMISSION [2]-

1240:2 1263:9,1324:37,1330:8, 1331 :38, 1232:18,1359:27

1307:6charge [4] - 1256:26, 1331:42

1334:19,1337:14, Commissioner [4]-command [26] -1233:29,

1257:11,1272:40, Cliffs [3] - 1274:5,1337:31, 1337:36, 1233:6,1284:47,1338:24, 1338:44, 1235:29, 1255:24,

1276:7 1274:31, 1352:30 1255:26,1255:27,1350:18,1354:16

Charge [1] -1255:20 cliffs[1]-1351:321339:24,1340:47, Commissioner) [1]-

1255:31, 1255:32,charged [2] -1274:24, climatology [2] - 1241 :47,

1341:23,1341:24, 1344:71342:38,1343:7, 1255:37, 1255:41,

1330:34 1244:20 1255:42, 1255:45, common[1]-1272:17

chart [9] - 1235:27,1344:33, 1345:3, commonplace [2] -

CLiMATOLOGY[I]- 1255:46, 1256:3,

Transcripl produced by Merrill Legal Solulions

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TRAN.022.0135_R

1248:36,1248:42 1330:14, 1335:31, 1323:18 contemporaries [1]- correctly [2] - 1266:3,communicated [1]- 1339:28, 1354:41, confidentiality [1]- 1281:9 1350:14

1341:36 1355:8 1283:1 content[1]-1311:5 correlate [1] - 1239:37Communication [2]- concert [1] - 1253:46 confirm [1] - 1238:28 contents[1]-1277:13 correlating [1] - 1241 :21

1263:23,1263:28 conclude [3] - 1257:6, confirmed [2] - 1318:23, continue [2] - 1238:19, correSpOnd[2]-1315:21,communication [5]- 1305:15,1309:30 1318:34 1340:2 1315:23

1263:30,1312:12, concludes [3] -1250:33, conforms [1] - 1298:33 continued [1] - 1238:7 CORRESPONDENCE [1]-

1312:14,1321:20, 1269:6, 1282:24 conjunction [1] - 1283:25 continues [1] - 1277:44 1323:431331:15 concluding [1] - 1271:3 connection [1] - 1348:8 continuing [3] - 1239:46, correspondence [6] -

Company [4] - 1349:42, conclusion [6] - 1275:35, consensus [7] -1289:24, 1273:30,1273:31 1315:26,1321:30,1350:13,1350:29, 1282:38, 1283:32, 1289:27,1333:14, Continuing [1] -1346:2 1323:11,1323:15,1350:37 1292:16, 1301 :32, 1333:19,1333:23, continuum [4] -1234:15, 1323:26, 1323:29

company [6] - 1234:46, 1304:47 1333:37,1334:1 1234:22, 1253:22, corresponding [2] -1235:43,1253:45, conclusions [1] -1290:24 consequence [11]- 1253:27 1239:39,1240:131312:46,1358:7 concoction [2] - 1283:29, 1276:23,1277:19, contrary[1]-1312:47 corresponds [1] - 1240:17

compare [1] -1346:16 1283:31 1283:27,1285:39, controversial [1]- Cossack [1] - 1338:40compared [2] -1240:38, concrete [1] - 1305:13 1296:37,1297:27, 1272:33 cost [3] - 1350:8, 1350:11,

1281:7 concur [1] - 1264:46 1323:10,1332:34, controversies [1]- 1350:20compares [1] -1239:31 condition [4] - 1276:24, 1338:6, 1341 :37, 1274:43 counsel [4] - 1276:12,comparison [1] -1236:15 1286:38, 1286:39, 1354:44 Controversy [1] - 1273:41 1283:27,1284:30,complete [5] - 1234:24, 1287:21 consequently [1]- controversy [2] - 1271 :40, 1344:20

1236:43,1267:16, conditions [35] -1233:10, 1349:34 1275:6 Counsel [2] -1232:33,1283:1,1316:38 1237:14, 1238:21, consider[6]-1263:13, convenient [2] - 1271 :20, 1232:38

completed [6] - 1235:4, 1239:39, 1240:30, 1265:4,1267:14, 1349:37 count [1] - 1307:331235:15,1236:24, 1240:37,1240:39, 1280:13,1339:30, conversation [4] - counterparts [1] - 1237:361250:39,1253:14, 1240:41,1241:23, 1339:37 1281:14,1321:22, country [4] - 1281 :40,1253:20 1241:32,1241:33, considerable [1]- 1326:8,1326:14 1317:38,1317:43,

COMPLETED[I]- 1241:38,1241:39, 1277:15 convert [2] - 1240:6, 1324:381250:41 1242:12,1242:17, considerably [2]- 1240:7 couple [8] -1234:32,

completely [2] - 1243:40, 1244:26, 1245:1, 1279:27,1298:35 converted [1] - 1240:11 1240:45, 1261 :6,1245:42 1245:17,1247:42, considerations [1]- Cooper [3] - 1332:43, 1269:9, 1286:28,

completing [2] - 1234:7, 1251 :44, 1257:18, 1262:45 1332:47,1333:2 1312:17,1334:41,1255: 15 1258:29,1259:13, considering[1]-1311:14 cooperated [1] - 1277:39 1346:35

completion [6] - 1234:41, 1259:17,1259:34, considers [1] - 1271 :39 coordinates [4] -1304:13, Course[3]-1237:9,1238:4,1254:30, 1263:1, 1263:4, 1263:5, consistent [3] - 1277:34, 1342:39, 1348:5, 1348:9 1253:32, 1256:21254:44,1255:12, 1266:14, 1266:21, 1277:35, 1339:5 copy [15] - 1238:27, course [36] -1234:17,1256:23 1266:34, 1266:36, consolidation [3]- 1238:28, 1264:38, 1235:16,1236:15,

complex [1] - 1349:17 1268:46, 1275:33, 1254:14,1254:18, 1271 :6, 1286:21, 1237:28,1237:31,complicated [1] - 1261:45 1282:44 1254:31 1302:5, 1306:39, 1237:33,1247:46,complicating [1] - 1261 :6 CONDITIONS [3]- conspiracies [1] - 1274:43 1323:19,1340:44, 1248:6,1248:14,

complied [1] -1358:39 1239:10,1239:14, conspiracy [8] - 1271 :35, 1340:45, 1355:34, 1248:22, 1248:30,

component [9] - 1241 :4, 1239:18 1272:1,1273:41, 1357:45, 1358:30 1249:2, 1253:31,

1241:5,1242:2,1257:6, conduct [12] -1234:36, 1273:46, 1275:6, COPY[2]-1271:10, 1254:38, 1255:34,

1258: 15, 1258: 16, 1235:36, 1256:11, 1275:42, 1277:40, 1358:33 1255:41, 1256:2,

1258:22,1260:27, 1256:12,1256:28, 1284:32 copyright [2] - 1286: 15, 1257:24,1257:38,

1261:36 1256:33, 1257:2, Construction [5]- 1286:22 1257:40,1260:19,

components [2] - 1257:3, 1267:20, 1349:42, 1350:3, core [2] - 1253:36, 1264:4, 1264:24,

1234:31,1234:32 1301:46,1314:14, 1350:13,1350:29, 1254:39 1266:21, 1267:39,

compressible [1]- 1314:20 1350:37 corner [2] - 1269:35, 1268:9, 1277:28,

1240:45 CONDUCT[I]-1264:1 contact [7] - 1247:33, 1269:39 1282:16,1283:30,

computer [3] - 1240:35, conducted [13] - 1235:38, 1267:37,1268:10, Corps [1] - 1313:26 1292:26,1298:10,

1350: 1, 1350:36 1237:30, 1248:35, 1331 :42, 1354:26, corps[1]-1354:3 1303:15,1327:37,

computers [1] - 1240:38 1294:21, 1302:2, 1354:27,1354:45 CORR.016,0040 [1]- 1339:26, 1354:44

con [1] -1253:42 1314:25,1315:6, contacted [2] - 1354:38, 1315:30 courses [1] - 1237: 1°concentrate [2] - 1312:25, 1315:9,1315:19, 1355:8 CORR.016,0048 [1]- court [2] - 1290:40,

1313:17 1326:38, 1345:28, contacts[1]-1237:14 1322:6 1305:26

concept [3]-1292:25, 1350:19,1355:26 contain [1] - 1284:8 correct [14] - 1235:34, Courtney [1] - 1239:6

1352:2,1352:3 conducting [2] - 1235:40, contained [5] - 1308:34, 1236:6,1236:27, COURTNEY[I]-1239:15

concern [1] -1312:5 1314:26 1321:46,1322:17, 1238:28, 1269:46, cover [9] - 1245:27,

concerned [5] - 1307:39, conducts [1] - 1237:34 1327:38,1330:47 1286:23,1294:18, 1273:9, 1273:26,

1308:47,1316:37, conference [3] - 1275:30, containing [1] - 1276:43 1295:17,1297:8, 1273:28,1276:7,

1316:42,1336:18 1275:31, 1275:44 CONTAINING [1]- 1332:13,1336:8, 1284:19,1294:44,

concerning [14] - 1272:3, conferences [1] - 1275:27 1271:10 1337:10,1340:10, 1295:1, 1295:5

1272:9,1280:23, confidential [1] - 1323:40 contains [2] - 1271 :7, 1357:16 cover-up [6] - 1273:9,

1283:2,1283:13, CONFIDENTIAL [1]- 1323:39 Correct [5] - 1238:19, 1273:26,1276:7,

1284:35,1315:22, 1323:43 contemporaneous [1]- 1292:38, 1294:25, 1294:44, 1295:1, 1295:5

1315:27,1322:18, Confidential" [1]- 1263:19 1324:39, 1331:46 covered[3]-1245:31,

,19/1/09 (22) 7Transcripl produced by Merrill Legal Solulions

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TRAN.022.0136 R

8,19/1/09 (22)

1294:31,1294:32 1273:18, 1287:13, Dechaineaux [2]- departmental [1]- developing [2] - 1236:16,covering [2] -1342:20, 1287:16, 1295:29, 1265:38, 1266:4 1254:24 1237:19

1349:22 1295:36 decided [1] - 1278:13 departure [1] - 1308:25 development [1]-

cranium [2] -1340:13, damaged [2] - 1277:8, decision [8] - 1233:30, depicted [1] - 1289:9 1245:331341:4 1279:27 1257:15,1260:17, depicts [2] -1269:31, diagram [11] - 1244:9,

create [1] - 1283:33 dark[5]-1246:11, 1275:2,1281:37, 1270:24 1250:39,1257:42,created [1] - 1285:32 1246:15,1329:1, 1281:38,1281:46, deployed [1] - 1257:11 1258:11, 1258:34,credibility [4] - 1283:34, 1330:14,1330:35 1282:32 deployment [1] - 1236:30 1260:24, 1260:29,

1330:9,1336:17,1338:8 darken [3] - 1267:42, decision-making [2] - depth [1] - 1344:2 1262:23, 1269:46,

credible[1]-1328:10 1267:43, 1267:46 1257:15,1260:17 DeputY[I]-1257:8 1270:15,1344:35

CreW[19] -1256:29, darkened [1] - 1268:3 decisionS[1]-1267:19 derided [1] - 1275:42 DIAGRAM [1]-1250:41

1259:33,1259:47, darkness [4] - 1246:30, deck[9]-1260:20, derive[1]-1344:15 diary [1] - 1276:33

1266:32,1272:46, 1246:35,1247:25, 1282:8, 1291 :5, 1291 :7, derived [1] - 1241 :22 dictionary [1] -1278:32

1273:5,1279:15, 1267:36 1292:14,1305:22, descended [1] -1243:24 died [3] - 1273:25,

1279:29,1281:24, Darwin [1] - 1338:38 1306:2,1306:17, descending [1] - 1317:1 1340:26, 1341 :231282:6,1294:22, data [1] - 1239:38 1306:23 describe [4] - 1239:43, difference [9] -1243:34,1305:46,1328:9, date[13]-1311:12, decks [4] - 1286:36, 1243:2,1287:32, 1246:18, 1246:41,1328:15,1328:17, 1316:10,1317:25, 1287:5, 1287:22, 1294:21 1248:24, 1248:25,1329:41,1335:20, 1318:28,1318:38, 1288:46 described [6] - 1244:36, 1248:27,1248:28,1336:34 1322:21, 1322:26, declaration [1] - 1280:19 1245:36,1275:8, 1309:24, 1330:4

criminal [1] - 1294:22 1323:7,1323:34, declaring [1] - 1272:42 1275:47,1285:14, different [22] - 1234:24,

criterion [1] - 1243:13 1339:20, 1339:21, decoded [2] - 1337:39, 1286:38 1237:46,1240:14,cross [2] - 1276:30, 1339:22,1341:16 1338:11 describes [2] - 1242:37, 1243:41, 1253:23,

1343:37 dated [3] - 1264:10, deemed [1] -1323:4 1287:34 1254:20, 1258:22,

cross-currents [1]- 1264:43, 1265:26 deepest [1] - 1281 :36 describing [2] - 1280:37, 1260:40, 1260:41,

1343:37 DATED [4] - 1264:34, defamation [1] - 1330:24 1288:27 1286:6,1287:41,

cross-examination [1]- 1265:30,1266:10, Defence [5] - 1234:4, description [1] -1287:4 1289:21, 1289:23,

1276:30 1337:34 1234:14,1277:29, designate [1] - 1255:34 1300:26, 1311 :44,

crows [1] -1245:47 dates [1] -1324:46 1287:9, 1343:32 designated [1] - 1269:32 1313:10,1333:11,

cruiser [8] - 1264:26, David [4] - 1302:5, definite [1] - 1266:29 designed [1] - 1272:44 1333:12,1341:27,

1279:24,1279:37, 1302:24,1316:34, Definitely [3] - 1241 :12, desire [2] - 1272:2, 1341:28,1350:17

1281:32,1282:1, 1339:26 1249:29,1310:33 1284:38 difficult [19] -1246:27,

1298:40,1307:8, daylight [8] - 1233:36, definitely [3] - 1263:13, despatches [1] -1324:37 1249:24, 1249:35,

1307: 15 1251:10,1264:27, 1291:44,1310:33 desperately [1] - 1305:6 1251 :32, 1264:20,

cruiser's[1]-1298:39 1265:2, 1265:43, degree [5] - 1234:7, despite [1] -1274:321264:47,1265:1,

cryptograms [1] - 1273:3 1266:5, 1267:4, 1267:25 1234:10,1246:37, destroy [1] - 1356:451265:41, 1266:22,

CSIRO [1] -1344:13 days [10] - 1266:45, 1247:14,1247:15 destroyed [1] - 1308:321268:3, 1268:6,

culminating [2] - 1234: 19, 1279:47,1280:34, degrees [21] - 1240:29, detail [2]-1281:14,1268:10,1268:11,

1234:22 1289:27,1301:10, 1246:13,1246:23, 1293:291268:27,1268:30,

cumulus [1] - 1245:33 1308:25, 1309:6, 1247:2,1247:6, details [6] - 1245:4,1284:33, 1312:34,

cumulus-type [1]- 1312:13,1319:33, 1248:21,1248:47, 1251 :31, 1283:46,1330:32, 1331:6

1245:33 1338:25 1249:4, 1249:43, 1355:9,1355:16,difficulty [4] - 1260:31,

Cunningham [1] - 1285:4 daytime[1]-1237:12 1250:1,1250:11, 1355:401262:9, 1262:28,

cupboard [1] - 1276:34 dead[2]-1318:31,1342:9 1250:24, 1250:29, 1268:39detect [3] - 1245:21,

current [8] -1238:13, deal [3]-1287:47, 1250:30, 1257:31, 1268:7,1268:17dim [1] -1329:1

1240:47,1257:7, 1310:29,1331:5 1258:3, 1259:2, detected [1] - 1257:39Diploma [1] - 1237:43

1257:8,1316:47, dealing [2] - 1284:32, 1270:14,1299:35, detection [1] - 1257:39diplomatic [3] - 1308:30,

1343:43,1344:23, 1305:16 1304:15 determine [7] -1258:44,1308:40, 1309:7

1344:24 Dear[1]-1315:42 delayed [2] - 1328:44, 1265:21, 1268:1,direct[3]-1303:18,

Current [1] - 1343:38 debate [5] - 1271 :40, 1329:2 1268:13,1268:35,1309:4,1311:23

CURRENT[2] - 1344:29, 1273:38, 1273:39, deliberately [5] - 1273:16, 1319:6,1324:16directed [6] - 1256:34,

1344:30 1273:42,1276:1 1290:39,1306:19, determined [1] - 1267:241327:14,1329:17,

currents [6] -1339:17, decade[2]-1274:44, 1328:44, 1329:2 determining [2] - 1268:8,1330:42, 1336:31,

1343:37,1344:2, 1276:4 deliver[1] - 1309:8 1268:391356:44

1344:3,1344:43 decades [1] - 1275:5 delivered [1] - 1308:45 Detmers [11] - 1272:38,directing [1] -1255:19

cyclone [4] - 1241 :43, December[19]-1264:10, delivery [1] - 1255:21 1273:17,1299:32,direction [18] - 1233:20,

1242:6,1242:9,1244:12 1264:43, 1265:36, Delta[I]-1302:11 1299:38, 1305:23,1242:22, 1242:25,

cyclones [1] -1244:21 1272:31, 1276:21, delved [1] - 1278:30 1306:18,1308:31,1243:40, 1243:41,

1316:45,1317:8, demise[3]-1291:10, 1308:42, 1309:8,1243:44,1244:10,

D 1317:10,1317:16, 1302:28,1311:18 1329:391244:16,1247:7,

1317:38,1317:43, demonstrate [2]- Detmers' [2] - 1243:23,1248:16,1255:8,

1318:36,1324:38, 1307:47,1344:9 1272:421257:27,1260:25,

Daily[I]-1337:16 1338:41, 1338:42, denial [1] - 1277:22 detract [1] -1245:211264:25, 1265:6,

daily [1] -1278:31 1338:45, 1339:6, denying [1] - 1277:20 develop[3]-1236:11,1267:14,1269:47

DAILY[I]-1337:33 1351 :30, 1352:12 departed [2] -1319:13, 1237:15,1285:24directly[3]-1322:25,

damage [8] -1244:37, DECEMBER [1] - 1264:34 1356:41,1357:471338:41 Developing [1] -1237:211244:42,1272:44, deceptions [1] - 1289:45 Department [1] - 1275:40 directs [1] - 1257:4

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Dirk[2]-1274:12,1274:14 doctored [2] - 1351 :40, downwind [1] -1248:17 1303:41,1304:15, 1331:17,1355:21disadvantageous [1]- 1351:47 Dr[6]-1273:3,1315:23, 1304:41 emailed[1]-1322:15

1265:46 document [36] - 1239:2, 1324:17,1324:18, East [8] - 1235: 14, Embarked [1] - 1324:34

disappearance [1]- 1242:47,1243:20, 1324:20, 1324:28 1241 :42, 1242:6, embedded [1] - 1280: 191279: 14 1263:24, 1263:44, Draft [1] - 1263:24 1242:9, 1244:11, emerge[1]-1316:1

disappeared [1] -1279:37 1264:9,1264:37, draught [1] - 1244:42 1256:17,1319:13, emerges[1]-1289:41disavOW[3]-1291:1, 1265:11,1265:14, draW[6]-1242:17, 1324:24 emitting [1] - 1249:30

1291 :2, 1292:3 1265:20, 1265:26, 1247:45,1257:20, east-west[1]-1241:4 EML.002.0023 [1]-disbelief [2] -1272:23, 1265:34, 1265:35, 1273:38, 1311 :20, easterly[4]-1241:1, 1345:18

1272:24 1265:37,1266:2, 1311:29 1241:30,1241:34, EML.003.01 06 [1]-disbelieved [1] - 1284:2 1266:8,1283:15, drawing [2] -1248:15, 1243:45 1323:44discern [9] - 1251: 16, 1298:47,1299:6, 1252:35 eastern [2] - 1245:16, EML.003.01 07 [1]-

1260:47,1262:44, 1302:4, 1302:31, drawings [1] -1287:2 1245:29 1323:401268:28,1268:30, 1302:33,1303:13, DRAWINGS[I]-1261:13 easy [7] - 1250:26, empirical [1] - 1296:421268:42,1268:47, 1303:32, 1303:33, DRAWN [1]-1250:41 1259:30, 1260:22, employ [2] - 1342:35,1269:2,1269:3 1304:37,1304:39, drawn[1]-1311:23 1260:47,1261:4, 1347:47

discerning [2] -1262:28, 1307:45, 1320:41, dreW[3]-1252:14, 1267:37,1268:27 employed [2] - 1288:9,1268:21 1324:27,1337:27, 1252:38 Echelon [1] - 1324:29 1350:6

discharged [1] -1323:35 1345:19,1345:24, drift [1] - 1279:36 Economic [1] - 1235:39 employment [2]-

discount [1] - 1334:45 1349:46 drifted [1] - 1282:2 eddies[3]-1344:4, 1320:46,1321:9discovered [3] - 1277:30, DOCUMENT[7] -1239:13, drink[1]-1334:35 1344:9,1344:16 enables [1] - 1259:42

1310:15,1344:38 1239:17,1263:46, drive [1] - 1253:43 edge [2] - 1245:29 enclosing [1] -1323:21discreetly [1] - 1280:32 1263:47,1264:34, driver[1] - 1275:6 education [1] - 1346:4 encounter [2] - 1327:29,discuss [3] - 1338:28, 1265:30,1266:10 driving [3] - 1248:9, effect [12] - 1240:25, 1327:30

1339:27,1359:4 documents [8] - 1238:38, 1251 :14, 1254:9 1242:38, 1243:36, encountered [2] -

discussed [3] -1247:42, 1263:19,1265:22, dropping [1] - 1258:19 1243:37,1249:28, 1233:13,1304:471275:31,1275:33 1271:42,1272:17,

DSC [2] - 1265:27, 1249:31,1250:12, end[II]-1237:41,1250:6,discussing [1] - 1340:24 1308:44,1324:18,

1265:30 1251 :9, 1251 :22, 1251:31,1255:28,discussion [5] - 1271 :44, 1358:40 DSC" [1] - 1265:16 1260:19,1266:14, 1275:37,1276:3,

1275:35,1291:42, DOD [1] - 1265:36DSTO [1] - 1244:36 1295:21 1278:10,1278:19,

1304:36,1358:45 done[16]-1239:1,due [2] -1283:41,1316:47 effectively[1]-1241:1 1281 :22, 1325:45,

discussions [1] -1279:1 1239:5,1240:16,dunes [1] - 1346:43 effectS[10]-1233:10, 1350:12

Disembarked [1]-1242:23, 1250:25,

during [10] - 1236:29, 1233:11, 1233:29, end-on [1] - 1250:61324:36 1256:30,1267:12,

1236:43, 1255:6, 1233:34, 1245:24, ended [1] -1351:46disembarked [1]-

1287:3, 1299:22,1272:45, 1280:40, 1247:41,1257:14, ends [1] - 1326:33

1324:301300:15,1302:3,

1291 :8, 1291:10, 1260:16,1267:4, enemy [1] -1296:31disguise [2] -1272:37, 1306:19,1313:29,

1331 :42, 1332:5, 1268:21 Enemy [1] - 1263:251308:47

1317:9,1336:281334:32 efficiency [1] -1263:32 ENEMY[I]-1263:47

Disguised [1] -1263:25 Doohan [2] - 1273:23,During [1] -1256:10 effluxion [1] - 1271:46 energy [1] - 1243:38

DISGUISED [1] -1263:47 1273:25Dutch [1] - 1277:4 effort[4]-1272:6, engage [3] -1329:18,

disk [2] -1325:4,1325:16 Dorsetshire [1] - 1264: 1°duties [3] - 1238:5, 1275:45,1355:1 1330:42, 1336:32

dismantle [1] -1289:40DORSETSHIRE [1]-

1254:22, 1254:24 eighths [1] - 1245:30 engaged [2] - 1279:24,dismiss [1] - 1301:45

1264:35duty [4] - 1280:40, either [18] -1250:10, 1296:18

dispute [1] - 1295:25dot[2]-1240:13

1282:30, 1329:23, 1262:35,1270:14, engagement [8]-

disregard[3]-1311:5,dotted [1] - 1248:21

1334:32 1270:31, 1272:45, 1233:37,1237:3,1311:7,1311:43

doubt[6]-1281:10,DVD[4]-1315:3,1315:15, 1303:10,1305:3, 1244:35, 1276:39,

dissonance [1] - 1280:121299:17,1313:39,

1339:25, 1355:26 1307:23,1312:1, 1280:24,1301:18,distance [7] - 1245:22,

1329:14,1332:34,Dwayne [1] - 1274:11 1312:41,1332:34, 1307:44, 1336:33

1251:15,1258:3,1357:18 1334:43,1337:10, English[7]-1278:12,

1258:26,1264:22,doubtful [1] - 1319:25

E 1339:32, 1340:2, 1278:32,1279:2,1269:20,1270:24

down[25]-1241:38, 1347:10,1351:23, 1305:20, 1305:35,distances [2] -1236:17,

1241:45,1241:46, 1351:47 1305:37,1305:39

1264:471242:47,1246:28, Ean [3] - 1303:44, 1304:4, Either [1] - 1353:45 English-Japanese [1]-

distant [2] - 1245:41,1249:45, 1250:31, 1304:6 elaborate[1]-1277:16 1278:32

1249:351259:29, 1259:41, early [4] - 1242:33, Elder [2] -1276:47,1277:1 Enid[3]-1354:23,1355:3,

distinguish [2] - 1310:12,1259:45, 1260:5, 1244:26, 1255:26, elderly [1] - 1278:37 1355:16

1310:201260:10,1262:23, 1272:30 elements [6] - 1239:30, enlarged [1] - 1298:28

distress [2] - 1356:3,1262:45, 1263:22, earth [2] - 1241:16, 1241 :39, 1259:25, enlisted [1] - 1323:35

1356:71310:47,1316:30, 1281:11 1259:39, 1268:38, enormous[3]-1273:10,

disturbing [3] - 1313:31,1322:41, 1324:34, easier[4]-1241:7, 1319:24 1290:18,1343:361332:24, 1343:1, 1261 :46, 1262:43, elongated[1]-1241:6 ensure[1]-1334:191345:43,1345:44 1344:20,1350:7, 1268:42 elsewhere[1]-1274:35diver[1]-1274:11 1351 :27, 1354:25 ensuring [1] -1323:1

diverge [1] - 1312:38 easily[2]-1251:12, email [11] - 1315:39, enter [1] - 1290:16down" [1] - 1332:25 1251:18 1316:23, 1316:24,diverted [1] - 1312:29 entire[4]-1237:2,down-sea [5] - 1259:29, east[9]-1241:4,1242:18, 1316:30,1317:40,doctor[2]-1314:7, 1259:41, 1259:45, 1240:35,1278:6,1352: 10

1242:34, 1243:3, 1318:16,1318:39, 1289:421260:5,1260:10 1246:9, 1302:35, 1318:41,1322:7,

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entirely [5] -1305:3, 1251:7,1252:12, Exclusion [1] - 1235:39 1258:14,1351:4 factors [5] -1259:26,1308:41,1337:10, 1253:21, 1257:15, excused [3] - 1252:44, explanation [7] - 1283:31, 1259:36,1262:16,1338:29,1339:5 1257:17,1257:37, 1271:14,1359:13 1306:31,1340:16, 1262:22, 1262:32

entitled [2]-1237:29, 1258:2,1258:47, Executive [2] - 1236:2, 1340:26, 1340:30, facts [4] - 1311 :21,1277:46 1260:18,1261:19, 1253:31 1340:31, 1342:23 1330:36, 1353:7

ENTITLED [5] -1239:9, 1266:17,1267:5, exercise [2] - 1248:20, exploration [1] - 1310:33 factual [4] - 1284:10,1239:13,1239:17, 1267:33, 1267:36, 1278:47 exploring[1]-1301:32 1311:11,1311:35,1239:25,1283:17 1268:22,1269:16, exercises [2] - 1235:7, explosion [2] -1297:29, 1331:34

entitlement [1] -1235:12 1269:42, 1272:30, 1256:11 1298:43 Faculty[2]-1237:8,entries [1] - 1273:8 1273:27,1276:25, exhaust [1] -1262:13 exposed [2] - 1278:21, 1237:24

entrusted [1] - 1308:29 1284:34, 1295:20, exhibit [10] - 1242:44, 1319:24 faculty [3] - 1237:26,

entry[3]-1235:41, 1295:26,1296:12, 1261:11,1265:28, express[1]-1281:10 1255:18,1255:20

1320:46,1324:29 1296:26, 1297:32, 1271 :8, 1283:15, expressed [2] - 1281 :5, fade [1] -1267:13enveIOpe[14]-1321:14, 1299:14, 1301 :21, 1323:40, 1344:21, 1312:28 Fah [20] - 1297:2, 1297:11,

1321:31,1321:36, 1301 :40, 1302:3, 1344:26, 1344:40, extend [1] - 1239:33 1297:39,1298:14,1322:4,1322:18, 1304:21, 1304:36, 1358:31 extended [1] - 1245:45 1298:15,1298:38,1322:21,1322:25, 1305:13,1307:4, EXHIBIT[20]-1238:34, extendS[1]-1241:46 1299:36, 1299:40,

1322:38,1323:1, 1307:38, 1308:39, 1239:9,1239:13, extent [2] - 1272:44, 1300:4,1300:7,

1340:34,1341:12, 1309:10,1309:32, 1239:17,1239:25, 1273:17 1300:16,1300:18,1341:27,1341:28, 1311:23,1312:45, 1250:41,1261:13, extracts[1]-1278:5 1300:28,1305:18,

1350:31 1312:47,1313:34, 1263:46, 1264:34, extraordinary [1]- 1305:19,1305:34,

environment [3] - 1314:23,1315:34, 1265:30,1266:10, 1271:40 1306:39, 1306:43,

1236:21,1237:39, 1317:33,1318:46, 1271:10,1283:17, extrapolate [1] - 1239:34 1307:4, 1307:32

1256:43 1320:13,1329:4, 1284:27,1323:43, extreme [1] - 1242:8 Fah's [2] - 1298:32,

environmental [3]- 1330:46,1342:17, 1327:3,1327:7, extremely [3] - 1245:14, 1307:381253:35,1256:21, 1343:29, 1343:31, 1337:33, 1344:28, 1264:20, 1339:37 failing [1] -1308:33

1257:25 1343:41,1345:7, 1358:33 eye[3]-1236:16,1237:20, lair [2] - 1242:30, 1309:29equation [1] - 1240:9 1349:46, 1350:38, exhumed [1] - 1325:32 1237:21 fairly [3] - 1243:13,equations [2] - 1240:44 1350:43, 1350:45, existence [3] - 1307:43, eyes [2] - 1268:38, 1291:21,1310:3

era[1]-1277:35 1353:30, 1353:41, 1308:18,1327:37 1299:37 faith [1] - 1351:1

eradicating [1] -1274:8 1353:43, 1354:2, expect[4]-1241:19, eyewitness [2] - 1305:17, fake [2] - 1349: 19,

Eric[3]-1332:43, 1354:10,1355:7, 1241:23,1244:31, 1306:23 1349:201332:47,1333:2

1356:33, 1358:45, 1248:43 lall [1] - 1250:31

error[2]-1241:3,1318:411359:4, 1359:5, 1359:6 expectation [1] - 1245:15 F laIl5[1]-1322:21

evolution[1]-1267:17errors [2] -1240:28, expected [4] - 1240:20, False[1]-1351:21

1241:5evolutions [2] - 1267: 17, 1241 :32, 1244:23, false [16] -1274:44,

escapes[1]-1305:11267:20 1288:47 fabrication [2] - 1272:44, 1351:20,1351:23,

escort [1] -1329:23EXAC [1] - 1253:31 expecting [2] - 1251 :45, 1276:13 1351:24,1351:25,

especially [1] -1264:23exact[2]-1250:25, 1260:45 facing [1] - 1262:42 1351 :34, 1352:5,

establish [3] -1267:7,1335:30 expensive [1] - 1277: 15 lacl[46]-1241:1,1245:19, 1352:14,1352:22,

1272:2,1311:22Exactly [2] - 1300:1, experience [19] - 1233:29, 1245:28, 1248:28, 1352:23, 1352:26,

established [5] - 1247:33,1358:6 1248:8,1248:15, 1250:13,1252:13, 1352:32, 1352:39,

1264:19,1311:21,exactly[5]-1237:4, 1254:18,1254:31, 1255:33, 1263:33, 1353:9,1353:10,

1318:2,1353:71331 :3, 1339:33, 1254:32, 1255:3, 1266:47,1273:43, 1353:24

establishment [1]-1349:25,1350:15 1255:5,1255:16, 1285:29, 1285:36, falsity [2] - 1353:27,

1234:3exaggeration [1]- 1255:43,1256:13, 1293:10,1301:14, 1353:30

establishments [1]-1290:31 1256:14,1256:20, 1301 :42, 1302:13, familiar [1] - 1321:4

1234: 17examination [2] - 1233:38, 1259:4, 1265:8, 1302:33,1307:18, famous[1]-1335:16

estimate [2] -1261 :39,1276:30 1268:42, 1279:3, 1307:23, 1308:8, fan [1] - 1297:16

1270: 12EXAMINATION [5]- 1304:22 1309:5,1309:10, Fantasy [1] - 1273:34

estimated [1]-1269:191233:44, 1251 :5, experienced [5] - 1233:26, 1309:31,1310:7, lar [21] - 1236:18, 1243:17,

el [2] -1258:30,1268:361253:7,1269:12, 1251 :42, 1259:13, 1310:13,1311:40, 1270:18,1270:24,

Eurylochus [1] -1305:211284:44 1260:45, 1261:2 1312:12,1325:34, 1272:14,1282:26,

evaluation [1] -1273:46examine [1] - 1238:38 experiencing [1]- 1325:46, 1326:43, 1283:35, 1301 :5,

Evans [1] - 1276:41examined [6] - 1233:17, 1246:39 1330:1, 1333:5, 1301:8,1306:41,

evening [1] -1243:241277:26, 1277:33, expert [10] - 1286:38, 1335:37,1343:24, 1307:39, 1312:3,1313:46,1323:2, 1289:9, 1289:20, 1343:28, 1343:36, 1316:35,1316:42,event [4] -1242:7,1264:4,1332:35 1289:21, 1289:22, 1343:42, 1344:4, 1319:6,1321:39,1281:34,1344:19 example [4] - 1251 :27, 1289:29, 1295:20, 1353:38, 1353:45, 1325:2,1328:17,events [2] -1280:45, 1267:39, 1274:29, 1295:26, 1343:41 1354:27,1357:7, 1335:12,1336:17,1339:28 1277:42 experts [2] - 1233:7, 1357:14,1357:15, 1356:18eventual [1] -1285:41 examples[1]-1274:41 1289:26 1358:14,1358:26

everywhere [1] - 1287:26 fascinate [1] - 1286:36excavated[1]-1274:18 explain [7] - 1239:44, Fact [2] -1273:34,

evidence [80] -1233:7, fast [1] - 1240:39exceptional [1] - 1265:3 1243:4, 1243:34, 1285:30

1233:19,1242:32, faster [2] - 1258:17,excess [1] - 1272:9 1250:14,1279:4, factor [5] - 1260:37, 1266:271244:25,1245:9,exchange [1] - 1272:45 1284:20, 1348:11 1263:13,1267:13,

1246:34,1246:47, fate[3]-1283:47,excited [1] - 1332:24 explained[3]-1257:18, 1267:18,1274:46

1326:45, 1330:361247:31,1247:45,

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father[4]-1347:26, finished [1] - 1255:26 1252:4,1252:16, 1243:27 fresh [3] - 1259:32,1347:28,1354:15, fire [10] -1272:24, 1252:19,1252:28, FOrCe[3]-1234:4, 1291:5, 1281 :2, 1359:6

1354:42 1272:37,1272:46, 1252:40, 1260:23, 1291 :6 friction [1] - 1240:25fatigue [1] - 1259:47 1277:7,1277:35, 1260:26,1260:27, forcing [1] - 1250:15 friend [3] - 1279:6,fatigued [1] -1259:33 1282:20,1297:12, 1260:29, 1260:31, forecast [3] - 1237:29, 1279:11,1283:4lault[I]-1328:23 1298:35, 1300:4, 1260:34, 1260:36, 1241 :35, 1242:29 friends [1] - 1278:47favourable [1] -1245:17 1307:27 1260:40, 1260:43, forecasting [1] - 1238:18 frigate [2] - 1235:6,fearful [1] -1329:40 fired[24]-1272:41, 1260:44, 1260:46, forecasts [4] - 1237:37, 1235:14

feature [3] -1241 :47, 1277:10,1281:47, 1260:47,1261:21, 1238:8,1238:19, FROM [3] - 1263:46,

1242:9,1273:42 1292:36,1292:37, 1261 :44, 1261 :46, 1245:43 1337:33,1344:28

features [5] - 1245:4, 1293:1, 1293:36, 1262:1,1262:4,1262:7, Foreign [1] -1275:40 front [4] - 1251 :30,1251:28,1261:6,1269:2 1294:18,1296:5, 1262:18,1262:19, forensic [2] - 1341: 18, 1274:35, 1276:38,

February [4] -1339:6, 1296:6,1296:13, 1262:26, 1262:28, 1342:17 1298:321344:23,1344:24, 1296:15,1296:24, 1262:34, 1263:2, forensically [1] - 1345:44 front-page [1] -1274:351344:25 1296:25,1297:7, 1263:4, 1263:8, forensics [1] - 1346:5 frustration [1] - 1263:38

FEBRUARY [3] -1344:29, 1297:33, 1297:46, 1263:11,1263:12, forgery [1] -1276:29 fuel[1]-1291:71344:30,1344:31 1298:38, 1299:32, 1263:14,1264:47, forget [1] - 1349:25 lull [11] - 1237:35, 1247:2,

Federal [1] - 1295:8 1299:46, 1306:44, 1265:4, 1268:22 forgiven [1] - 1342:16 1247:23, 1254:8,lell [2] -1275:34,1275:46 1307:7,1307:14, flashing [5] - 1251:10, lorm[5]-1248:3,1306:15, 1256:13,1260:33,fellow[2] - 1349:24, 1307:19 1251:16,1251:17, 1306:28,1321:10, 1280:2, 1284:46,

1350:2 firing [4] -1297:16, 1265:2, 1268:23 1336:17 1331 :34, 1350:46,

lelt[3]-1263:35,1335:46, 1297:43, 1299:39, Ilat [1] - 1262:41 formal [2] -1253:38, 1355:16

1336:3 1305:17 flat-screen [1] -1262:41 1253:41 lully [3] -1249:14,

fertile [1] -1271:47 first [32] - 1233:1, flaws [1] -1240:27 formation [1] - 1344:45 1325:46, 1358:39

few[12] -1240:29, 1233:15,1242:2, Fleet [6] - 1233:26, formed[3]-1272:16, function [1] -1236:29

1240:30,1247:4, 1244:30,1247:42, 1255:39, 1256:5, 1288:44, 1334:38 functions [1] - 1278:22

1247:12,1261:47, 1253:13,1254:6, 1256:14,1257:4, former[2]-1291:4, fundamentals [1]-1305:2,1306:1,1306:5, 1257:39, 1263:21, 1257:10 1323:12 1236:381312:13,1330:34, 1273:12,1273:13, fleet [9] -1233:28,1235:8, formerly [2] - 1276:41, funnel [10] - 1249:27,1334:31,1340:12 1273:15,1273:18, 1238:7,1254:9, 1330:31 1251:30,1261:17,

fiction [4] - 1283:30, 1277:1,1279:17, 1254:19,1255:33, forward [26] - 1259:8, 1261:23,1261:44,1284:8,1284:23, 1279:43, 1283:44, 1256:3,1256:7,1256:23 1261:22,1261:44, 1262:3, 1262:11,

1285:29 1284:38, 1291 :8, flew[1] -1252:22 1262:2, 1262:40, 1262:16,1263:12,fictional [1] - 1284:16 1291 :46, 1292:18, floating[4]-1343:39, 1271 :32, 1271 :36, 1268:35

lield [1] - 1239:34 1292:21, 1298:19, 1351:16,1351:31, 1271:41,1274:1, funnel"[1]-1251:29

fields [1] - 1239:38 1298:42, 1299:30, 1352:29 1275:47,1276:4, funnels [1] - 1249:29

fierce [1] - 1279:261299:33, 1320:44, FLOATS [1] - 1239:26 1276:31,1278:1, fuss [1] - 1259:46

lifty [2] -1278:19,1282:341328:19,1340:44, flooring [1] - 1287:22 1290:41, 1292:36,

fifty-four [1] - 1282:341344:38,1348:14, Ilow[2] - 1242:2, 1329:21 1293:21, 1296:12, G

fighting [1] - 1255:81354:23 fluids [1] -1240:45 1297:31,1298:41,

file[19]-1313:41,First [3] - 1238:22, fly [2] -1252:19,1252:29 1303:34, 1304:28,

1313:43,1313:46,1238:36, 1243:34 flying[7]-1248:17, 1305:9, 1306:6, gain [4] - 1253:40,

1314:5,1314:16,firstly [6] - 1243:5, 1248:30, 1249:8, 1349:47,1354:43, 1254:17,1272:7,1298:3

1321: 14, 1322: 12,1244:47,1253:25, 1249:41, 1259:9, 1355:21 gained [4] -1237:46,

1322:45,1323:13,1261 :8, 1274:42, 1324:9 1262:27 forwarded[1]-1316:16 1254:5,1254:16,

1324:5,1324:8,Firstly [2] - 1249:42, focus [2] - 1256:39, Four [1] - 1303:2 1339:46

1324: 10, 1324: 16,1256:41 1256:40 four [4] - 1234:18, gaps [3] - 1350:14,

1324:25,1324:28,litted[3]-1266:4, follow[3]-1267:17, 1263:18,1263:34, 1350:27,1350:36

1326:12,1350:27,1291:14,1291:16 1267:21, 1300:31 1282:34 Gardens [1] - 1334:34

1350:31fiVe[2]-1236:31,1236:47 followed [5] - 1233:3, foyer[1]-1278:38 gauge [1] - 1251 :28

files [2] -1323:27, Ilag [17] - 1248: 16, 1274:38, 1275:31, Frame [1] - 1275:36 Gawler [1] - 1254:7

1350: 141249:28,1250:7, 1298:43, 1350:36 frankly [1] - 1309:42 General [1] - 1324:42

filling [1] -1275:11250:45, 1251 :45, FOLLOWING [1]- fraud [1] -1277:16 general[13]-1241:37,

film [1] -1325:131251:47,1252:14, 1271:12 Fraud" [1] - 1273:34 1241 :40, 1247:35,

final[2]-1239:21,1252:22,1259:10, Following [3] - 1233:24, Fraudulent[1]-1271:41 1263:40, 1264:30,

1331:431260:42, 1260:45, 1255:24, 1255:45 fraudulent [4] - 1271 :42, 1275:34,1285:19,

finaIlY[1]-1280:381265:42, 1272:38, following [7] - 1240:9, 1274:47,1277:43 1289:23, 1298:33,

Finally [4] - 1251 :20,1277:3, 1277:4, 1277:5 1241:9,1252:13, freed [1] - 1252:28 1306:3,1333:14,

1257:6,1265:34,flags [55] - 1233:35, 1281:13,1317:47, freelance[1]-1285:19 1333:36,1334:1

1268:201234:35, 1248:30, 1325:37,1331:44 Fremantle [10] - 1236:25, Generally [1] - 1263:42

finders [1] - 1274:281249:8,1249:12, follows [2] - 1282:39, 1255:25, 1272:35, generally [8] - 1236:4,

findings [1] - 1243:201249:14,1249:16, 1313:23 1291:8,1291:11, 1241:2,1242:1,1249:22, 1249:35, 1243:12,1244:12,

fine [3] - 1257:44, 100t[2]-1351:32,1353:16 1295:14,1313:2,1249:40, 1249:45, FOR[2]-1239:14, 1338:42, 1338:44, 1247:7,1250:29,

1261:34,1330:11 1250:5,1250:14, 1265:30 1339:1 1251:13finer [3] - 1245:4, 1251 :28, 1250:15,1250:18,

1251:31 force [4] - 1242:36, frequent[1]-1243:13 generated [1] -1242:71250:23, 1251 :43,

finish[1]-1281:45 1242:37,1243:19, frequently [1] - 1264: 15 gentle [1] - 1243:5

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gentleman [5] - 1291 :3, 1339:29, 1339:30, H 1329:23 1290:23, 1303:4,

1304:38,1315:33, 1339:35 Heading [1] -1303:43 1303:22, 1309:35,

1333:31,1343:40 grail [2] - 1339:36 headlined [1] -1274:31 1333:6, 1336:3, 1337:3

genuine [2] - 1272:2, granddaughter [1]- hair [1] - 1242:24 headlines [1] - 1274:38 histories[2]-1275:16,

1277:40 1278:2 half[7] -1237:35, Headquarters [7]- 1275:18

George [2] -1316:17, grandfather [7] - 1280:27, 1250:30, 1270:32, 1238:6,1238:14, history [7] - 1272:20,

1321:22 1280:35, 1280:45, 1270:33, 1270:45, 1238:16,1255:39, 1282:23, 1310:3,

geostrophic [1] - 1241 :15 1281:14,1281:16, 1309:42, 1309:46 1255:40,1257:4, 1310:6,1310:7,1312:1,

Geraldton [6] - 1272:35, 1282:47,1283:3 HALF[3]-1282:41, 1257:10 1335:17

1274:16,1274:31, Grandfather[1]-1281:3 1283:8,1283:17 health [2] - 1280:36, History [4] - 1252:36,

1291:13,1338:40, grata [1] - 1316:35 Half[l] - 1277:46 1283:41 1269:30, 1269:36

1340:23 gratitude [1] - 1281:6 Hall[2]-1331:1,1356:8 heap[1]-1311:38 hit [20] - 1281 :33, 1292:29,

German [18] - 1252:12, grave[4]-1274:14, halliards [1] - 1252:39 hear [6] - 1233:6, 1233:15, 1292:44,1292:47,

1258:2,1267:34, 1274:17,1349:34, Halstead [10] - 1287:45, 1233:24,1276:17, 1293:1, 1293:30,

1273:44,1275:33, 1349:35 1287:47,1288:2, 1311:41,1311:43 1293:34, 1293:43,

1275:41, 1279:24, graves [2] - 1349:36, 1326:22, 1326:24, heard [11] - 1257:15, 1293:47,1295:21,

1279:28,1279:36, 1349:38 1327:10,1348:42, 1260:18,1276:16, 1296:2,1296:19,

1281:21,1281:23, great [11] - 1248:27, 1348:45, 1348:46, 1276:38, 1314:28, 1296:26,1297:47,

1287:2,1293:47, 1248:28, 1263:35, 1349:11 1321 :33, 1321 :35, 1298:40,1299:37,

1295: 13, 1295: 14, 1264:23,1277:19, halyard[1]-1252:14 1331:6,1331:29, 1300:16,1306:45,

1308:35,1316:9, 1281:20,1311:8, halyards [1] - 1262:4 1333:40, 1354:33 1307:28, 1307:30

1332:28 1312:43,1331:4, hand[11]-1241:11, hearing [1] - 1284:39 HMAS [38] -1232:18,

Germans [4] - 1306:5, 1331:5,1350:13 1250:30, 1269:34, heat [8] - 1242:8, 1249:30, 1234:17,1235:3,

1306:24,1306:25, greater [2] - 1258:25, 1269:39, 1280:1, 1249:31, 1249:32, 1235:5,1235:13,

1306:29 1260:30 1287:39, 1290:4, 1249:34,1262:12, 1235:17,1235:33,

Germany[2]-1281:41, green [12] - 1249:1, 1302:5, 1308:29, 1262:14,1262:17 1237:8,1254:7,1254:8,

1281:43 1249:39, 1249:42, 1316:40 heat-induced [1] - 1242:8 1254:33,1254:47,

Gill [3] -1269:35,1272:19, 1250:2, 1250:46, hand-to-hand [1]- heating [2] - 1240:25, 1255:16,1255:25,

1284:3 1259:2, 1260:21, 1308:29 1242:8 1255:46, 1256:2,

Given [4] -1259:17, 1260:25, 1270:9, Handed [1] - 1344:7 heavy [1] - 1278:33 1256:4, 1273:34,

1260:19,1267:36, 1270:11 handed [3] - 1303:35, height [5] - 1240:4, 1274:16,1274:32,

1268:23 Gregory [2] -1275:14, 1313:1,1313:11 1240:5, 1244:3, 1274:36, 1276:42,

given [15] - 1240:31, 1275:16 handle [1] -1237:16 1244:19,1250:21 1276:47,1283:13,

1251:7,1255:4, grips[1]-1284:31 handling [3] - 1234:36, held [1] - 1275:27 1285:25,1291:47,

1262:31,1266:21, ground[1]-1271:47 1234:37,1253:35 Held [1] - 1232:30 1302:29,1310:16,

1267:39,1268:24, grounds [1] - 1328:47 happy [2] - 1244:29, help [3] - 1278:21, 1311:18,1313:32,

1269:42,1273:44, group [10] - 1255:7, 1280:14 1281:42,1311:29 1325:21, 1330:35,

1304:37,1308:31, 1255:9,1257:12, Harbor [2] - 1282:16, helped [1] -1256:32 1334:29, 1335:41,

1309:7,1343:31, 1272:15,1272:18, 1301:10 helplessly [1] - 1282:21354:42, 1356:3,

1358:45,1359:4 1288:19,1334:37, hard [10] - 1260:28, Hence[1]-1350:2 1356:39

Gladstone [3] - 1255:25, 1334:38, 1349:37 1263:32,1266:47, HER[I]-1264:1hmm [18] - 1285:46,

1255:31,1255:46 Group [7] - 1233:25, 1267:41, 1268:34, Herald[1]-1284:131290:13,1290:25,

glare[1]-1251:14 1256:26,1256:27, 1268:38, 1301 :8, hero[1]-1291:51290:29, 1293:24,

God [1] - 1345:43 1256:36, 1257:9, 1330:40, 1330:44, herself[4]-1259:1,1294:9,1294:12,

godfather [1] - 1285:37 1272:16,1273:37 1331:4 1272:42, 1283:2,1294:23,1295:15,

good-faith [1] - 1351: 1 guaranteed [1] - 1263:34 Hard [1] - 1301 :5 1354:341295:23, 1296:20,

governing [1] - 1240:44 guess[7]-1241:22, harder [5] - 1251 :26, Hetty[2]-1331:1,1356:81296:27,1300:8,

government [1] -1256:34 1244:30,1265:19, 1262:44,1263:10, hide [2] - 1272:44,1304:1,1314:1,

Government [10] - 1257:4, 1316:44,1317:14, 1269:1, 1330:37 1273:171326:25,1339:7,

1294:32,1294:33, 1317:47,1318:35 hardly [3] - 1317:28, 1342:12high [6] - 1241 :43,

1294:35,1294:41, Guidance [1] - 1263:24 1327:21, 1327:24 1245:16,1245:29,HMS[2]-1264:10,

1294:42,1295:8, guide [1] - 1286:35 Hartog [2] - 1274:12, 1264:351245:31, 1249:33,

1342:35,1344:12, Gulf[I]-1235:15 1274:14 1256:32hoist [8] - 1248:17,

1347:46 gun[3]-1282:8,1291:14, hazard [1] - 1266:47 higher [5] - 1235:26,1251:45,1251:47,

Governments [1]- 1291:16 haze[7]-1249:31, 1245:20, 1245:23,1252:14,1260:45,

1273:29 gunfire[1]-1281:31 1249:32, 1249:34, 1245:44, 1252:301262:32, 1265:42,

GPS [10] -1346:10, gunnery[10]-1233:27, 1262:12,1262:17, 1277:5highlight [1] - 1249:7 hoisted [3] - 1260:46,1346:12,1347:6, 1253:18,1254:22, 1263:12,1268:37 highlights [1] - 1239:32

1347:8,1347:11, 1254:24, 1254:40, head [6] - 1249:1, highly [2] - 1279:43,1261:21,1277:4

1347:12,1348:10, 1255:1,1255:18, 1249:44,1270:12, 1301 :9hoisting [1] - 1261 :43

1348:16,1348:23 1255:19,1256:38, 1277:32, 1277:33, Highway [1] - 1285:4hoists [2] - 1249:28,

Grace[6]-1314:41, 1299:30 1290:37 1261:21himself[1] -1308:43

1320:37,1320:39, Gunnery [1] - 1254:45 heading [10] - 1268:37, hippopotamus [2] -hold [3] - 1327:13,

1325:47,1355:38 guns [4] - 1236:20, 1269:47,1302:18, 1314:25,1314:281350:32, 1350:33

gradually [1] -1344:17 1282:8, 1282:9, 1299:34 1302:34, 1302:35, historian [1] -1336:2holder [1] - 1321 :21

graduated [1]-1234:14 gurus[1]-1301:11 1303:6,1303:14, historical [10] - 1274:33,holding [1] - 1242:24

Grail [4] - 1339:28, 1303:40, 1303:41,1290:10,1290:17,

holes [1] - 1274:13

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Hollywood [2] -1315:45, identical [1] - 1237:47 inclination [1] - 1250:21 1355:4,1356:14, 1345:19,1345:22

1324:3 identification [7]- include [1] - 1276:15 1357:1,1357:12 intended [2] - 1328:9,

Holy [4] - 1339:28, 1234:25,1267:12, included [1] - 1244:26 Information [1] - 1286:5 1328:161339:29,1339:30, 1267:16,1267:20, Included [1] - 1272:33 informed [6] - 1284: 15, intending[1]-1259:151339:35 1267:23, 1267:28, includes [1] - 1236:12 1321 :24, 1321 :30, intense [1] -1337:3

home [3] - 1283:39, 1306:15 including [3] - 1233:29, 1322:25,1332:27, intensify [1] - 1273:381326: 12, 1355: 18 identified [2] - 1240:40, 1247:9,1343:37 1355:30 intensive [4] - 1290:10,

Han [1] - 1232:25 1264:25 inconvenient [1]- initial [3]-1233:8, 1290:17,1290:22,

honed [1] - 1255:6 identify[5]-1241:19, 1359:21 1233:34,1257:36 1344:3hoped [1] - 1273:36 1245:6, 1265:44, increase [3] - 1262:8, initiating [1] - 1303:15 intention [1] - 1284:9hoping [1] - 1324:13 1267:27,1267:29 1262:36 injured [1] - 1272:43 intentS[2]-1319:6,horizon [11] -1236:19, identifying [2] - 1234:34, increased [1] - 1243:25 inland [2] - 1241 :44, 1330:11

1245:7,1246:13, 1245:4 increasingly [1] - 1273:39 1349:26 interact [1] - 1242:1

1246:24,1246:26, identity [3] - 1264:18, Indeed [1] -1283:31 innocent [1] - 1274:47 interacted [1] - 1311 :151250:21,1250:24, 1267:7,1283:2 indeed [6] -1267:34, innuendo [1] - 1272:5 interaction [2] - 1233:9,1250:28,1250:31, II [4]-1232:18,1252:4, 1274:4, 1274:8, inordinate [1] - 1274:42 1256:411251:8,1251:15 1263:19,1323:3 1313:44,1325:33, inq[1]-1316:43 interacts [1] - 1256:43

Horsefield [1] -1316:39 IJNI-124[1]-1273:6 1353:45 inquire [1] - 1265:13 intercept [3] - 1312:39,horses [3] - 1243:13, iIIegal[2]-1235:41, independently [1]- inquiries [3] - 1275:11, 1327:14,1329:45

1243: 14, 1243: 15 1342:15 1264:15 1275:27,1322:3 interest [8] - 1274:28,Horsfield [10]-1315:4, illuminated [2] - 1247:38, India" [1] - 1324:36 Inquiry[25]-1233:18, 1279:18,1285:24,

1315:7,1315:16, 1250:7 Indian [7] - 1241 :42, 1238:23, 1242:33, 1285:28, 1285:33,1315:21,1315:33, illuminating [1] - 1268:45 1242:6, 1242:9, 1271:31,1272:15, 1285:39,1287:42,1318:30,1320:33, illumination [3] - 1246:31, 1244:11,1302:12, 1272:18,1272:30, 1334:301325:6,1325:8,1325:12 1247:21,1247:25 1329:24,1329:31 1275:39, 1276:26, interested [3] -1283:47,

Horsfield's [2] - 1320:30, iIIustrate[1]-1242:16 indicate [4] - 1272:15, 1277:23, 1277:45, 1288:20, 1345:261325:11 image [3] - 1242:43, 1273:4, 1284:30, 1283:21, 1283:22, interesting [2] - 1305:45,

Hospital [3] -1315:46, 1261:11,1269:27 1297:11 1283:39, 1283:41, 1344:51324:4,1324:42 imagery[1]-1289:10 indicated [7] - 1249:4, 1287:9, 1295:21, international [1] - 1267:47

hostilities [2] -1279:21, imagine [3] - 1259:21, 1277:30, 1280:28, 1299:14,1302:4, internet[1]-1319:431279:45 1262:41,1323:12 1295:11,1297:1, 1322:46, 1323:2, internment[1]-1272:40

hour [2] - 1248:44, 1277: 1 immediately [2] - 1313:1, 1342:16,1354:15 1323:15,1337:19, interpret [3] - 1299:9,hours [6] - 1246:35, 1352:37 indicates [5] - 1280:26, 1355:16,1358:46 1299:21,1347:1

1247:4,1247:12, Immediately [1] - 1355:41 1280:43, 1284:2, INQUIRY[I]-1232:18 interrogation [4] - 1297:2,1335:44,1336:33, impact [6] - 1238:9, 1284:6,1308:18 inquiry [1] - 1290:40 1297:11, 1298:6,1338:41 1246:3,1251:17, indicating [6] - 1248:1, Inquiry's [1] - 1319:42 1298:14

house [2] -1276:34 1262:18,1267:9, 1249:44,1260:11, inquisitive [2] -1350:28, interrogators [1]-hove[1]-1277:5 1267:16 1302:9,1318:32, 1350:30 1272:38HSK [3] - 1357:33, 1358:7, impending [1] - 1233:21 1357:44 insatiable [1] - 1278:28 intervention [1] - 1308:8

1358: 19 Imperial [1] - 1282:23 Indicating) [1] - 1305:32 inside [1] - 1263:8 interview[11]-1315:6,hull[2]-1274:13,1293:11 implication [1] - 1248:16 indicating) [1] - 1249:10 insights [1] - 1335:30 1315:9,1315:18,human [1] - 1340:9 important [8] - 1274:41, indication [1] - 1276:27 insinuate [2] -1330:13, 1315:19,1320:37,humidity [1] -1240:3 1310:3,1311:2, indications [1] - 1236:18 1330:40 1325:5, 1325:11,hundred [1] - 1240:45 1315:47,1318:12, individual [3] -1255:9, insistence [1] - 1301 :11 1326:2, 1345:28,

hundreds[1]-1264:16 1339:37,1339:38, 1256:30, 1297:26 insisting [1] - 1275:11 1355:26Hundreds [1] -1275:7 1359:6 induced [1] - 1242:8 insofar [1] - 1292:2 interviewed [2] - 1321 :42,

hunting [1] - 1330:32 importantly[3]-1255:40, inexplicable [1] - 1279:33 inspection [1] - 1323:6 1339:25

hurry [1] -1312:43 1316:26,1318:40 infer[1]-1241:14 instance [1] - 1286:36 interviews [1] - 1320:31

hydrostatic [1] - 1240:6 impossibilities [1]- inference[1]-1311:22 instead [1] -1337:2 INTO[I]-1232:181331:34 inferences[1]-1311:20 Institute[1]-1288:17 intrigued [1] - 1284:1

I impossibility [1] - 1333:43 infirm [1] -1283:41 Institution [1] -1287:10 invade [1] - 1280:4impossible [10] - 1301 :12, inform [2] - 1322:2, instructed [1] - 1346:44 inversion [1] - 1245:32

1330:40, 1330:43, 1329:14 instructions [1] - 1315:10 investigate [1] -1259:12I-58 [7] -1294:7,1297:33, 1333:39, 1333:46, information [30]- instructor [2] - 1255:19 investigated [1] - 1275:21

1304:46,1304:47, 1333:47,1334:1, 1238:10,1244:36, instructors [1] -1255:17 investigation [3]-1305:3,1308:36,1309:9 1334:12,1336:22, 1257:25, 1275:11, intact [1] - 1288:47 1284:14,1301:46,

I-58's [1] - 1299:38 1336:23 1281:27,1286:5, integritY[1]-1334:19 1302:2idea[19]-1280:15, improbable [1] -1280:10 1291 :32, 1299:23, intelligence [6] - 1287:32, investigations [3]-

1289:4,1289:8, improve [1] - 1235:43 1308:44,1309:11, 1288:20, 1288:23, 1283:21, 1283:27,1289:19,1289:28, improved [1] - 1252:26 1309:37,1309:40, 1288:27,1289:13, 1283:371292:45,1303:9, IN [3]-1239:10,1283:18, 1313:37,1314:34, 1357:12 involved [32] - 1235:41,1303:12,1303:22, 1358:33 1316:6,1319:28, Intelligence [2] - 1288:13, 1275:9,1276:11,1304:26,1318:37, inability [1] - 1308:3 1319:32,1319:40, 1288:18 1276:15,1280:28,1333:38,1335:1, inaction [1] - 1275:1 1319:45,1320:5, intelligence-interested [1] 1292:7,1292:17,1335:3,1335:4,

incapable[1]-1297:15 1322:11,1322:17, - 1288:20 1294:33, 1294:35,1345:16,1348:24,

incident[2]-1279:47, 1322:20, 1322:22, intend [3] - 1342: 18, 1294:38, 1294:44,1349:41,1352:1

1335:38 1322:34, 1325:43, 1295:1, 1295:4,

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1297:40,1301:17,

1301:33,1302:28,1304:29,1304:31,1304:45,1305:3,

1305:10,1307:44,

1308:4,1308:14,1311:3,1314:4,1324:21,1324:45,

1349:44,1354:3,

1354: 15involvement [10]­

1273:19,1277:21,1280:9,1292:2,1299:9,

1301 :4, 1301 :42,1303:35,1304:27,

1308: 18involves [2] -1273:28,

1290:44iota[1] -1338:30Iraq [4] - 1235:19,

1236:25,1236:46,

1237:7Iraqi [3]-1235:20,

1236:33,1236:43

Iraqis [2] - 1236:40,

1236:47ish [1] -1257:45Island [5] -1256:17,

1274: 12, 1274: 14,1277:18,1277:21

Islands [2] - 1274:37,

1275:22isolated [1] - 1349:38issue [6] - 1238:21,

1251:24,1260:30,1268:20,1319:34,

1320:6issued [3] -1319:33,

1320:7,1320:14

iSSUeS[3]-1251:14,1255:38,1262:12

itching [1] - 1281 :42items [2] - 1275:7,

1359: 14itself [4] - 1251 :25,

1257:3,1260:11,

1329:34Ivan [1] -1299:15

J

JA[I]-1330:29

Jack[4]-1291:4,1291:38,

1292:8,1355:7

JAMES [3] - 1233:42,

1238:34,1253:5

JANUARY [1] - 1359:28

January [6] -1232:41,1234:1,1253:11,1271:30,1339:6,

1339:24Japan [5] - 1256:18,

1278:14,1279:20,1282:45,1327:44

Japan'S[1] -1282:15Japanese [53] - 1273:4,

1273:5,1273:19,

1277:2,1277:47,1278:2, 1278:32,1278:40, 1278:44,

1279:3, 1279:44,

1279:45, 1280:1,1280:2, 1280:9,1280:18,1280:28,

1280:33, 1282:23,1282:33, 1290:45,

1292:37,1293:1,1293:30, 1293:34,

1293:43,1294:7,1294:21, 1296:3,1296:7,1296:13,

1299:9,1299:47,

1300:21, 1300:27,1301:4,1301:17,1301 :42, 1302:10,

1302:27,1303:34,1304:44, 1305:9,1307:35, 1307:39,

1307:43,1308:19,

1311:16,1312:29,1312:33,1328:36,1328:39, 1337:38

JAPANESE [1] - 1283:18

JAS[I]-1265:17

Jebal [1]-1236:46

Jeffrey [4] - 1339:43,1340:9, 1354:29,

1354:31JeffreyS[3]-1341:44,

1342:1, 1342:5

jeopardised [1] - 1282:14jettisoned [1] - 1273:2JL[I]-1239:11

job [3] - 1278:12, 1284:33,

1332:5Joe [1] - 1347:16

JOE[I]-1239:15

John[21]-1273:23,1285:1,1315:23,1315:26,1315:39,1315:42,1316:15,

1316:23,1322:7,

1324:4,1324:12,1330:10,1336:17,1336:42, 1345:34,

1345:37, 1345:41,1346:10,1346:14,

1347:6JOHN [1] -1284:42

Johnson [5] - 1278:41,1280:23, 1283:5,

1283:7,1283:25

JohnSOn"[1]-1283:10join [4] -1233:46,1234:3,

1253:9, 1308:28

joined [4] - 1234:4,

1235:5,1235:13,

1343:43joining[2]-1235:17,

1240:13Joint [4] - 1238:6, 1238:8,

1238:14,1238:15

Jolly [12] - 1340:20,

1340:22, 1340:23,

1340:39,1341:10,1341 :23, 1342:9,1345:9,1345:12,

1347:16,1348:24,

1348:25Jolly's [2] -1342:9,

1346:42journalism [3] - 1285:19,

1285:21journalist [8] -1276:36,

1285:15,1285:16,

1288:8, 1330:23,

1336:2,1358:13,

1358:29journalistic [2] - 1285: 18,

1334:19journalists [1] - 1275:9journey [1] - 1259:30judge [1] - 1359:6July [2] - 1256:5, 1322:7

jump[2]-1292:15,

1300:19June [4] - 1305:29,

1321 :9, 1324:37,

1337:20Junior [1] - 1237:9junior [5] -1234:16,

1235:30, 1235:44,1236:6,1236:10

JWAC[I]-1253:32

K

Kalbarri [1] -1276:43Kantara[1]-1324:30Karlov[6]-1233:4,

1316:17,1321:22,1321 :25, 1322:2,

1348:38keen[1]-1318:44keep[6]-1234:45,

1236:5, 1237:22,

1253:44,1269:27,

1330:34keeper[2]-1236:1,

1236:3Keeping [7] -1234:20,

1234:23,1234:27,

1234:42, 1253:20,

1253:41, 1254:8

keeping [8] - 1234:37,1235:11,1237:17,

1248:42,1249:17,1254:32,1342:17,

1349:28kelp[I]-1274:11

Kendle [2] - 1355:7,

1355:8Kennedy [5] - 1302:5,

1302:24, 1302:26,

1316:35,1339:26

kept [2] -1323:26,

1330:14kernel[1]-1311:39

Kerr[21]-1232:35,

1321:41, 1339:42,

1340:27, 1341 :24,1341:38,1342:16,1345:6, 1345:28,

1345:31, 1345:36,

1345:40, 1346:8,1346:12,1346:17,1346:41, 1347:4,

1348:10,1348:17,1349:42, 1354:25

Kerr's [2] - 1348: 13,1348:14

key[7]-1234:37,1236:11,

1238:41, 1239:2,1239:30, 1239:32,

1253:45kilometre[1]-1240:8kilometres [3] - 1245:3,

1245:5, 1245:11

Kimberleys [1] - 1241 :45kind[1]-1240:13Kingdom [1] - 1273:28kit [1] - 1276:42

Kitsche [2] - 1276:29,

1276:32Knill [2]-1335:9,1335:11

knot[1]-1248:14knotS[29]-1240:30,

1241:30,1241:34,1242:28, 1242:29,

1242:30,1243:12,1243:19,1243:46,1247:47,1248:6,

1248:7,1248:10,1248:22, 1248:28,

1248:29, 1249:9,1257:24,1257:34,1257:36,1260:15,

1266:24, 1266:28,1266:43, 1266:46,

1267:1, 1328:32,

1328:34knowing [3] - 1267:26,

1345:42,1357:14

knowledge [2] - 1278:27,

1330:24known [12] - 1234:46,

1238:7,1239:38,

1240:39, 1241 :42,1246:24, 1253:40,

1291:3,1321:37,1322:37,1330:38,

1331:3knows [6] - 1282:28,

1339:42, 1345:43,

1347:21, 1347:23,

1356:16Kobe [1] - 1308:26

Kormoran [121] - 1242:33,1244:25, 1245:9,1245:10,1245:19,

1246:34,1246:47,

1247:1,1247:31,1247:43,1247:46,1248:2, 1248:5,

1248:14,1248:18,1248:47,1249:8,

TRAN.022.0142 R

1249:39,1250:10,

1251:11,1251:22,1257:24,1257:37,1257:40,1257:41,

1257:44,1258:5,

1258:10,1258:12,1258:18,1258:20,1258:47,1259:9,

1259:11, 1259:26,1259:27,1259:37,

1259:42, 1260:3,1260:12,1260:14,

1260:19,1260:22,1261:16,1261:20,1261:23,1261:27,

1261 :28, 1262:33,

1262:39,1266:17,1266:24, 1267:5,1267:6,1267:7,

1267:38, 1268:26,1268:27,1269:16,1269:33, 1269:42,

1270:25, 1272:22,

1272:23, 1272:34,1272:36, 1272:41,1272:45,1272:47,

1273:14,1273:15,1273:18,1273:24,

1276:32, 1276:39,1277:3,1277:4,1277:7,

1277:38, 1279:25,1293:22, 1293:30,1293:35, 1293:36,

1296:14,1296:24,1296:25,1297:12,

1297:43, 1297:46,1298:1, 1299:32,1299:41, 1300:4,

1300:24, 1305:21,1306:43,1307:7,

1307:10,1307:14,1307:27,1311:16,

1312:29,1312:39,1327:14,1327:25,1327:28, 1327:36,

1328:11,1328:31,

1329:18,1329:34,1329:37,1330:42,1335:20, 1356:45,

1357:33,1358:7,1358:14,1358:19

Kormoran'S[21]-1249:1,

1249:43,1250:12,1252:38,1258:12,

1258:21, 1260:22,1261:22,1261:29,1261:32,1261:34,

1266:18,1268:24,

1272:42,1277:10,1299:30, 1305:46,1328:8,1328:15,

1328:17Kramer[1]-1340:8

Kulmerland [2] - 1309:6,

1327:44Kulmerland's [1]­

1308:25

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TRAN.022.0143_R

Kyoto [1] - 1278:11 1259:18,1266:14, legends [1] - 1289:40 1319:26, 1319:28, log[4]-1271:7,1273:7,

1266:16 Len [2] -1238:46,1239:5 1319:37, 1319:38, 1339:9,1352:10

L laundryman [7] - 1292:35, length [3] - 1251 :26, 1325:25 LOG[I]-1271:10

1293:9,1297:3,1300:7, 1277:39, 1323:35 Iifebelts [5] - 1276:26, logbook [2] - 1351 :38,1300:10,1306:6, LeSS[1]-1322:31 1319:41,1320:6, 1351:45

lads [1] -1335:38 1306:16 less [8] - 1240:24, 1241 :6, 1320:14,1320:15 logbooks [1] - 1351 :44lady [1] - 1326:33 laundrymen [2] - 1292:30, 1250:19,1264:23, lifeboat [2] - 1306:24, logic [4] - 1292:25,lamp [3] - 1251 :10, 1295:13 1269:22, 1272:4, 1306:30 1299:43, 1300:21,

1251:17,1265:43 LaurenCe[9]-1313:25, 1322:23, 1322:30 lifeboats [3] - 1279:31, 1318:27lamps [3] - 1234:36, 1320:45,1321:17, letter [23] - 1276:46, 1282:7,1295:13 London [2] - 1337:16,

1265:2,1266:5 1322:12,1322:18, 1280:33, 1280:35, LIFEBOATS [1] - 1239:25 1356:4land [2] - 1282:46, 1323:3,1323:19, 1284:19, 1284:21, Iight[II]-1247:22, Long's [1] - 1275:2

1290: 10 1324:12,1325:20 1304:13,1317:4, 1247:32,1247:38, longevity [1] - 1281:5landed [1] -1306:25 laW[1] - 1312:1 1318:7,1323:18, 1251:16,1267:13, longitude [4] - 1246:6,Lane[14]-1312:7,1312:9, laWS[1]-1330:24 1337:15,1337:20, 1268:23,1324:14, 1246:17,1246:37,

1312:13,1331:2, lay[I]-1328:12 1337:31, 1342:20, 1354:28, 1354:32, 1246:381331:8,1331:41, Layton[1]-1356:2 1348:35,1349:10, 1356:20 look [34] - 1238:36,1333:31,1335:29, LCDR [19] - 1232:35, 1349:13,1354:4, lighthouse [4] - 1273:6, 1238:41,1241:13,1337:15,1337:20, 1303:44, 1304:4, 1354:6,1354:7,1354:9, 1338:39, 1338:40, 1241:18,1263:5,1337:37,1355:22, 1304:6, 1321:41, 1354:10,1354:39, 1351:15 1263:10,1268:32,1356:15,1356:30 1339:42, 1339:43, 1354:40 lights [7] - 1267:35, 1269:30, 1270:6,

LANE[I]-1337:33 1340:27,1341:44, LETTER [1] - 1337:33 1267:44, 1267:45, 1270:20,1287:5,Lane's [3] - 1336:5, 1342:1, 1342:5, Letters [1] -1276:10 1267:47,1268:2, 1289:4,1291:17,

1336:13,1336:47 1342:16,1345:6, letterS[2]-1276:12, 1268:8,1268:12 1293:18,1297:45,language [1] -1278:45 1345:28,1348:10, 1323:16 likelihood [1] - 1308:33 1303:5, 1303:23,large[4]-1240:19, 1348:13,1354:25, LEUT[28]-1232:36, Iikely[5]-1233:11, 1304:29, 1306:8,

1240:27,1245:6, 1354:29,1354:31 1233:15,1233:17, 1245:14,1251:46, 1306:11,1313:41,1256: 16 lead[1]-1301:16 1233:19,1233:40, 1318:47,1327:17, 1322:40, 1330:20,

largely[1]-1275:41 leader[1] - 1335:8 1233:46, 1238:34, 1343:38 1332:16,1332:42,larger [1] - 1254: 10 leadership [1] - 1253:26 1245:36, 1250:34, limit [4] - 1243:10, 1334:20,1337:27,largest[2]-1291:14, leading [3] - 1245:28, 1250:42, 1252:44, 1243:11,1243:14, 1340:19,1344:3,

1291:15 1247:4,1330:9 1252:46, 1253:21, 1243:19 1344:33,1345:18,Largs [5] -1312:38, leads[1]-1353:28 1257:16,1257:19, limited [1] -1279:3 1348:34, 1351 :5,

1312:43,1312:47, leaflets [1] - 1278:44 1276:47,1341:38, limped [1] -1274:2 1357:391313:3,1313:11 learn [4] - 1234:35, 1345:31, 1345:36, line [7] - 1249:45, looked [5] -1274:16,

last [29] - 1240: 16, 1234:36,1236:19 1345:40, 1346:8, 1257:28,1269:19, 1282:31, 1295:43,1272:31,1274:29, learned [2] - 1278:46, 1346:12,1346:17, 1272:19,1337:11, 1339:46,1350:121274:44,1275:5, 1334:29 1346:41,1347:4, 1347:33,1357:37 looking [26] - 1241 :3,1275:37,1276:47, learning[4]-1234:25, 1348:14,1348:17, lines [5] - 1248:21, 1241:4, 1246:29,1278:25,1281:15, 1236:14, 1236:21, 1349:42 1262:4, 1303:2, 1249:15,1249:45,1282:24,1286:28, 1237:36 LEVEL [2] -1344:28, 1316:31,1328:5 1250:4, 1250:5,1287:8,1288:7, least[6]-1248:44, 1344:29 Iink[1]-1265:19 1250:13,1250:19,1289:27,1298:19, 1252:12,1265:47, level [17] - 1232:30, list [2] - 1272:33, 1310:27 1251:13,1261:28,1309:16,1310:15, 1266:28, 1267:29, 1235:26, 1235:43, List [1] -1273:3 1261:47,1262:13,1311:3,1312:13,

1321 :9 1239:33, 1239:42, listed [1] - 1282:5 1262:23, 1262:24,1327:27,1332:17,

leave[4]-1278:14, 1240:5,1240:7, listen [1] - 1334:36 1268:37,1268:43,1335:23,1343:28, 1339:1,1351:18, 1240:12,1240:15, live [2] - 1237:3, 1272:5 1322:44,1324:16,1346:4,1351:4,

1352:37 1241:13,1241:18, Iived[1]-1282:13 1327:32, 1340:11,1351:27,1355:6, leaving[1]-1262:31 1241:31,1245:20, lives [1] - 1281:8 1340:24, 1348:23,1355:46,1357:43

Leaving [1] -1265:38 1255:42, 1344:22, living [3] - 1278:20, 1348:24, 1348:25,late [4] -1299:15,

led [5] - 1275:24, 1301 :32, 1344:23, 1349:33 1282:10,1282:26 1354:411326:39,1340:23,

1301 :46, 1303:16, levels [1] - 1256:32 local [2]-1274:2,1275:17 100kout[1]-1245:191355:6

1303:44, 1304:3 Library [1] - 1278:29 localised [1] - 1240:23 looks [3] - 1265:17,latitude [2] - 1246:6,

lee [12] - 1240:24, library [1] - 1278:38 locate[1]-1301:43 1269:45, 1270:221246: 16

1259:18,1259:19, lie[9]-1273:17,1290:40, located [12] - 1238: 15, lose[1]-1268:10latitudes [2] - 1246:17,

1259:24,1259:27, 1297:22,1300:17, 1245:19,1274:17, loss[15]-1271:36,1246:20 1259:43, 1259:44, 1306:47,1307:22, 1274:36, 1274:39, 1271 :39, 1272:3,

launch[13]-1259:11, 1260:4, 1260:9, 1319:7,1346:17, 1276:33, 1277:20, 1272:10,1272:20,1259: 14, 1259: 15,

1266:31, 1266:36, 1346:18 1277:26, 1277:31, 1273:16,1274:9,1259:21,1260:4,

1266:37 lied [2] - 1290:33, 1298:15 1277:32, 1277:44, 1275:3,1275:15,1260:8,1266:19, Leeuwin [1] - 1343:38 lies [1] - 1289:40 1304:30 1277:21, 1285:25,1266:23,1266:34,

left [9] - 1254:46, 1275:1, lieutenants [1] - 1236:31 locating [1] - 1273:13 1285:33, 1291 :39,1266:39,1266:42,

1294:11, 1296:34, life [9] - 1253:16, 1272:43, location [9] - 1273:41, 1292:17,1316:11266:47,1267:1

1305:2,1312:43, 1281:5,1281:6,1281:8, 1275:32,1275:45, LOSS[I]-1232:18launched [2] -1259:43,

1325:23, 1338:38, 1282:9,1285:10, 1342:38,1346:13, lost [1] -1247:341293:30

1345:31 1306:30, 1354:23 1347:10,1347:32, love[1]-1341:2launching [4] - 1233:35,

legally [1] - 1237:29 Iifebelt [6] -1276:25, 1348:3,1348:16 low[1] -1250:28

,19/1/09 (22) 15Transcripl produced by Merrill Legal Solulions

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TRAN.022.0144_R

lower [1] - 1349:33 1338:10 1327:11 Medical[1]-1313:26 meteorology [1] - 1237:45lowered [1] - 1293:22 manned [1] - 1282:8 Max [1] - 1340:8 medium [1] - 1244:27 METEOROLOGY [1]-

lowest [1] - 1243:6 manner [2] - 1234:34, maximum [3] - 1247:6, meet [1] - 1326:20 1239:15

lucky [2] -1256:14, 1254:13 1249:33, 1251:41 meeting [2] - 1308:39, method [7] - 1239:32,

1256:20 manoeuvre [1] -1236:41 May" [1] - 1324:36 1345:6 1239:36, 1241 :20,

lunch [5] -1300:34, manoeuvring [3] - McAndrew [6] - 1283:38, Melbourne [2] - 1237:31, 1290:11,1290:17,

1305: 16, 1305: 19, 1236:12,1248:3, 1283:39, 1283:46, 1276:37 1290:231307:42,1307:44 1249:33 1284:15,1284:20, member [5] - 1235:28, methodological [1]-

luncheon [1] - 1306:35 map [5] -1269:29, 1284:27 1283:20,1287:40, 1241:10

LUNCHEON [1] -1300:37 1269:31,1269:41, McArthur [7] - 1315:23, 1288:10,1288:17 methodology [1]-

lying [2] -1273:14, 1270:17,1270:24 1315:26,1315:39, members [3] - 1282:6, 1241:25

1334: 10 March [2] - 1291 :35, 1316:15,1317:4, 1287:41, 1336:34 methods[4]-1239:32,1310:15 1318:8,1318:32 memorabilia[1]-1276:44 1239:41, 1239:44,

M March/April [1] - 1317:47 McCluskey [1] - 1305:29 Memorial[1]-1277:15 1239:45

mariners [1] - 1243:2 McCormack [3] - 1239:6, memories[1]-1316:12 METOCEAN [1] -1239:26

Maritime[7]-1274:6, 1239:23, 1239:26 memory [7] - 1328:23, metre [3] - 1244:22,machine [1] - 1282:9 1274:18,1274:23, McDonald [5] - 1303:44, 1332:45,1333:10, 1244:39, 1244:40machinery [1] -1273:1 1274:24, 1275:29, 1304:4, 1304:6, 1337:17,1350:8, metres [7] - 1244: 1,magazine [1] - 1358:5 1277:45,1284:19 1304:17,1304:21 1354:40,1356:14 1244:3, 1244:41,MAGAZINE[I]-1358:33 mark [7] - 1242:44, McLaughlin [39]- men [5] -1272:47, 1244:43, 1245:45,magnetic[3]-1274:4, 1244:8, 1261:10, 1232:34, 1233:1, 1273:16,1306:1, 1257:35,1269:25

1274:8,1275:20 1271 :6, 1283:15, 1233:6, 1233:44, 1334:34,1339:31 Mets [1] - 1248:37magnitude [2] -1257:32, 1358:30,1358:31 1233:46, 1238:32, mentioned [12] - 1234:31, Michael [3] - 1272:28,

1273:27 marked[3]-1249:47, 1238:36, 1239:4, 1236:37, 1239:41, 1279:12,1285:35MAIL [1] -1337:33 1323:18,1344:20 1239:21, 1239:28, 1242:14,1250:12, Michiko [4] - 1278:9,Mail [1]-1337:16 Market [1] - 1232:30 1242:11, 1242:40, 1253:33,1273:13, 1282:44, 1283:6,main [4] - 1256:39, marking [1] - 1278:18 1242:46, 1243:33, 1279:17,1287:21, 1283:23

1256:40,1259:31, mass[4]-1278:22, 1244:46, 1246:3, 1299:17,1313:4,1358:7 mid [2] -1255:26,1272:151313:36 1349:34, 1349:35, 1248:35, 1249:26, Mentioned [1] - 1324:37 mid-1970s [1] - 1273:42

maintain [12] -1266:25, 1349:36 1250:4, 1250:33, mentioning [1] - 1281:7 Middle[3]-1235:14,1267:37,1267:38, massive [2] - 1273:26, 1250:38, 1252:44, merchant [8] - 1252:4, 1319:13,1324:241268:3,1292:4, 1276:7 1253:3,1253:7,1253:9, 1263:31, 1264:43, middle [5] - 1279:8,1292:40,1292:47, mast [1] - 1245:6 1258:8, 1261 :15, 1265:27,1266:4, 1302:13,1329:24,1310:37,1310:41, master [1] - 1352:36 1263:44, 1264:6, 1267:34, 1279:25, 1335:27,1349:251313:16,1321:13, master's [1] - 1351 :38 1264:37,1265:11, 1338:38 might [27] -1267:17,1339:9 mastheads [1] -1245:10 1265:19,1265:34, MERCHANT[I] -1265:31 1267:21, 1271 :34,

maintained [2] - 1277:22, masts [3] - 1249:27, 1266:8,1266:13, Merchant [1] - 1264:14 1278:4,1279:43,1292:29 1268:35,1333:13 1267:3, 1269:6, 1271 :3, mereIY[1]-1280:39 1289:4, 1289:8,

maintaining [1] - 1338:32 match [4] - 1239:38, 1271:14 message[4]-1333:17, 1289:28, 1302:5,maintenance [1] - 1235:27 1240:12,1268:9, mean[29]-1235:10, 1337:38, 1338:4, 1303:9,1303:12,MAJ [1] - 1272:40 1281:29 1239:33, 1239:42, 1338:11 1304:26, 1311 :30,MAJESTY'S[I]-1264:1 matching [3] - 1239:36, 1240:6, 1240:11, messages [4] - 1332: 19, 1319:42, 1320:36,major [12] - 1233:28, 1239:43 1240:15,1240:40, 1333:8,1333:14, 1324:14,1327:45,

1234:31,1234:32, material [13] - 1244:34, 1241:13,1241:18, 1333:25 1334:13,1337:24,1235:8,1254:9, 1272:3, 1277:43, 1241:31,1241:32, messenger [2] - 1333:40, 1337:25,1344:5,1254:19,1255:33, 1283:12,1283:24, 1242:35,1247:20, 1335:47 1344:13,1345:44,1256:3,1256:7, 1284:30, 1284:34, 1251 :33, 1270:13, MESSRS [1] - 1239:26 1353:17,1354:31,1256:23,1257:12, 1289:5, 1290:4, 1276:3, 1281 :25, met [4] - 1264:15, 1309:6, 1355:20, 1358:441275:6 1335:21, 1340:5,

1286:4, 1286:26,1332:21, 1335:38 Might [1] - 1265:13

majored[3]-1234:11, 1356:34, 1357:24 1286:47,1295:40,metallurgically [1]- mile[6]-1265:1,1265:42,

1278: 12 materials [2] - 1233:18, 1301 :39, 1304:6,1277:33 1270:32, 1270:45

Malakka[2]-1277:5, 1272:141308:4,1308:13,

metallurgists [1]- miles [23] - 1245:2,1308:47 mathematics [1] - 1234:12

1331 :21, 1339:35,1277:26 1245:7,1245:12,

male [1] -1313:27 matter [14] - 1240:8,1340:15,1340:17

metallurgy [1] - 1277:34 1245:41,1251:33,Maly[I]-1322:7 1251 :35, 1291 :31,

means [11] - 1236:20,metamorphosed [1]- 1258:3, 1260:28,

man [8] - 1292: 14, 1305:15,1306:34,1241:15,1243:4,

1273:22 1260:30,1263:7,1313:40,1313:44, 1309:5, 1309:30,

1247:21,1247:26,METEOROLOGICAL [1]- 1263:8, 1263:9,

1326:37,1330:33, 1311:17,1316:34,1249:42,1267:12,

1239:14 1263:15,1263:34,1334:43,1335:8, 1333:36, 1338:34,

1339:36, 1341 :2,meteorologist [3]- 1264:16, 1264:21,

1341:39 1345:3, 1351 :9, 1355:251350:45,1350:47

1233:16,1237:27, 1264:23, 1265:5,man's[1]-1282:23 matterS[11]-1291:29,

meant [4] - 1237:3,1257:16 1265:47,1266:6,

managed [1] - 1350:32 1311:6,1312:2,1237:10,1332:28,

meteorologists [1]- 1270:26, 1270:28,management [4]- 1312:18,1315:22,

1346:331238:1 1270:33

1253:27,1255:36, 1326:40, 1335:31,measure [1] - 1244:5

Meteorology [6]- military[2]-1237:38,1274:25,1323:21 1338:29,1343:14, measured [1] - 1244:4

1237:28,1237:31, 1291:4Manchester[4]-1331:11, 1355:43, 1358:36 medical [2]-1314:7,

1237:43,1237:46, Military [1] - 1235:201332:13,1337:39, Matthew[2] - 1288:5, 1321:10

1238:2, 1240:36 militia[3]-1349:32,

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1349:40,1350:37 1356:21 movements [5] - 1301 :12, 1331:27 never [17] - 1279:38,million [1] - 1320:26 momentarily [1] - 1340:11 1324:17,1327:45, nautical [12] - 1245:2, 1282:35,1284:7,

mind [14] -1259:36, momentum [1] - 1339:46 1338:37,1345:1 1245:7,1245:11, 1284:9,1288:10,

1261:23,1269:28, Monday[1]-1232:41 moves[1]-1241:45 1246:24, 1251 :33, 1289:14,1289:17,

1289:16,1306:33, Montgomery [12]- moving [1] - 1263: 1 1260:28, 1260:30, 1296:33, 1297:41,

1333:2,1333:37, 1272:28, 1272:39, MSLP [3] - 1240:33, 1263:7,1263:8,1263:9, 1304:31,1314:28,

1346:25,1348:23, 1273:26,1273:27, 1241:9,1241:10 1263:14,1263:15 1321:36,1321:45,

1349:28,1351:5, 1273:37,1274:1, mummification [1]- naV[1] - 1268:7 1324:18,1340:16,

1354:47,1355:20, 1276:31, 1279:13, 1316:46 Naval [8] - 1253:46, 1341 :46, 1342:5

1355:45 1284:4, 1285:35, museum[1]-1335:17 1277:45,1279:15, Nevertheless [4]-

mine [4] - 1336:5, 1285:36, 1301:44 Museum [7] -1274:6, 1280:1, 1280:2, 1281 :35, 1284:6,

1342:27,1344:36, Montgomery's [6]- 1274:18,1274:23, 1284:19,1287:10, 1284:18,1284:33

1347:37 1272:33, 1273:35, 1274:24, 1275:29, 1308:35 neverthelesS[1]-1297:19minimum [1] - 1259:46 1285:43, 1302:23, 1277:45,1284:19 naVal[1]-1281:20 neW[8] -1235:20,

Minister [3] - 1277:29, 1352:2, 1352:3 music [2] - 1334:36, Navier[1] - 1240:44 1236:32,1238:15,

1290:33,1290:39 months [11] - 1234:26, 1334:39 Navier-stokes [1]- 1246:31,1247:18,

Minor[1]-1256:25 1234:27,1235:6, must [23] - 1277:37, 1240:44 1247:20, 1247:24,

minOr[6]-1235:16, 1235:14,1235:19, 1279:3,1281:37, Navies [1] - 1243:2 1343:45

1235:23,1235:32, 1236:47,1237:34, 1283:1,1285:41, navigated [1] - 1304:13 New[2] - 1326:39, 1358:5

1254:5,1255:31, 1237:35,1278:14, 1286:24, 1291 :45, navigation [16] - 1235:16, Newcastle[1]-1235:13

1255:32 1286:28,1319:17 1292:16,1300:11, 1235:23, 1235:24, newly [1] -1254:16

minus [1] -1270:14 moon [11] - 1233:22, 1301 :30, 1317:20, 1236:3, 1253:34, news [1] -1274:35

minute [4] - 1264:42, 1246:4, 1246:31, 1319:3,1319:5, 1255:41, 1255:42, newspaper [4] - 1285:21,

1265:36,1269:43, 1246:33,1247:17, 1323:26, 1327:29, 1256:38, 1267:35, 1286:45, 1358:22,

1349:8 1247:18,1247:20, 1328:21, 1335:46, 1267:44, 1267:45, 1358:25minutes [7] - 1246:8, 1247:22,1247:23, 1336:3, 1336:11, 1267:46, 1268:2, Newspaper [1] - 1285:22

1246:16,1246:21, 1247:24,1247:38 1341:36,1348:19, 1268:12,1304:22 newspapers [1] - 1284:141246:29,1246:37, moonless [2] - 1267:8, 1354:39, 1359:3 Navigator [6] - 1235:26, next [24] - 1234: 15,1331:43,1346:35 1267:39 Myanmar [1] - 1304:41 1235:33,1235:37, 1240:33, 1246:23,

misconstrued [2]- moonlight [1] -1247:28 mysterious [1] -1279:14 1235:46, 1236:9, 1255:12,1255:13,1347:12,1348:12 morning [2] - 1233:2, 1236:24 1255:47,1256:1,

misconstruing [1]- 1276:17 N Navy [31] - 1233:2, 1256:24, 1256:25,

1346: 18 Morning [1] -1284:13 1233:16,1233:47, 1264:12,1264:37,

misleading [1] - 1277:43 mortally [1] -1282:1 1235:20, 1236:33, 1265:20, 1267:24,

Miss[1]-1320:37 Most[2]-1241:16, NAA,074.0064 [3]- 1237:34,1237:45, 1278:35,1279:40,

missing [1] - 1322:4 1245:42 1264:37,1265:28, 1238:1, 1246:25, 1281:13,1282:18,

mission [5] - 1256:41, most [20] - 1238:43, 1265:32 1255:39, 1273:29, 1289:22,1300:16,

1256:44,1257:2, 1243:2, 1263:32, NAA,074.0065 [2]- 1273:30, 1273:31, 1306:45, 1324:1,

1259:32,1308:28 1267:34, 1275:8, 1265:35, 1266:11 1274:6, 1276:6, 1334:25, 1339:2

mistake[12]-1313:13, 1278:28, 1285:42, NAA,092,0025 [1]- 1277:20, 1277:22, Next [1] - 1264:8

1317:5,1317:7, 1305:46,1311:2, 1324:27 1280:28, 1282:23, night [15] -1234:45,

1317:18,1317:21, 1312:5,1315:46, name [24] - 1253:23, 1290:33,1290:37, 1237:12,1247:21,

1317:25,1317:30, 1316:26,1316:40, 1265:17,1278:9, 1290:38, 1295:4, 1247:28, 1247:34,

1317:32,1317:34, 1318:11,1318:40, 1278:40, 1283:38, 1305:37, 1329:21, 1253:44, 1267:8,

1318:38,1334:44, 1329:44, 1339:38, 1284:47,1288:4, 1340:15,1352:19, 1267:35, 1267:36,

1348:24 1346:42,1357:13 1288:5, 1305:1, 1352:36,1357:8 1267:39,1268:13,

mistaken [1] - 1307:23 MOStly[1]-1321:22 1319:29,1319:34, NEAR [1] - 1239:14 1282:2, 1282:29,

mistakes [1] -1348:32 mother [5] - 1326:21, 1319:41,1320:8, near [5] - 1244:42, 1273:2, 1291:8,1291:11

mix [1] -1262:22 1326:34,1326:37, 1320:24, 1329:41, 1274:37,1302:12, night-time [1] - 1237:12

mixed [1] - 1332:40 1346:45, 1346:46 1340:10,1340:20, 1343:29 Nights [1] - 1247:32

Mmm-hmm [18] - 1285:46, motion [1] - 1240:45 1343:40,1347:16, nearly[1]-1282:34 nights [1] - 1247:37

1290:13,1290:25, motivated [1] - 1272:5 1354:22, 1354:23, necessarily[5]-1301:31, nil [1] - 1244:37

1290:29,1293:24, motive [2] - 1306:47,1354:24,1355:27, 1329:35,1333:37, nine [4] - 1235:6, 1237:34,

1307:221355:37 1349:20, 1349:37 1289:26, 1299:331294:9,1294:12,

1294:23,1295:15, motorboats [1] - 1272:47named [1] - 1335:9 necessary [2] - 1322:38, No-one [1] - 1290:41

1295:23,1296:20, mountain [2] - 1240:25,namely [1] - 1282:45 1345:27 Nobody[1]-1281:45

1296:27,1300:8, 1245:5names [1] - 1283:6 need[11]-1254:17, non [3] - 1289:29,

1304:1,1314:1, move [12] - 1238: 1,narrow [1] - 1259:3 1257:42,1258:17, 1316:35, 1334:35

1326:25,1339:7, 1238:21, 1241 :37, nation [1] - 1289:42 1264:39, 1269:33, non-alcoholic [1]-1342: 12 1242:11, 1243:33, national [2] - 1323:4, 1286:15,1316:5, 1334:35

moderate [3] -1243:6, 1244:46, 1246:3, 1323:9 1334:45,1352:10, non-expert [1] - 1289:291244:20,1244:23 1247:41,1252:16, native [2] -1278:20, 1355:4,1357:24 None [1] - 1356:35

moment [10] - 1246:33, 1257:14,1266:13, 1282:46 needed [3] - 1258:9, none [6] - 1288:25,1250:9,1257:19, 1267:3 nature [8] -1275:7, 1278:45, 1350:24 1307:40, 1330:1,1259: 12, 1261 :24, movement[4]-1236:15, 1275:31, 1277:42, neighbour [1] - 1355:30 1337:12,1353:51292:43,1305:2, 1236:39,1241:16, 1283:12,1285:18, nest [1] -1245:47 nonsense [7] - 1324:46,1339:33,1340:2, 1338:38 1301:21,1301:41, neutral [1] - 1272:37 1328:2, 1335:46,

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1336:4,1336:12, 1338:9, 1338:39, 1242:6, 1242:9, 1274:47,1285:36, 1250:301337:46,1343:12 1341:19,1356:1 1244:11,1280:41, 1291 :21, 1334:34 ones [2] - 1296:34,

normal [4] - 1235:42, NOVEMBER [3] - 1239:10, 1302:12,1329:24, oiling [1] -1269:24 1310:281253:14,1258:29, 1239:14,1239:18 1329:31 old [11] - 1240:46, ongoing [1] - 1286:171263:6 Nowhere [1] -1283:29 oceanography [1]- 1278:10,1309:11, onward [1] - 1298:36

normally [3] - 1255:4, nowhere [2] - 1302:12, 1238:8 1309:41,1315:45, opened [3] - 1272:37,1314:14,1314:19 1349:25 October[1]-1319:14 1319:17,1322:23, 1277:7,1284:35

north [12] - 1241:4, NT[I] - 1342:42 octres[1]-1245:30 1322:27,1322:28, opening [2] - 1298:35,1241:6,1246:8, NTBR [3] - 1342:41, OF[24]-1232:18, 1322:30,1322:31 1308:321247:11,1257:45, 1342:44, 1342:45 1238:34, 1239:9, Ombudsman [1] - 1326:39 operate [1] - 1253:461258:5,1276:43, NTPR [1] - 1342:41 1239:10,1239:15, ON [1] -1239:13 operations [11] - 1234:37,1304:15,1304:25, nUmber[9] - 1237:14, 1239:17,1264:1, Once [5] -1235:32, 1235:18,1235:36,1343:21,1343:37, 1275:27,1280:22, 1264:34, 1264:35, 1236:24, 1240:11, 1235:40, 1236:40,1349:26 1296:23,1311:44, 1265:31,1271:10, 1268:33,1329:1 1236:41,1237:4,

north-ish [1] -1257:45 1316:36,1333:11, 1282:41, 1283:8, once[8]-1241:17, 1255:38,1256:10,north-south [2] - 1241:4, 1333:21, 1351:44 1283:17,1283:18, 1247:32,1253:26, 1256:33,1257:3

1241:6 Number[1] -1322:19 1284:27,1327:3, 1259:1, 1280:32, Operations [4] - 1238:6,north-west [1] -1304:25 nursed [1] - 1282:34 1327:7,1344:28, 1296:30, 1312:21, 1238:9,1238:14,1255:4northerly [1] -1257:38 NX24732[1]-1322:19 1358:33 1355:12 operator [3] - 1260:45,northern [1]-1256:17 OFF[I]-1239:10 One [7] - 1244:34, 1261 :2, 1332:26Norwegian [2] -1272:37, 0 offer[1] - 1289:28 1253:45, 1259:26, opinion [8] - 1289:3,

1277:3 offered [3] - 1291 :32, 1274:46,1279:11, 1289:22, 1289:23,note[11]-1243:11, 1304:26, 1354:42 1281:39,1281:44 1289:29,1304:27,

1249:17,1252:34, o'clock [1] - 1300:35 offering [1] - 1289:3 one [87] - 1234:24, 1311:8,1311:29,1282:39,1298:13, oar[1]-1274:30 offhand [2] - 1328:25, 1236:31,1236:37, 1324:111314:46,1326:3, object [3] - 1245:6, 1328:29 1238:47,1239:32, opportunities [1]-1326:4,1326:7, 1302:44, 1304:42 office [2] - 1336:35, 1240:18,1243:40, 1301:381326:11,1355:23 obscure [1] - 1249:29 1338:10 1245:30, 1250:30, opportunity [5] - 1288:37,

notebook [1] - 1276:30 observation [6] - 1240:4, Officer [7] - 1236:2, 1251:1,1251:35, 1291:9,1312:16,noted [6] - 1312:22, 1288:46, 1298:4, 1237:10,1254:45, 1252:12,1254:22, 1315:17,1325:13

1312:23,1320:28, 1316:26,1318:17, 1255:3, 1255:4, 1255:17,1259:31, Opportunity [1] - 1301 :361356: 15, 1356: 16 1318:40 1255:17,1255:20 1265:1,1271:39, opposite [2] - 1264:25,

notes[9]-1297:2,1297:6, observations [8] - officer [36] - 1233: 16, 1272:38, 1277:43, 1356:471297:11,1298:6, 1239:34, 1246:25, 1233:27,1234:19, 1278:37,1280:38, opposition [1] - 1296:291319:42,1342:26, 1246:28, 1253:35, 1235:25, 1236:3, 1282:28, 1286:38, options [1] - 1262:461347:32,1347:35, 1275:19,1288:33, 1236:38,1241:12, 1290:41,1291:11, oral [1]-1275:161357:46 1288:44, 1295:42 1248:43, 1251 :42, 1291 :46, 1292:18, order [8] - 1258:25,

Nothing [3] -1274:19, observe[4]-1289:29, 1253:14,1253:16, 1292:21, 1292:30, 1260:3,1262:27,1308:20,1340:37 1295:36,1318:20, 1253:17,1253:25, 1292:44,1292:47, 1266:25,1268:10,

nothing [9] - 1300:27, 1320:47 1253:26, 1253:29, 1295:12,1295:13, 1282:12,1296:23,1305:11,1305:47, observer [1] - 1281 :35 1253:36, 1253:46, 1295:22, 1295:44, 1322:471307:38,1309:37, observers [1] - 1273:39 1254:4, 1254:5, 1296:2,1296:19, ordered [6] - 1282:30,1321:10,1342:17, obstructions[2]-1262:1, 1254:21, 1254:23, 1296:22, 1296:26, 1291:13,1291:17,1356:29,1358:12 1262:5 1254:24, 1254:30, 1297:28, 1300:26, 1313:27,1351:17,

nothing" [1] -1356:27 obtain [6] - 1275:45, 1254:33, 1254:35, 1301 :30, 1301 :33, 1352:36notice [2] -1295:29, 1289:8,1319:40, 1254:39, 1255:1, 1302:12,1302:17, orders [2] - 1308:35,

1295:35 1319:45,1340:8, 1255:7, 1255:21, 1302:37,1303:18, 1356:41Noting [1] - 1260:40 1355:11 1255:34, 1255:43, 1305:21, 1309:31, Organisation [1]-noting [5] -1258:30, obtained [6] - 1272:14, 1276:47,1313:29, 1311:20,1311:36,

1287:101266:23,1267:11, 1272:17,1275:17, 1324:3, 1330:11 1311:42,1312:30,

organisation [2] -1268:12,1268:28 1280:23, 1283:40, officer's [2] - 1255:35, 1312:35,1312:39,

1287:40,1288:1notion [5] -1292:25, 1323:15 1320:44 1313:10,1313:15,

organised [3] - 1237:10,1304:44,1312:28, Obviously [3] - 1247:22, officers [12] - 1233:2, 1313:31,1314:24,

1274:7,1275:301312:37,1353:28 1256:14,1262:2 1235:30, 1235:44, 1314:38,1314:43,

organising [1] -1234:39Nottle [1] - 1232:36 obviously [8] - 1247:11, 1236:7,1236:10, 1314:44,1318:47,

original [2] - 1331 :28,novel [1] -1246:14 1247:23,1248:2, 1241:17,1248:38, 1319:4,1319:5,1322:9,

1358:10November[26]-1233:22, 1258:16,1262:37, 1274:33, 1279:29, 1325:34, 1328:4,

originally [1] - 1288:351238:22,1241:40, 1262:42,1270:27, 1281:25,1352:11, 1328:18,1329:4,

originals [1] - 1340:431242:12,1246:4, 1317:11 1353:3 1330:33, 1332:20,

originated [1] - 1307:91246:5,1247:10, occasion [2] - 1278:37, Officers [3] -1253:31, 1334:10,1338:27,

Orion [1] -1274:161314:24 1263:35,1288:18 1338:30, 1339:44,

1247:17,1247:35, ostensibly [1] - 1276:461271:37,1272:35, occasionally [1] - 1274:47 offices [1] - 1239:47 1340:8,1340:14,

otherwise [1] -1273:381273:9,1275:19, occupation [2] - 1285:7, official [3] -1272:19, 1341 :3, 1343:45,

1285:10 1273:9,1275:1 1344:25, 1349:35, Otway [16] -1273:7,1279:19,1281:18,

1354:13,1355:25, 1273:12,1338:25,1294:32,1302:9, occur[1]-1327:45 Official [4] - 1252:36,

1338:37,1339:9,1304:30,1327:46, occurs[1]-1246:15 1269:29, 1269:36 1355:30, 1358:36

1343:12,1343:13,1330:30,1334:42, Ocean [8] - 1241 :42, often[5]-1264:16, one-and-a-half[1] -

1343:20, 1343:22,

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TRAN.022.0147 R

19.19/1/09 (22)

1351:9,1351:15, 1332:17, 1334:26, partnership [1] - 1281:40 perhaps [9] - 1259: 10, Philippines [3] - 1303:45,1351:31,1352:19, 1335:26, 1335:27, parts [2] - 1284: 1, 1305:45 1262:32, 1270:4, 1303:47,1304:181352:45,1353:21, 1347:33, 1349:7, party [1] -1277:9 1297:28,1302:10, phOne[3]-1341:39,1353:35 1351:12, 1351:27, pass[2]-1312:35, 1319:28,1331:20, 1342:33, 1347:43

Otway's[I]-1352:43 1351 :37, 1353:16, 1344:20 1341:20,1341:25 phOtO[6]-1261:8,OUght[I]-1264:17 1355:46,1356:37, passage [2] - 1298:17, PerhapS[6]-1287:31, 1261:18,1269:43,ourselves [1] - 1237:38 1357:5, 1357:43 1306:38 1288:39, 1320:25, 1270:8, 1270:25,

OUT [1] - 1344:28 PAGE[I]-1263:46 paSSed[2]-1275:18, 1320:26, 1324:28, 1341:18

outboard [1] -1266:19 Page [2] - 1330:23, 1281:27 1355:11 photograph [7] - 1261 :26,

outcome [1] -1239:45 1351:10 passing [1] - 1320:28 period[11]-1236:44, 1299:5, 1306:40,

outfit [2] -1235:27,1236:6 pages [3] - 1280:22, passive [1] - 1273:39 1237:42,1254:14, 1322:41,1341:30,

outfitted [1] - 1236:45 1281:13,1351:5 past [1] - 1239:46 1263:19,1263:37, 1341 :34, 1347:32

outlining [1] -1290:15 Pages[1]-1351:12 Pastor[1]-1299:15 1267:1, 1322:22, photographs [8] -

outrage [1] - 1289:42 paint [5] - 1287:23, pathologist [4] - 1313:43, 1325:40, 1334:32, 1287:14,1287:18,

outrageous [1] - 1328: 11 1287:25, 1287:26, 1314:17,1314:31, 1358:8, 1358:22 1287:20,1288:34,

outright [1] - 1290:40 1287:28, 1288:46 1318:46 periscope [1] - 1281 :27 1288:37,1288:45,

Outside [1] - 1263:9 paintings [1] - 1287:3 Pathologists [1] - 1314:14 perishing [1] - 1272:43 1289:10,1295:28

outside [6] - 1260:28, Palestine [1] - 1324:30 pathologists [1] - 1314:19 permanent [2] - 1242:9, photos[1]-1261:7

1263:34,1264:20, paper[6]-1239:4, patrol [14] - 1233:28, 1246:20 pic [1] - 1340:39

1265:46,1358:45, 1239:22, 1239:28, 1235:3,1235:18, permission [1] - 1233:40 picked [2] - 1273:26,

1359:5 1264:42, 1283:29, 1235:37, 1235:41, permits [1] - 1299:8 1302:22

Overnight [1] - 1320:36 1310:16 1235:46, 1236:2, permitted [1] - 1306: 16 picking [1] - 1284:22

overseas[1]-1319:10 PAPER [1] -1239:25 1236:20, 1236:25, perpetually [1] - 1263:29 picks[1]-1348:21

overview[1] -1241 :37 papers [1] - 1239:22 1254:6, 1255:25, persistence [1] - 1333:24 picture [13] - 1240:29,

overwhelm [1] - 1271 :44 parades [1] - 1278:23 1255:27,1255:45, persistent [3] - 1241:47, 1241 :40, 1242:2,

own [12] - 1260:4, paragraph [31] - 1251 :39, 1257:1 1328:8,1328:15 1261:27,1268:32,

1275:10,1288:44, 1252:3, 1263:22, patrols [1] - 1235:38 person [14] - 1283:38, 1269:15,1269:16,

1289:16,1293:31, 1264:11,1264:40, pattern [3] - 1239:35, 1283:47,1284:22, 1269:20, 1279:40,

1299:37,1305:4, 1264:42, 1265:35, 1239:36, 1239:43 1287:47,1297:31, 1345:31,1351:12,

1311:32,1336:13, 1278:25, 1278:35, patterns [1] - 1242:1 1305:26, 1311 :42, 1353:16,1353:17

1336: 14, 1336: 16, 1280:27,1281:15, Pauline [1] - 1322:7 1316:4,1335:11, pictures [6] - 1293: 18,

1339:46 1282:24, 1283:32, pay [3] - 1334:22, 1338:8, 1350:5, 1340:14,1340:25,

owned [1] - 1340:23 1283:45, 1284:6, 1335:15,1335:16 1350:10,1350:19, 1340:29, 1340:33,

1298:20, 1298:29, peace [1] - 1282:30 1355:27 1340:36

p 1299:26,1300:15, peak[2]-1244:6,1244:40 persona [1] - 1316:35 piece[4]-1288:28,

1300:17,1305:43, Pearl [3] - 1282: 16, personal [1]-1340:1 1310:3,1310:15,1340:71306:45,1313:23, 1301:10,1302:11 personnel [4] - 1238:10, pieces [1] - 1311 :28

Pacific [6] - 1278: 1, 1322:41,1324:1, pen [1] -1270:42 1255:36, 1255:38, Pilbara[1]-1241:451278:19,1278:27, 1330:47,1332:17, people [26] - 1234:39, 1337:39 piles[1]-1332:431278:43,1280:5, 1334:26, 1351 :28, 1271 :30, 1275:46, persons [3] - 1275: 15, pinpointed [4] - 1346:9,1280:41 1355:46, 1357:43 1276:4, 1276:38, 1275:30, 1288:20 1347:5,1347:10,

PACIFIC [1] -1283:18 pardon [1] - 1288:12 1285:34, 1292:8, perspective [7] - 1254:29, 1348:15page[66]-1242:46, Parliamentary [4] - 1301 :26, 1301 :39, 1255:35, 1255:39, PINQ.SUBS.016.0116 [2]-

1242:47,1252:35, 1275:39, 1277:23, 1301 :43, 1308:7, 1255:40,1261:27, 1337:27,1337:341263:21,1264:8, 1322:46,1337:19 1310:44,1311:44, 1262:38,1268:31 place[13]-1258:12,1264:9,1264:12, Part [1] - 1322:45 1316:36,1329:44, persuaded [2] - 1291 :42, 1279:33, 1290:40,1274:35,1278:25, part[17]-1237:19, 1333:11,1333:21, 1291:44 1316:28,1317:46,1279:8,1279:9, 1244:32, 1245:20, 1333:37,1333:39, PERTAINING [1] - 1323:43 1318:18,1318:34,1279:40,1280:26, 1253:38, 1264:11, 1333:41, 1334:4, pertaining [2] - 1233:8, 1318:36,1318:37,1280:43,1280:47, 1284:38, 1287:11, 1336:19,1337:5, 1238:42 1318:45,1329:31,1281:13,1281:15, 1301:19,1302:27, 1339:45,1340:12, Perth [5] - 1291 :18, 1340:44,1348:141282:24,1282:38, 1305:46, 1308:42, 1359:4 1315:23,1315:26, place.[1]-1290:411283:44,1283:45, 1309:16,1335:23, per[9]-1246:31,1246:37, 1324:4,1351:45 placed [2] - 1322:20,1289:35,1289:38, 1336:19,1336:20, 1249:16,1250:7, pervade[1]-1277:44 1322:471290:7,1298:19, 1349:22, 1356:29 1250:45, 1260:36, Peter[10]-1278:40, places [1] - 1306:21298:26,1299:2, partial [1] - 1316:46 1260:42,1310:16, 1279:6,1279:17, plan[1]-1241:201299:5,1305:42, participate [1] - 1281 :38 1324:35 1279:23, 1280:11, plane [1] - 1272:341306:34,1308:22, particular [11] - 1233: 19, percentage [1] - 1260:35 1280:23, 1283:4, planned [1] - 1280:441308:23,1309:5, 1233:33,1247:43, perceptions [1] - 1295:44 1283:7,1283:10, plans [1] - 1282:151309: 12, 1309: 14, 1248:41, 1287:20, perfidy [1] - 1306:23 1283:25 platform [1] - 1256:331309:15,1313:22, 1287:41, 1298:46, perform [1] -1313:27 Phase[1]-1237:9 plausible [1] - 1245:421315:38,1316:16, 1318:41,1328:24, performance [1] -1256:33 phase[6]-1233:21, play [2] - 1332:5, 1345:271320:44,1322:40, 1334:44, 1344:4 performed [6] - 1313:35, 1237:37,1246:23, played [1] - 1334:361323:47,1324:28, particularly [1] - 1343:28 1313:37,1313:38, 1247:17,1254:38, player [2] - 1281 :34,1325:27,1328:5, particulars [1] - 1280:23 1313:39,1314:30, 1254:39 1334:371330:20,1330:21, partly[I]-1293:15 1325:21 phases[2]-1234:18, pIOt[I]-1264:181330:27,1331:38, partner[1]-1281:43 performing [1] - 1314:35 1234:24 ploy [1] -1306:19

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TRAN.022.0148_R

pIUS[1]-1270:14 1280:17,1311:45, 1264:4,1265:16, prevent [1] -1306:15 progress [5] - 1253:38,pocket [1] - 1358: 15 1311:46 1265:26, 1266:2, prevents [1] - 1245:32 1254:10,1281:28,

point [24] -1236:19, possible [5] - 1243:39, 1266:42, 1269:24, previous [4] - 1243:20, 1282:3,1316:471240:22,1249:17, 1259:30, 1282:43, 1270:11, 1270:36, 1253:33,1265:37, progresSed[4]-1254:32,1250:38,1254:1, 1317:28,1334:6 1270:41, 1271 :6, 1334:31 1254:45,1254:47,1257:41,1259:7, possibly [5] - 1273:6, 1271 :16, 1271 :20, previously [4] - 1258:14, 1255:181263:18,1285:42, 1301 :16, 1308:8, 1271 :24, 1283:15, 1266:15,1274:37, progressing [2] - 1253: 16,1289:29,1297:45, 1337:9, 1351:47 1285:28, 1286:21, 1312:28 1254:71299:18,1300:26, post [4] - 1237:7, 1238:4, 1288:16,1290:36, primary[8]-1235:47, proliferate [1] - 1272:91301:41,1307:43, 1239:47,1254:43 1291:1,1292:40, 1236:1, 1236:4, prologue [5] - 1289:34,1308:18,1324:9, Post [1] - 1276:18 1293:18,1296:17, 1253:14,1253:28, 1303:5,1333:5,1336:7,1328:23,1329:11, posted[3]-1235:17, 1298:17,1298:22, 1253:34, 1254:23, 1337:21333:36,1340:16, 1237:8, 1238:6 1299:13,1300:14, 1256:37 prominent [1] - 1274:441350:38,1351:1 postgraduate [1]- 1300:34, 1301 :16, Prime [2] - 1290:33, promising [1] - 1274:4

pointer[1]-1274:41 1237:31 1302:15,1302:40, 1290:39 promoted [1] - 1313:42pointing [2] - 1242:22, Postgraduate [1]- 1302:47,1304:15, Prince [1] -1305:1 promoting [1] - 1275:10

1249:8 1237:43 1304:35, 1306:33, Principal [2] -1254:44, prompt[1]-1257:19pointS[3]-1240:11, posting[5]-1238:13, 1309:14,1310:6, 1255:17 proof [7] - 1296: 14,

1240: 12, 1240: 14 1256:24, 1256:25, 1312:20,1313:20, principal [5] - 1253:17, 1296:42, 1304:32,poised [1] -1280:3 1257:7,1257:8 1314:14,1314:38, 1254:32, 1254:35, 1304:43, 1340:1,Pole[1]-1246:19 postulate [1] - 1259:24 1315:33,1317:23, 1254:38, 1255:21 1353:33, 1353:34polished [1] -1279:5 postulated [3] - 1249:37, 1318:2,1319:10, principles [3] - 1248:39, propaganda[1] - 1278:44politics[1]-1234:11 1251 :21, 1259:8 1319:16,1320:10, 1253:25,1266:31 proponents [1] - 1274:32pool [1]-1241:5 postulation [1] - 1259:38 1320:30, 1320:36, print [2] - 1282:46, proportions [1] - 1273:10poorly [1] - 1250:7 potential [1] - 1275:32 1323:24, 1323:29, 1344:22 proposal [1] -1266:3Port [3] -1236:46, potentially[1]-1252:28 1323:34, 1323:39, PRINT[1]-1344:28 propose [1] -1259:10

1275: 14, 1275: 16 pouch [5] - 1308:30, 1325:2, 1327:9, print-out [1] - 1344:22 proposed [1] - 1271 :29port[11]-1249:43, 1308:34, 1308:40, 1327:20, 1327:41, PRINT-OUT[1] - 1344:28 proposition [10] - 1259:8,

1259:39,1259:42, 1309:7,1327:38 1328:2, 1328:21, printed [3] - 1264:38, 1270:39, 1293:21,1260:3,1260:4, Power[1]-1275:44 1329:30,1331:31, 1331:17,1331:22 1329:5, 1330:9,1260:12,1262:37, powered [1] - 1272:47 1333:23, 1337:8, prisoner [1] - 1273:5 1330:47,1338:25,1266:19,1266:23, practice[1]-1258:29

1338:19,1338:36,prisoners [1] - 1295: 14 1340:6,1349:47,

1266:35,1266:38 practise [1] - 1254: 171339:14,1340:39,

privy [1] - 1330:34 1350:391341 :18, 1342:20,position [42] - 1243:39, preceded[1]-1274:341343:3,1343:10,

probability [1] - 1333:26 propositions [2]-

1248:18,1248:30, Precisely[1]-1319:31344:19,1344:45,

problem [10] - 1240:47, 1290:43, 1293:291249:13,1249:38, preferred [1] - 1284:3 1346:39,1349:7,

1241:11,1263:29, propounding [1]-

1250:2,1250:4, preliminary [2] - 1239:5, 1349:19,1350:45, 1296:41,1311:34, 1303:141250:11,1251:9, 1267:23 1354:22, 1354:36,

1316:3,1343:10, prospect [1] - 1244:371251:25,1252:23, prepare [2] - 1238:23, 1355:20, 1355:45,

1343:17,1355:6, protect[2]-1259:19,1257:9,1257:22, 1257:1 1358:2, 1358:29, 1355:15 1266:311258:11,1258:12, prepared [2] - 1305:17, 1359:1, 1359:9, procedures[1]-1266:45 protecting [1] - 1266:321258:32,1258:38, 1350:11 1359:16,1359:20, proceeded [2] - 1234:16, protection [1] - 1274:241258:42,1258:44, preparing [3] - 1238:37, 1359:25 1282:19 prove [6] - 1290:46,1259:14,1260:11, 1238:38, 1259:11 Press [10] - 1287:45, proceedings [2] - 1291 :46, 1292:22,1260:25,1261:45, prescribed [1] - 1282:44 1287:47,1288:2, 1264:10,1276:46 1305:3,1311:15,1262:21,1262:26, presence [5] - 1249:26, 1326:22, 1326:24, PROCEEDINGS [1]- 1311:161262:34,1262:35, 1262:11, 1299:38, 1327:10,1348:42, 1264:35 proved [2] -1273:45,1263:11,1263:12, 1300:27,1352:43 1348:45, 1348:46, process [5] - 1254:36, 1277:141264:17,1265:46, present[9]-1291:10, 1349:11 1272:12,1277:9, provide[18]-1233:19,1268:24,1268:25, 1315:12,1318:45, press[5]-1274:27, 1279:30,1286:17 1233:33,1238:7,1268:28,1281:31, 1325:2, 1330:29, 1274:31, 1275:7, produce [1] -1305:12 1238:9, 1247:25,1284:34,1292:5, 1337:37,1343:38, produced [7] - 1271 :43, 1259:18,1259:24,1277:28, 1277:301292:40,1312:21, 1349:24, 1352:45 1272:1,1272:4,1273:3, 1259:26, 1259:43,1317:39,1329:35, preSSUre[16]-1239:34,

1283:24, 1304:38, 1259:44, 1260:4,presented [1] -1296:45 1239:42, 1240:1,1348: 1° presently[5]-1310:8, 1344:21 1260:9, 1262:36,1240:4,1240:7,positioning [2] -1233:34, 1310:23,1310:27, 1240:12,1240:15, production [2] - 1272:12, 1266:31, 1284:34,1268:35 1312:22,1343:27 1358:40 1312:45, 1355:40,1241:14,1241:16,positions[4]-1251:20, PRESIDENT [105]- 1241:18,1241:43, Professional [2] - 1357:241269:32,1273:43, 1242:5, 1242:43, 1244:44,1245:16, 1288:13,1288:18 provided [13] - 1268:22,1304:40 1243:23, 1244:34, professional [1] - 1288:23 1271:31,1271:47,1245:29,1245:31positive [5] - 1301 :21 , 1245:36, 1248:20, pressures [2] -1240:18, Professor[12] - 1315:4, 1283:20, 1284:3,1301:23,1301:40, 1248:33,1249:19, 1241:31 1315:7,1315:16, 1284:18,1302:26,1304:36,1304:43 1249:47,1250:36, presumably [1] - 1356:45 1315:21,1315:33, 1315:3, 1320:33,

possession[4]-1317:11, 1250:44, 1251 :3, pretty [2] - 1260:28, 1318:30,1320:30, 1334:20,1340:15,1319:27,1335:22, 1252:11, 1252:32, 1320:33, 1325:6, 1356:30, 1356:411268:31335:24 1252:42, 1252:46, 1325:8, 1325:11, providing [5] - 1266:36,

possibility [4] -1280:14, Pretty [1] - 1285:121325:12 1266:37,1277:5,1258:2, 1261:10,

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1297:31,1355:15provision [2] -1284:20,

1359: 14provoked [1] - 1271 :40proximity [1] - 1262:16Pschunder [2] - 1308:27,

1308:30pseudonyms [1] -1283:8PTE.005,0042 [1]­

1344:33PTE.005,0053 [1]­

1348:34PTE.005,0055 [1]­

1320:41PTE.005,0062[1]-1341:6PTE.005,0066 [1]-

1340: 19public [3] -1274:28,

1277:28,1329:20publication [5] - 1272: 12,

1275:36,1282:41,1283:9, 1291 :24

publicist [1] -1316:17

publicity [1] - 1278:22publish [2] - 1275:2,

1284: 16published [10] -1272:28,

1273:33,1284:7,1285:40,1286:9,1286: 15, 1286: 18,1286:22,1286:24,1286:32

publisher [11] - 1276:17,1287:34,1287:44,1288:29,1326:21,1326:30,1326:34,1327:9,1348:36,1348:39,1348:41

publishing [2] - 1286:33,

1288:30pubs [1] - 1240:1pure [1] - 1260:36purport [1] - 1303:13purported [2] - 1278: 1,

1278:6purporting [2] -1276:33,

1303:33purports[3]-1306:39,

1358: 13, 1358: 14purpose [10] - 1233:38,

1235:47,1236:1,1236:4,1247:45,1265:43,1284:29,1302:26,1309:9,1315:15

purposes [4] -1248:2,1257:17,1319:6,1330:11

pushing [2] - 1275: 10,1344: 17

put [46] - 1242:15,1244:13,1257:42,1259:8,1259:25,1260:3,1260:24,1270: 1, 1271 :32,1271:41,1274:1,1276:4,1276:31,

1278:1, 1283:5,1283:13,1289:31,1290:43, 1292:36,1293:21, 1294:14,1296:12,1296:29,1297:31, 1303:33,1304:28, 1304:31,1306:6,1309:10,1309:30,1311:31,1312:30,1313:15,1315:30,1318:39,1323:4,1325:27,1329:34, 1335:40,1336:46, 1337:43,1339:20, 1339:21,1340:40, 1340:41,1349:47

putrid [1] - 1276:24puts[2]-1336:16,

1336:42putting [2] -1257:24,

1275:46Putting [1] - 1270:42

PWO [6] - 1255:5, 1255:7,1255:8,1255:12,1255:15,1255:20

PWOG [1] - 1254:45

Q

QC [2] - 1232:25, 1232:33qualification [12]­

1237:41, 1237:45,1237:47,1253:15,1253:28, 1253:34,1253:42, 1254:3,1254:6,1254:16,1254:19,1254:23

qualifications [1]­

1314:10qualified [6] - 1234:42,

1234:44, 1235:32,1241:17,1254:16,1254:44

qualifying [1] - 1235:2

quarry[1]-1356:40quarter [18] - 1249:39,

1250:12,1261:18,1261 :30, 1261 :32,1261:34,1261:47,1262:35, 1262:38,1262:45,1266:18,1268:26, 1270:2,1270:13,1270:15,1298:40, 1307:8,1307:15

quartermaster [1]-

1305:20quarters[1]-1258:41

quashing [1] - 1273:36Queensland [2] - 1285:5,

1325:13quell [1] - 1316:33questioned [2] - 1282:32,

1335:29questioning [3] - 1250:33,

1269:6,1284:15questions [8] - 1252:8,

1269:9,1330:17,1332:45, 1345:3,1347:31,1359:9,1359:11

quick [1] - 1298:39quickly[4]-1246:11,

1261:7,1313:42,1358:43

quiet [1] - 1334:35quirk[1]-1326:45Quite[2]-1309:41,

1319:31quite[17]-1256:20,

1261 :36, 1261 :39,1261:47,1262:14,1262:15,1263:8,1267:41,1280:10,1293:12,1301:12,1312:47,1319:20,1329:20,1342:15,1356:47,1358:43

quote [2] - 1299:2,

1335:34

R

RAAF [2] - 1272:34,1274:16

radar [3] - 1267:40,1268:4,1268:12

radio [16] - 1331 :42,1332:10,1332:20,1332:26, 1333:1,1333:11,1333:17,1333:25, 1333:38,1335:36, 1335:41,1336:26,1336:27,1336:35,1338:10,1352:19

raft [1] - 1272:43rafts [2] - 1282:7, 1282:9raider [10] - 1272:36,

1279:28, 1298:38,1329:25, 1329:45,1330:32, 1332:28,1336:32, 1336:33,1357:9

raider's [2] - 1298:42,

1328:9raiders [1] -1267:34Raiders [1] - 1263:25RAIDERS[I]-1264:1rain[1]-1245:34raised [1] - 1312:2

ran[1]-1329:25RAN [13] - 1232:34,

1232:36, 1243:2,1253:10,1254:47,1255:22, 1265:22,1274:34, 1351 :16,1357:8, 1357:30,1358:9,1358:17

RAN,002,0139 [2]­

1242:41,1271:11

range [29] -1233:17,1236:21,1244:47,1245:3, 1245:45,1246:1,1251:33,1251 :42, 1258:19,1260:26,1260:27,1260:29,1260:37,1261:1,1261:36,1261 :40, 1262:8,1263:2, 1263:3,1263:13,1263:37,1264:20, 1265:45,1267:15,1279:26,1322:21, 1322:26

ranging [1] - 1235:38rank[1]-1255:5RANR [4] - 1232:33,

1232:35, 1232:38,1339:43

rate[1]-1266:46Rather [3] - 1256:30,

1273:35, 1292:35rather [3] - 1281 :22,

1299:22, 1353:41re [4] - 1273:46, 1343:30,

1354:26, 1354:27re-arise [1] -1343:30re-contact [2] - 1354:26,

1354:27re-evaluation [1] ­

1273:46reach [1] - 1308:33reached [2] - 1249:21,

1289:27reaching [1] - 1290:23read [52] - 1234:35,

1244:20,1246:14,1246:27,1247:23,1249:24, 1249:35,1251:39,1251:43,1257:25, 1260:22,1260:28, 1260:43,1261 :46, 1262:32,1262:39, 1262:43,1263:2, 1263:4,1263:14,1263:20,1263:25, 1264:11,1264:38, 1264:42,1264:47,1265:1,1265:4,1265:17,1265:41, 1268:22,1270:41, 1278:5,1284:29,1285:14,1287:8,1287:11,1289:29, 1290:3,1298:29,1300:15,1305:36, 1306:38,1319:42, 1328:21,1329:1,1330:15,1339:9, 1345:22,1346:26,1346:37,1357:16

reader[1]-1290:15readers [3] - 1280:1,

1282:39, 1333:6reading [9] - 1233:35,

1234:35, 1260:31,

TRAN.022.0149_R

1278:31,1279:11,1283:31, 1283:46,1299:27,1328:25

reads[1]-1315:40

ready[1]-1306:1real [1] - 1346:4realise[1]-1280:11reality [1] - 1283:34really [5] - 1236:21,

1250:31,1296:17,1313:30, 1328:2

reappeared [1] - 1324:11reason [14] -1259:29,

1266:38, 1267:43,1297:21,1300:17,1301:19,1303:35,1312:40,1319:7,1321:44,1321:45,1349:42, 1349:43

reasonable [6] - 1251: 15,1311:44,1320:7,1327:15,1329:43,1329:47

reasonably[2]-1250:28,1263:6

reasoned [1] - 1271 :44

reasoning [1] - 1299:43reasons[4]-1259:31,

1267:42, 1274:43,1324:5

reassurance [1] - 1316:5recant[1]-1296:2

received [12] - 1273:4,1274:22, 1274:33,1280:34, 1302:5,1331:1,1337:39,1348:35, 1348:36,1355:21, 1356:2, 1356:7

recent [2] - 1280:33,

1331:15recently [6] - 1254:46,

1275:36,1276:3,1277:44,1319:27

reciting [1] - 1337:4

reckon [1] - 1270:9recognise [1] - 1331 :35

recognised [1] - 1276:23recognition [2] - 1236:13,

1268:47recollection[1]-1252:11recollections [1]­

1335:30recommendations [1]­

1245:43record [6] - 1240: 1,

1273:8,1315:18,1320:45,1334:37,1350:37

recorded [5] - 1239:39,1325:10,1331:44,1352:11,1355:26

recording [2] - 1339:25,1339:26

recordings [1] - 1238:43

records [10] - 1240:37,1240:38, 1313:46,1317:37,1317:40,

L-__ , 19/1 /09 (22) --------"--21

Transcripl produced by Merrill Legal Solulions

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TRAN.022.0150_R

1321:21, 1323:20, 1276:22, 1285:25, 1309:2, 1309:42, require [1] - 1351 :38 RFD [2] -1232:25,1323:21, 1326:47, 1288:32, 1288:45, 1309:46,1312:40, required [2] - 1253:36, 1232:331327:5 1289:9,1290:16, 1313:43,1320:1, 1325:32 RGH [1] - 1324:40

RECORDS [3] - 1323:44, 1291:31,1292:17, 1320:3, 1320:4, requirement [1] -1237:35 Richardson [13] - 1288:5,1327:3,1327:7 1295:12,1296:2, 1320:27,1322:9, requirements [1]- 1314:41,1315:9,

recounting [1] - 1293:38 1297:7,1320:22, 1325:23,1326:15, 1237:38 1320:37,1320:39,recover [2] - 1286:45, 1321:21,1322:11, 1326:18,1328:17, requisite[1]-1254:17 1325:5,1325:7,

1349:33 1323:27,1333:7, 1328:25, 1329:41, reSCUed[1]-1306:24 1325:34, 1326:3,

Red [1] - 1273:2 1356:46, 1358:40, 1333:10,1334:22, Research [2] - 1272:16, 1326:20, 1326:21,

red [1] -1249:42 1358:45 1335:12,1340:20, 1273:37 1327:11

Reds [1] - 1341 :38 relationship [3] - 1291 :29, 1346:29, 1346:31, research [12] - 1277:15, Richardson's [2] -

reds [1] - 1340:31 1342:2, 1342:6 1346:32, 1346:35, 1278:42,1290:10, 1325:47,1336:14

redUCe[2]-1251:12, relative [33] - 1234:25, 1349:43,1350:14, 1290:17,1290:19, ridiculous [1] - 1299:22

1251:47 1236:15,1236:20, 1356:15,1356:29 1290:22, 1290:23, right-hand [2] - 1269:34,

reek[1]-1276:13 1236:39, 1246:39, Remember [3] - 1260:37, 1317:9,1337:3,1350:2, 1269:39

refer [8] - 1283:45, 1247:43,1248:1, 1261:1,1262:7 1350:19,1350:35 right-side [1] - 1259:44

1285:36,1285:45, 1248:5,1248:12, remembering [1]- researched [1] -1304:46 rightly [3] - 1297:25,

1320:22, 1324: 1, 1248:18,1248:29, 1350:15 researcher [2] - 1279:11, 1313:43, 1334:23

1328:6,1330:13, 1248:35, 1248:39, Remembrance [1]- 1283:4 rigour [6] - 1303:5,

1354: 14 1248:46, 1249:1, 1278:18 researchers [4] - 1275: 10, 1303:22, 1309:35,

reference[5]-1246:18, 1250:10,1252:23, reminded [3] -1305:19, 1277:40,1350:7, 1333:6, 1336:3, 1337:4

1252:34,1265:39, 1257:22, 1257:35, 1305:23, 1305:25 1353:14 ring [1] - 1337:28

1357:46,1358:6 1258:14,1259:2, remiss [2] - 1271:4, researching [1] - 1327:32 risk [2] - 1323:5, 1323:10

references[1]-1328:14 1260:20, 1260:21, 1337:6 reside[1]-1354:19 River [1] - 1302:11

referred [13] -1237:19, 1260:34, 1261 :27, removed [2] - 1273:1, residents[1]-1275:17 RIVETT [3] - 1233:42,1242:36,1265:36, 1262:34, 1263:11, 1322:45 resolved [2] - 1267:28, 1238:34, 1250:421272:39,1303:5, 1268:18,1268:24, removing [1] - 1273:8 1267:29 Rivett[11]-1233:15,1314:26,1329:4, 1269:31,1270:13 rendezvous [1] - 1309:9 respect [4] - 1247:34, 1233:17,1233:19,1330:8,1339:27, Relative [2] - 1236:37, Renwick [2] - 1232:38, 1281:37,1316:47, 1233:40, 1233:46,1341:44,1342:38, 1268:18 1251 :3 1331:5 1250:34, 1252:44,1345:6,1348:4 relatively [1] - 1281:8 RENWICK [15] - 1251:1, respond [2] -1351:41, 1252:46, 1253:21,

referring [7] - 1268: 16, release [2] - 1277:28, 1251 :5, 1251 :7, 1252:8, 1356:25 1257:16,1257:191302:37,1303:23, 1277:31 1252:34,1265:13, response [5] - 1261 :21 , road [2] - 1236:34,1328:14,1336:11, relevance [5] - 1244:34, 1265:24, 1269:9, 1261 :43, 1265:20, 1237:171338:9,1356:8 1326:42, 1326:44, 1269:12,1269:14, 1266:3,1318:14 rocked[1]-1328:19

refers [3] - 1238:47, 1340:47,1348:31 1269:27,1270:17, responsibility [2]- ROE [1] - 1267:261243:5,1333:9 relevant[5]-1241:10, 1270:38, 1271:1, 1235:27,1235:29 role [9] - 1235:47,

reflects [1] - 1247:22 1263:26, 1264:11, 1359:11 responsible[4]-1234:47, 1236:29, 1236:32,Refresh [1] -1337:17 1318:42,1357:47 Repa! [1] -1315:45 1235:28, 1255:8, 1238:18,1255:2,refused [2] - 1284:16, relics [1] -1274:22 repeated [1] - 1332:24 1255:21 1255:4,1256:27,

1339:27 relied [4] - 1275:16, replied[1]-1316:15 res! [2] - 1282:22, 1349:23 1256:36, 1350:29

regard [1] - 1324:46 1295:12,1298:45, reply[4]-1280:31, result[7]-1244:11, Roll [1] - 1346:22

regarding [1] -1316:43 1299:6 1280:39,1316:16, 1272:36,1274:7, room [4] - 1241 :3,

regime [1] - 1255:36 Relvel [3] - 1236:33, 1323:20 1277:16,1285:41, 1284:40, 1325:23,

regiment [1] -1354:3 1236:36,1248:10 report [7] - 1238:44, 1337:3,1350:12 1332:10

Regiment[3]-1331:11, rely [7] - 1292:32, 1297:1, 1244:30, 1264:9, resulted [1] - 1275:35 rough [2] - 1261 :40,

1332:13,1337:40 1297:6, 1297:20, 1275:40, 1287:8, results[3]-1241:29, 1269:20

region [2] - 1247:32, 1297:43, 1300:3, 1305:8, 1305:37 1322:2, 1350:35 roughly [3] - 1269:47,

1274:39 1300:10 REPORT [2] - 1239: 13, resume [1] - 1300:34 1270:14,1289:26

regret [1] - 1282:32 relying[3]-1287:17, 1264:34 RESUMPllON[I]-1301:1 round [1] - 1242:6

reiterate[1]-1263:3 1299:11,1299:20 reported [4] -1299:39, retired[2]-1278:41, round-the-year [1]-

reject[2]-1280:14,remain [2] - 1283:1, 1302:17,1351:15, 1304:9 1242:6

1307:29 1321:31 1352:19 Retired [1] - 1304:7 routed[1]-1264:15

rejection [1] -1272:19 remained[1]-1280:19 reporting [2] - 1275:5, retract [2] - 1292:45, routine [2] - 1267:34,

relate [2] - 1233:7,remaining [4] - 1233:36, 1281:28 1300:23 1313:30

1274:411267:4,1267:16, reports [3] - 1244:21, return [4] - 1237:7, routinely [4] - 1313:34,

related[3]-1233:17, 1267:25 1274:21, 1274:27 1243:17,1260:14, 1314:3,1314:26,

1264:43,1344:41remains [6] - 1238: 18, represent [3] - 1234:44, 1272:24 1314:30

relates[2]-1307:45,1248:3,1274:12, 1235:12,1253:42 returned[1]-1319:12 routines [1] -1237:22

1357:251310:34,1339:30, Representing [1] - revealed [2] - 1283:37, routing [1] - 1238:42

relating [1] -1307:431349:27 1232:38 1331:41 Royal [14] - 1233:16,

relation [30] - 1237:17,remark [2] - 1327:27, reprimanded [1] - 1335:42 revealed" [2] - 1343:4, 1233:47,1273:29,

1238:38,1249:40,1329:41 republished [1] - 1275:37 1343:5 1273:30, 1273:31,

1251 :8, 1251 :20,remarkable [1] -1287:21 reputable [1] -1336:8 revelation[2]-1315:47, 1274:5,1277:19,

1260:17,1271:35,remember [34] - 1286:42, request [2] - 1323:34, 1318:12 1287:10,1290:39,

1272: 10, 1272: 18,1297:25, 1298:46, 1331:43 revelations [1] - 1282:42 1295:4,1354:16,

1272:20,1276:7,1301 :9, 1308:41, requesting [1] - 1322:11 reviews [1] - 1239:30 1354:43,1357:7

,19/1/09 (22) 22Transcripl produced by Merrill Legal Solulions

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TRAN.022.0151 R

23,19/1/09 (22)

rudimentary [2] - 1234:35, 1259:27,1264:43 1299:36, 1300:4, 1243:47,1244:3, second-last [5] - 1278:25,

1330:24 sailed [1] - 1327:44 1300:16, 1306:44, 1244:8,1244:10, 1281:15,1332:17,

rule[4]-1263:7,1321:32, sailor[10]-1276:22, 1338:30, 1338:32, 1244:27,1244:35, 1351:27,1355:46

1323:17,1323:24 1276:23,1315:45, 1338:34, 1340:27, 1245:20, 1253:39, secondary [1] - 1260:24rUleS[5]-1236:34, 1316:8,1316:9, 1343:31 1254:12,1254:27, seconded [1] - 1349:32

1237:3,1237:17, 1316:28,1318:11, SBLT[I] -1298:34 1254:31, 1254:46, secondly [2] -1253:26,1267:47,1272:22 1318:18,1318:32, SCale[17]-1240:19, 1255:13,1255:15, 1274:42

rumours [1] -1274:42 1325:21 1240:22, 1240:23, 1255:47,1256:1, secrecy [2] - 1274:42,

RUn[1]-1332:13 sailor's[1]-1314:36 1240:27,1243:1, 1256:21, 1256:31, 1322:47run [6] - 1236:5, 1259:41, sailors [5] - 1276:26, 1243:6,1243:10, 1257:11,1257:29, secret [5] - 1282: 15,

1259:45,1327:22, 1310:34,1319:33, 1243:11, 1243:24, 1257:34, 1259:29, 1282:34, 1323:30,1329:35,1348:20 1320:14,1334:37 1243:26, 1269:34, 1259:41, 1259:45, 1330:14,1330:35

RUNNERS[I]-1264:1 SaIVO[2]-1298:42, 1269:38, 1270:26, 1260:3, 1260:5, secretly [1] - 1280:44Runners" [1] -1263:25 1299:31 1270:32, 1270:43, 1260:10,1264:16, section [1] -1263:26running [2]-1234:38, salvos [2] - 1277:7, 1271:4 1268:23,1271:7, sections [1] - 1263:20

1264:28 1299:34 scales [1] - 1271:8 1273:2,1320:15, seCUred[1]-1262:5

Rush [2] -1232:33,1302:6 SampeY[1]-1274:11 SCALES[I]-1271:11 1338:30, 1338:32, security [2] - 1323:4,

RUSH[75]-1233:1, Sampey's[1]-1274:17 scenario [1] - 1260:2 1338:34, 1344:23, 1323:101271:22,1271:29, Samuel [1] - 1293:39 scene [2] - 1282:4, 1344:24,1351:16, see [68] - 1243:12, 1245:5,1283:20,1284:29, SAMUELS [2] -1284:42, 1294:11 1353:2, 1353:37 1246:26, 1248:29,1284:44,1284:46, 1358:34 schedule [1] - 1317:2 sea-going[1]-1254:12 1249:13,1249:16,1285:32,1286:31, Samuels [54] - 1233:3, Schrader [1] - 1272:40 seabed [1] - 1275:22 1249:32,1251:12,1288:27,1290:43, 1276:16,1284:39, Science [2] -1234:7, seal [1] - 1322:38 1251:17,1251:18,1292:28,1293:21, 1284:46, 1285:1, 1287:9 sealed[12]-1321:13, 1251:26,1251:30,1297:1,1298:19, 1285:11, 1285:24, science [2] - 1234:9, 1321:31,1321:36, 1251:32,1251:46,1298:25,1299:26, 1289:33, 1290:44, 1321:10 1321:39,1321:40, 1260:26, 1260:35,1301:3,1302:8, 1292:28, 1295:20, Scientific [1] - 1351 :39 1321 :46, 1322:20, 1261:16,1262:7,1302:20,1303:2, 1298:22, 1298:25, scientist [1] - 1343:32 1322:25, 1322:45, 1262:18,1262:46,1304:17,1305:15, 1298:29, 1298:45, scintilla [1] - 1309:31 1323:1,1323:13, 1263:8, 1267:46,1308:22,1309:29, 1299:27, 1301 :3, scores [1] - 1278:30 1350:31 1268:6, 1269:34,1312:7,1313:22, 1304:35,1305:15, SCOTT [2] - 1233:42, SEALED [1] - 1323:43 1269:38,1278:6,1314:23,1315:6, 1306:33, 1308:22, 1238:34 seaman [15] - 1233:16, 1282:12,1287:4,1315:30,1315:36, 1309:45,1311:20, Scott [1] -1233:15 1233:26,1234:18, 1287:5,1287:28,1317:32,1319:12, 1312:17,1315:39, screen[10]-1242:16, 1235:25, 1236:38, 1288:35,1293:18,1319:40,1320:13, 1316:12,1317:33, 1262:41,1298:13, 1241:12,1241:17, 1295:28, 1297:21,1320:33,1320:41, 1320:13,1321:1, 1298:32,1315:30, 1248:38,1253:16, 1297:46, 1300:22,1323:26,1323:32, 1322:7,1327:13, 1320:42, 1324:1, 1253:29, 1253:36, 1305:7,1305:46,1323:37,1323:47, 1327:27,1328:5, 1346:37,1347:1, 1253:46, 1254:29, 1306:11, 1307:6,1326:47,1327:5, 1330:23,1336:17, 1357:39 1254:30,1259:13 1308:3,1311:13,1327:13,1327:43, 1336:42, 1339:24, scroll [4] - 1242:47, seaman's [3] -1236:16, 1311:20,1315:38,1328:4,1328:27, 1344:35,1345:27, 1263:22, 1346:22, 1237:20,1237:21 1316:3,1318:42,1330:8,1331:38, 1345:34,1345:37, 1346:32 seamanship [1] - 1234:26 1318:44,1318:45,1334: 19, 1337: 14, 1345:41,1346:10, scrolling [1] - 1346:25 search [6] - 1240:35, 1320:36, 1320:44,1337:31,1337:36, 1346:14,1346:28, scuttled [1] - 1273:1 1274:7,1291:17, 1320:45, 1322:6,1338:24,1338:44, 1347:6,1348:35, scuttling [1] - 1277:9 1340:2,1352:12, 1324:13,1324:30,1339:24,1340:47, 1354:14,1355:25, SEA[3]-1271:11, 1356:45 1324:32, 1324:43,1341:23,1342:38, 1358:37,1358:39, 1344:29, 1344:30 searched[1]-1282:18 1336:16,1336:19,1343:7,1344:33, 1359:3,1359:13, Sea[6] - 1256:18, searches [1] -1275:24 1341:24,1343:10,1345:3,1347:31, 1359:16 1256:26,1256:27, searching [1] - 1317:37 1350:28,1351:1,1348:3,1349:10, Samwells [1] - 1349:1 1256:36, 1257:26, seasonal [1] - 1344:24 1353:36, 1354:251349:30,1354:13, sand[3]-1293:12, 1275:44 SEASONAL [1] - 1344:31 seeing [1] - 1302:381354:31,1355:11, 1293:16,1346:43 Sea[73]-1233:19, seat [1] - 1276:38 seek[1]-1316:341355:25,1355:43, SANK [1] - 1279:12 1233:35, 1234:28, second [21] - 1236:26, seem[1]-1279:431358:36,1358:43, sank[3]-1273:25, 1236:12,1236:17, 1237:1, 1254:39, seemingly [1] - 1279:321359:13,1359:23 1291 :46, 1343:29 1236:39, 1236:43, 1261 :18, 1269:35, seized [1] - 1325:13

Sank [2] - 1272:28, 1236:45, 1237:1, 1278:25, 1280:26, selected [2] - 1255:24,

S 1285:35 1237:2,1237:12, 1281:15,1281:41, 1256:3satellite [2] - 1239:38, 1237:37,1239:33, 1291:15,1316:43, self[1] - 1274:47

safe [5] -1234:38,1241:22 1239:42, 1240:6, 1317:8,1317:10, self-serving [1] - 1274:47

1234:45,1237:17,satisfactory [2] - 1263:32, 1240:11,1240:15, 1317:15,1317:38, semi [1]-1316:45

1237:22,1253:441263:36 1241:13,1241:18, 1317:43,1332:17, semipermanent [1]-

safely [2] -1259:22,satisfied [1] - 1312:21 1241 :31, 1242:38, 1345:29,1351:27, 1241:44

1266:34save[1]-1311:6 1243:13,1243:15, 1354:24, 1355:46 send[8]-1259:11,

Safety[I]-1265:27saving [1] - 1306:30 1243:28, 1243:33, Second [2] - 1276:35, 1259:15,1260:5,SaW[14] - 1279:36, 1243:35, 1243:36, 1277:38 1332:35, 1333:8,

SAFETY [1] -1265:311295:44,1297:12, 1243:40, 1243:43, second-largest [1]- 1333:25, 1340:33,

safety [3] - 1234:47,1297:28,1297:47, 1243:44, 1243:45, 1291:15 1342:20

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sending [5] - 1277:9, shall [6] - 1242:44, 1320:6, 1320:8, Shu's [1] -1297:19 silhouettes [1] - 1268:211333:13,1333:17, 1271 :6, 1340:2, 1320:24, 1336:25, sick [1] - 1340:26 similar [5] - 1245:7,1333:38,1341:37 1342:36,1347:47, 1352:11 side [20] -1245:16, 1253:21, 1253:32,

seniOr[4]-1236:1, 1358:31 ship-handling [1]- 1249:35, 1252:39, 1262:26, 1263:4

1236:2,1255:5,1279:6 Shall [1] - 1359:20 1253:35 1259:39, 1259:42, simply [2] - 1339:36,

Sensational [1] -1271:41 shallow[1] - 1274:22 shipping [3] - 1264:44, 1259:44, 1260:3, 1356:26sensational [7] - 1271 :43, SHARK [1] - 1239:10 1265:27,1338:38 1260:4,1260:12, simulator[1]-1237:13

1275:8,1277:42, Shark [1] - 1274:39 SHIPPING [1] - 1265:31 1262:2,1262:17, sing [1] - 1336:351282:42,1315:47, shattering [4] - 1289:46, ships [26] - 1233:12, 1266:19,1266:23, Singapore [15] - 1312:8,1318:12,1350:39 1290:28, 1290:32, 1236:12,1236:17, 1266:33, 1266:35, 1313:9, 1328:44,

sensationalism [1]- 1290:44 1236:39, 1236:41, 1266:39,1270:14, 1329:2,1329:17,1288:28 shed[2]-1354:31, 1237:11, 1252:4, 1297:16, 1312:30, 1330:30, 1334:23,

sensible[1]-1271:44 1356:19 1253:39,1253:47, 1313:15 1334:34, 1334:41,

sent [27] - 1234:28, sheer [1] - 1335:46 1254:3,1254:12, sight [2] - 1279:37, 1334:47,1335:17,

1272:21,1312:37, shine [1] - 1324:14 1254:46, 1255:2, 1282:10 1335:37,1335:39,

1317:4,1317:40, ship [88] - 1234:25, 1255:9, 1256:44, sighted [10] - 1245:10, 1356:3, 1356:7

1329:45,1330:32, 1234:28, 1234:36, 1257:12, 1263:31, 1245:40,1257:44, singing [4] - 1334:38,1340:9,1340:25, 1234:37,1234:38, 1265:44, 1266:22, 1272:34, 1313:3, 1334:39, 1335:38,

1340:29,1341:10, 1234:45, 1234:46, 1267:15,1268:13, 1339:10,1351:31, 1336:251341:31,1341:33, 1236:13,1236:16, 1279:26,1296:18, 1351 :45, 1353:2, single[6]-1234:46,1341:42,1342:11, 1237:15,1237:17, 1305:1, 1305:21, 1353:21 1253:45,1253:47,1342: 14, 1343:21, 1237:22, 1245:20, 1320:23 sighting [2] - 1277:2, 1255:7,1279:34,1344:36,1344:37, 1245:44,1248:13, SHIPS[I]-1264:2 1298:34 1282:131348:45,1349:4, 1248:40, 1248:41, Ships[I]-1264:14 sign[1]-1335:15 single-ship [3] - 1253:45,1349:5,1349:10, 1249:15,1249:32, shipwreck [1] - 1286:39 signal [16] -1233:35, 1253:47,1255:71356:4,1356:11, 1251 :26, 1251 :28, shipwrecks [2] - 1274:25, 1234:35, 1252:4, sink[4]-1282:5,1282:19,1356:18,1356:26 1251 :29, 1252:24, 1275:32 1252:13,1260:23, 1308:36, 1312:30

sentence [1] - 1280:38 1253:35, 1253:42, shirt [1] - 1242:24 1260:40, 1263:2, sinking [6] - 1292:3,separating[1]-1313:11 1253:43, 1253:45, shock [1] - 1272:6 1263:4, 1266:5, 1302:8, 1304:29, 1304:32,September [6] -1235:8, 1253:47,1254:10, shocking [1] - 1289:42 1303:23,1356:18, 1304:45, 1309:9,

1323:19,1323:20, 1254:15,1254:18, shone [1] - 1354:29 1356:19,1356:26, 1334:321324:34,1327:44, 1254:21, 1254:25, shoot [2] - 1333:40, 1356:33, 1356:46 sinkings [1] - 1343:291341:24 1255:7,1255:9, 1335:47 signalling [8] - 1233:9, sister[9]-1313:36,

sequential [1] -1318:27 1256:30, 1256:32, shore[1]-1335:42 1236:13,1260:18, 1314:24, 1314:32,series [1] -1255:13 1258:9,1258:13, short [4] - 1264:28, 1262:31, 1263:33, 1314:34,1314:38,seriously [1] - 1336:30 1258:31, 1258:32, 1271 :24, 1281 :8, 1264:19,1264:22, 1318:28,1319:7,

serve [5] - 1235:2, 1258:35,1258:37, 1335:43 1267:7 1326:37,1326:43

1235:33,1238:2, 1258:38, 1258:39, SHORT[I]-1271:27 signalman[1]-1251:43 sisters[1]-1314:40

1254:3,1254:12 1258:45, 1262:24, shortlist [1] - 1350:7 signals [13] -1252:38, site[4]-1271:47,

served [4] - 1235:3, 1262:32, 1263:30, shot [1] - 1272:46 1272:21,1312:7, 1274:17,1275:14,1235:6,1273:38, 1265:2, 1267:41, shovels [1] - 1348:21 1312:24, 1312:38, 1343:291276:26 1267:44, 1267:46, show[1] - 1287:20 1331:1,1333:1,1333:3, sits [1] - 1236:19

serves[1]-1252:11 1268:16,1268:36, showed [1] - 1350:36 1356:2, 1356:6, sitting [4] - 1276:36,Service [1] -1322:19 1269:20, 1270:6, SHOWING [1] - 1344:28 1356:32,1356:47, 1281 :44, 1289:26,

service [7] -1320:14, 1279:25, 1279:30, showing [2] - 1259:3, 1357:13 1289:27

1320:45,1323:35, 1279:41,1281:21,1344:22 signature [1] -1238:30 situated [1] - 1261 :22

1326:47,1327:5, 1281:23,1281:25, shown[4]-1263:31, SIGNED [1] - 1265:30 situation [7] - 1233:12,1334:34,1340:23 1286:38, 1287:1,

1269:43, 1283:44, signed [7] -1265:16, 1258:9, 1258:33,

SERVICE [3] - 1323:44, 1287:4,1287:13,1331:20 1265:26,1265:37, 1260:7,1260:8,

1327:3,1327:7 1287:16, 1287:21, Shown [1] - 1238:27 1345:24, 1345:26, 1267:10,1356:8

serving [3] - 1233:2, 1287:25,1288:47,shows[2]-1302:11, 1348:27,1348:30 six[4]-1277:7,1278:14,

1274:47,1313:25 1291:10,1291:14,1302:12 significance [1] - 1324:8 1286:19,1319:17

sot[6]-1246:40, 1275:39, 1295:43,1306:14,shrapnel [3]-1277:25, significant [2] - 1246:17, size [2] - 1239:47, 1252:5

1275:44,1279:35, 1308:37,1313:4,1277:27,1277:32 1249:34 skeletal[1]-1274:12

1290:22,1310:4 1320:8,1320:15,shred[1]-1329:4 significantly [2] - 1250:18, skerrick [2] - 1353:30,

sets [3] -1280:22, 1320:16,1330:31,Shu [22] - 1297:2, 1252:1 1353:41

1281:13,1333:12 1334:29, 1335:21,1297:11, 1297:39, signing[1]-1321:9 skill [1] - 1235:43

setting [1] - 1267:18 1336:31,1351:15,1298:14,1298:15, SILENCE [3] - 1282:42, skilled [2] - 1313:40,

seven [4] -1235:14, 1352:36 1283:8,1283:17 1313:441298:32, 1298:38,1235:19,1272:11, SHIP'S[I]-1271:10

1299:36, 1299:40, silence[2]-1316:38, skills [9] -1253:26,1316:31

ship's [19] - 1234:47,1300:4,1300:7, 1335:36 1253:34, 1253:36,

several [1] -1235:38 1237:21, 1249:1,1300:16,1300:18, Silence [1] -1277:47 1253:46,1254:17,

shadow[2]-1249:23,1249:44, 1256:29,

1300:28,1305:18, silent [1] - 1330:35 1254:39, 1255:6,

1250: 161259:19,1266:33,

1305:19,1305:34, silhouette [6] - 1251 :22, 1288:24, 1288:32

shadowed [1] - 1282:31266:44,1270:12,

1306:39, 1306:43, 1259:3, 1268:28, skull [7] - 1277:31,

shadowing [1] -1251 :241271 :6, 1319:29,

1307:4, 1307:32, 1268:30, 1268:40, 1340:14, 1342:21,

shadows [1] - 1251 :241319:34,1319:41,

1307:38 1268:43 1345:38,1347:10,

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1347:21,1347:24 1326:12,1349:26, 1244:29 squeaky [1] - 1319:7 1252:3, 1305:45,SkY[I]-1245:30 1350:28 southerly [8] - 1241 :2, squiggly [1] - 1257:28 1306:40, 1312:42,slaughter [1] - 1294:22 son [5] -1340:12, 1242:1,1244:12, stacks [2] - 1315:46, 1319:25, 1328:24,

slaughtered [1] -1282:10 1346:42, 1346:44, 1244:15,1244:30, 1318:11 1331:44,1332:16,

slight [1] -1248:24 1347:13,1347:15 1257:27,1257:38, stall[5]-1255:19,1256:2, 1334:20,1337:37,

slightest [2] - 1326:42, song [2] - 1335:40, 1258:30 1256:38,1257:12, 1357:2,1357:36,

1343:28 1336:35 Southern [1] - 1239:6 1283:28 1358:25, 1358:27

slowly [1] - 1259:3 soon [2] - 1240:27, SOUTHERN [1] - 1239:19 Stall[3]-1256:1,1283:38, STATEM ENT [1] - 1238:34

small [7]-1236:41, 1276:35 spaghetti [1] - 1344:45 1290:38 statements [2] - 1328:22,

1254:10,1256:29, Sorry[7]-1301:7, spans [1] - 1250:30 stage [6] - 1246:13, 1333:7

1272:15,1277:35, 1316:20,1320:17, spare [1] - 1278:29 1306:18,1317:9, States[1]-1282:17

1311:28,1334:33 1327:38, 1340:20, SPC,006,0005 [1]- 1340:8,1340:14, states[7]-1271:7,

small-arms [1] - 1277:35 1342:44, 1348:28 1302:20 1355:31 1280:7,1280:47,

smaller[1]-1240:23 sorry [7] - 1251 :37, speaking [6] - 1243:26, stages [1] - 1339:21 1284:22, 1298:38,

smoke [2] - 1262:12, 1259:26, 1268:39, 1276:38, 1291 :21, stance [1] - 1292:6 1307:7,1314:16

1262: 15 1286:10,1295:32, 1325:40, 1345:45, stand [4] - 1235:12, STATES[I]-1271:11

smooth [1] -1240:28 1306:10,1325:22 1356:6 1268:33,1324:12, stating [1] - 1307: 18

SnOOk[34]-1310:25, sort[8]-1253:21, speaks [1] - 1304:40 1330:36 Station [7] - 1312:37,

1310:29,1310:33, 1256:11, 1269:3, Special [2] - 1291 :5, standard [1] -1245:15 1329:17,1330:30,

1310:47,1312:3, 1270:33, 1284:30, 1291 :6 standing [6] - 1245:43, 1331:2,1331:8,1356:42

1312:22,1313:17, 1289:3,1292:16,1354:2 special [1] - 1278:17 1248:13,1291:5, station [7] - 1240:5,

1313:25,1313:34, sorts [2] - 1236:9, 1238:5 specialisation [1] - 1234:9 1291:6,1292:11, 1248:42, 1259:41,

1313:47,1314:7, sought [1] - 1282:9 specialisations [1]- 1292:14 1266:25, 1335:42,

1315:27,1317:10, soul[1]-1282:10 1237:25 stands [1] - 1343:3 1351:17,1352:20

1317:37,1317:42, sound[1]-1308:12 specialised [2] -1237:27, star[1]-1246:25 station-keeping [1]-

1318:29,1319:5, sounded [2] - 1332:20, 1254:28 starboard [26] - 1249:38, 1248:421319:10,1319:19, 1332:23 specialist [1] - 1233:27 1249:42, 1249:43, stationary [4] - 1259:16,

1320:45,1321:17, source [19] -1246:34, specialists [1] - 1351 :39 1250:12,1252:14, 1260:15,1266:16,1322: 12, 1322: 19, 1247:31,1247:39, specific [6] - 1241 :39, 1252:15,1252:16, 1303:411323: 19, 1324: 12, 1261:20,1262:17, 1242:12,1247:41, 1252:39,1257:44, stationed [2] - 1259:1,

1324:14,1324:45, 1266:17,1308:41, 1255:30,1256:37, 1258:4, 1259:40, 1306:21325:3,1325:20, 1312:41,1312:42, 1332:44 1259:43, 1260:5, stations [2] - 1304:40,1325:35,1325:45, 1313:36,1320:1, specifically [2] - 1242:13, 1261 :29, 1261 :30, 1305:471326:43,1327:1,1330:8 1320:3, 1320:4, 1320:5, 1295:35 1261 :32, 1261 :34, stay [2] - 1261 :21, 1323:30

SNOOK [1] -1327:3 1320:22, 1320:24, speculation [11] - 1272:6, 1262:2,1262:17, steam [1] -1267:35SNOOK'S [1] - 1323:44 1320:25,1357:18, 1273:36, 1290:4, 1266:18,1268:26, steaming [3] - 1234:47,Snook's [7] -1316:27, 1358:10 1311:37,1311:38, 1270:1,1297:16, 1253:45,1253:47

1318:17,1321:8, sources [13] - 1238:37, 1311 :39, 1327:20, 1298:40, 1307:8, Steedman [2] - 1239:6,1322:44,1323:3, 1242:33, 1244:26, 1327:21, 1330:5, 1307:15 1239:221324:3,1350:31 1245:10,1247:1, 1343:27,1357:21 stars [1] - 1247:24 STEEDMAN [1] - 1239:26

so-called [2] -1325:3, 1257:37,1259:1, Speculative [1] - 1275:5 start[15]-1243:12, steer [2] - 1258:18,1337:38 1266:24, 1267:5, speed [19] - 1233:20, 1243:14,1245:4, 1258:21

soldiers[1]-1276:10 1309:42, 1309:46, 1242:27,1243:18, 1247:43,1253:28, steering [6] - 1247:46,sole [1] -1284:29 1309:47,1310:1 1247:2,1247:47, 1260:18,1266:28, 1248:6,1258:13,solid [1] -1308:20 south[23]-1241:1, 1248:14,1249:33, 1268:33, 1293:9, 1258:15,1302:45,someone [10] -1244:31, 1241:4,1241:6, 1258:16,1258:22, 1312:33,1318:3, 1304:42

1245:43,1245:44, 1241:30,1241:33, 1258:25, 1258:40, 1327:36, 1353:28, stem[4]-1287:1,1287:4,1312:42,1320:36, 1241 :34, 1242:18, 1260:19,1266:23, 1359:20, 1359:23 1287:5,1289:11343:21,1344:36, 1242:34, 1243:3, 1266:26, 1266:29, started [1] -1253:16 stemmed[1]-1352:101349:21,1349:27, 1243:45,1244:27, 1266:44, 1268:9, starting [3] - 1250:31, stems[1]-1343:111350:6 1244:29, 1244:32, 1328:27,1328:31 1258:42,1267:13 stencilled [2] - 1276:24,

Someone [1] -1248:13 1246:8, 1303:45, speeds [1] - 1249:33 starts[2]-1241:44, 1320:23sometimes [7] - 1241 :46, 1303:47,1343:37 spend [3] - 1234:6, 1263:9 stencilling [1] - 1276:27

1244:41,1244:43, South[7]-1246:19, 1278:4,1278:14 state[14]-1233:20, step [5] -1234:15,1247:23,1264:46, 1256:17,1256:18, spends [1] -1236:3 1243:45,1243:47, 1235:24,1253:13,1265:41,1274:46 1326:40, 1354:20, spent [4] - 1235:18, 1244:3,1244:27, 1265:5, 1267:24

somewhat [3] - 1250:15, 1355:3,1355:17 1236:47,1255:46, 1244:35, 1268:24, steps [2] - 1240:33,1286:6,1300:26 south-east [1] - 1242:34 1278:28 1284:12,1284:46, 1352:30

Somewhere [2] -1285:40, south-easterly [3]- spoken [9] -1277:39, 1306:5, 1313:23, stern[7]-1251:31,1303:47 1241:30,1241:34, 1291 :2, 1291 :38, 1325:23, 1333:6, 1261:35,1268:17,

somewhere [15]- 1243:45 1295:43, 1298:9, 1338:28 1287:2,1287:4,1287:5,1243:38,1258:21, south-south-east [1]- 1333:11,1346:44, State [1] - 1278:29 1289:11260:11,1268:26, 1243:3 1346:45,1354:15 statement [23] - 1238:23, still [19] -1238:14,1285:14,1294:17, south-south-easterly [1]- spray [1] - 1245:24 1238:27,1238:29, 1246:14,1246:26,1300:30,1303:45, 1241:1 spread[1]-1247:14 1238:30, 1238:32, 1249:21, 1259:37,1304:41,1307:46, south-west [1] - 1244:27 spreading [1] - 1275:6 1238:37,1238:39, 1276:24, 1282:28,1308:43,1312:41, south-westerly [1]- spurious [1] -1273:45 1247:35,1251:36, 1282:47,1292:6,

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1296:6,1296:38, 1277:2, 1279:44, Sue[4]-1291:4,1291:21, 1338:24 1258:5, 1258:8,1300:22,1312:11, 1280:10,1280:18, 1291 :38, 1292:8 suppose [7] - 1257:42, 1258:12,1258:17,1323:16,1323:24, 1282:27,1290:45, suffered [1] - 1244:38 1260:35, 1290:5, 1259:1,1259:10,1327:13,1330:37, 1291:9,1291:11, suggest [14] - 1272:4, 1297:25, 1301 :46, 1259:24,1259:37,1334:3,1353:37 1291 :45, 1292:3, 1293:38, 1295:44, 1306:22, 1358:30 1259:39, 1259:41,

Still [1]-1280:17 1292:4,1292:7, 1299:23, 1309:45, supposed [5] - 1281 :34, 1260:10, 1260:21,Stokes [1] - 1240:44 1292:12,1292:15, 1314:3,1314:23, 1302:34, 1303:41, 1260:27,1261:1,

stop[1]-1350:46 1292:16,1292:37, 1317:32,1324:45, 1326:38, 1344:8 1261 :33, 1262:44,

stopped [1] -1259:9 1293:1,1294:7,1296:3, 1338:44, 1350:39, surely[1]-1334:41 1266:18,1266:25,

stories [2] - 1337:5, 1296:7,1296:13, 1356:34,1356:47, surface [5] - 1243:38, 1267:6,1267:27,

1337:8 1297:40,1297:47, 1357:35 1343:39, 1344:22, 1267:40, 1269:32,

Story [1] -1277:47 1299:9, 1299:21, suggested [3] - 1272: 11, 1344:23, 1344:24 1269:44, 1270:1,

story [39] - 1282: 14, 1299:24,1299:47, 1273:19,1351:45 SURFACE [3] - 1344:29, 1270:25, 1271 :36,

1283:5,1283:9, 1300:21, 1300:23, suggesting [5] - 1265:43, 1344:30 1271 :39, 1272:3,

1283:29,1284:21, 1300:28, 1301:4, 1301:41, 1324:20, Surface [2] - 1233:25, 1272:11,1272:16,

1287:1,1291:18, 1301:12,1301:17, 1329:37,1356:44 1257:9 1272:20, 1272:21,

1296:34,1298:33, 1301 :42, 1302:28, suitability [1] - 1239:31 surfaced [1] - 1282:7 1272:23, 1272:24,

1311:42,1311:43, 1302:34, 1302:44, sum [1] - 1260:2 surrendered [1] - 1279:28 1272:26, 1272:29,

1314:28,1314:35, 1303:6,1303:14, Summation [1] - 1302:8 surrendering [2] - 1277:8, 1272:46, 1273:5,

1315:44,1318:10, 1303:34, 1303:39, summons [1] - 1358:39 1335:20 1273:24, 1273:25,

1325:47,1326:33, 1304:28, 1304:31, sun [42] - 1233:21, 1246:4, surveying [1] - 1288:32 1273:34,1273:37,

1331:28,1331:31, 1304:39, 1304:42, 1246:13,1246:23, surviving [4] - 1244:37, 1274:2, 1274:9,

1331:36,1334:13, 1304:44, 1304:46, 1246:40, 1246:43, 1276:47,1279:29, 1274:11,1274:13,

1334:45,1336:13, 1305:10,1307:20, 1247:1,1247:2,1247:4, 1282:6 1274:22, 1274:32,

1336: 14, 1336: 16, 1307:35, 1307:36, 1247:7,1247:22, survivor [5] - 1276:32, 1274:36, 1274:39,

1336:37,1336:39, 1307:43, 1307:45, 1249:17,1249:23, 1282:13,1282:27, 1275:3,1275:15,

1336:40,1336:42, 1308:4, 1308:8, 1250:9,1250:13, 1328:24,1355:31 1276:21, 1276:23,

1336:47,1339:42, 1308:13,1308:19, 1250:15,1250:17, survivors [7] - 1252: 13, 1276:24, 1276:26,

1339:43,1339:46, 1311:15,1311:16, 1250:22, 1251 :8, 1272:25,1273:15, 1276:27,1276:34,

1340:5,1343:14, 1312:29,1312:33, 1251 :9, 1251 :13, 1273:44, 1277:39, 1276:39, 1276:42,

1349:24,1354:33, 1328:37,1357:32, 1251 :14, 1251 :25, 1279:36,1287:2 1277:2, 1277:6,

1354:41 1358:8,1358:18 1262:21, 1262:23, suspect [4] -1292:6, 1277:10,1277:22,

STORY[I]-1283:18 SUBMARINER [1]- 1262:24, 1262:25, 1301:9,1301:11, 1278:29,1281:43,

Straat [2] - 1277:5, 1283:18 1263:6, 1263:11, 1349:41 1282:29,1283:13,

1308:47 Submariner [1] - 1277:47 1267:15,1267:18, suspected [4] - 1235:41,1283:40,1283:47,

straight [2]-1258:13, submariner [1] - 1278:2 1268:23, 1268:25, 1263:30,1286:37, 1284:13,1285:25,

1313:2 submarines [11]- 1268:29,1268:37, 1302:91285:33, 1285:36,

Strait [1] - 1329:24 1301:13,1301:14, 1268:43, 1268:44, Suspects[1]-1263:281285:37,1286:33,

Street [1] - 1232:30 1302:10,1302:11, 1269:1 Suspects" [1] - 1263:231288:34, 1290:45,

strict [1] - 1282:43 1302:12,1302:17, sun" [1] - 1265:3 suspicion [1] -1277:191291:17,1291:28,

strike [1] - 1306:28 1303:40, 1304:33, Sunda [1] - 1329:23 suspicious [1] - 1277:61291:31,1291:32,

strong [2]-1245:32, 1307:39,1307:47, sunk [5] - 1290:45, Swan [2] - 1254:8,1291:35,1291:39,

1311:46 1308:4 1301 :30, 1325:36, 1254:201291:47,1292:3,

struck [5] -1277:10, submission [1] - 1238:25 1332:27,1335:44 swell [17] -1243:34,1292:17,1292:22,

1279:34,1282:1, submissions [1] - 1271 :31 sunset [10] - 1233:21,1292:29, 1292:42,

1243:35,1243:37, 1293:11,1293:12,1298:42,1299:31 submit [1] - 1276: 12 1243:24, 1246:5, 1243:40, 1244:8,

structure [1] -1259:20 SUBMITTED[I]-1358:33 1246:11, 1246:38, 1244:11,1244:12,1293:15,1293:23,

structures [1] - 1252:27 submitted [3] - 1233:18, 1246:43,1247:4, 1244:15,1244:19,1293:30, 1293:34,

struggle [1] -1246:27 1283:9,1284:12 1249:20, 1257:31, 1293:35,1293:47,1244:20, 1244:22,

studied [1]-1344:2 subscribe [2] - 1285:42, 1267:8 1244:23,1244:27,1294:8,1294:18,

studies[5]-1239:1, 1286:4 superior [1] - 1324:3 1244:31, 1244:39,1294:22, 1295:21,

subscribed [2] - 1301 :45, superstructure [3] -1295:29, 1296:2,

1239:5,1239:31, 1258:30, 1259:201352:1 1249:27,1252:29,

1296:26,1297:7,1239:33, 1278: 11 Swell [1] - 1257:26 1297:15,1297:27,

study[2]-1241:26, Subsequent [1] - 1254:43 1261:16 sworn [4] -1233:42, 1298:1,1299:31,1242:29 subsequently [5]- supervision [1] - 1255:42 1253:5, 1284:42, 1348:8 1299:37,1300:16,

STUDY[I]-1239:9 1274:18,1291:13, support [12] - 1302:27, SYDNEY[2]-1232:18,1291 :16, 1297:32, 1303:13,1303:34,

1301 :30, 1302:29,style [1] - 1280:33 1279:12 1303:35, 1304:29,sub[1]-1234:11 1346:44 1304:44, 1309:32, Sydney [207] - 1232:30, 1304:32, 1304:45,sub-majored [1] - 1234:11 Subsequently [1]- 1329:5, 1330:46, 1235:13,1244:35, 1307:28, 1307:30,Subiaco [1] -1276:18 1315:18 1336:44, 1340:6, 1244:42,1246:7, 1308:14,1310:14,subject [7] - 1265:27, subspecialist [2]- 1349:46, 1350:39, 1248:47,1249:5, 1310:16,1310:34,

1276:30,1277:18, 1253:17,1254:40 1357:1 1249:9,1249:12, 1310:38,1311:18,1278:31,1323:24, substance [1] - 1283:23 supported [1] - 1275:14 1249:15,1249:38, 1312:24, 1312:38,1355:5,1359:13 substantive [1] - 1286:31 supporting [2] - 1304:27, 1250:10,1251:21, 1312:43,1312:46,

SUBJECT[I]-1265:31 succession [2] - 1263:18, 1330:9 1251 :23, 1252:13, 1313:4,1313:10,submarine [68] - 1273:5, 1298:39 supports [4] - 1302:32, 1257:38,1257:39, 1313:32,1314:36,

1273:6,1273:20, suddenly [1] - 1279:34 1302:33, 1331 :28, 1257:41,1257:43, 1315:16,1315:17,

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TRAN.022.0155_R

27,19/1/09 (22)

1315:22,1316:4, tanker[3]-1291:15, 1317:7,1317:18, 1358:2, 1358:29, ticket [6] -1235:4,1235:8,1316:8,1316:27, 1292:11,1292:14 1317:21,1317:24 1359:1, 1359:9, 1235:10,1253:40,1316:33,1316:42, tape [2] -1325:4,1325:16 terrific [1] - 1298:43 1359:16,1359:18, 1254:6,1254:191318:18,1318:32, target [14] - 1259:28, terrorism [1] - 1287:42 1359:20, 1359:25, tide[2]-1317:2,1344:471319:26,1320:26, 1259:30, 1259:46, test [1] - 1335:29 1359:27 tideS[1]-1339:171325:12,1325:21, 1260:6, 1268:44, testimony [2] - 1348:8, theirs[1]-1296:15 tied[1]-1241:221325:25,1325:36, 1268:45, 1281 :44, 1355:32 theme[1]-1272:17 timber [1] - 1340:71327:22,1327:29, 1327:18,1327:32, text [1] - 1284:8 themselves [6] - 1240:28, timing [2] - 1267:4,1328: 12, 1328: 19, 1328:9,1328:16, thanked[1]-1316:23 1249:24, 1249:29, 1267:141329:18,1329:23, 1328:35, 1328:40 THE[124]-1232:18, 1250:16,1259:14, Timor[1] - 1238:101329:37,1329:43, targets [1] -1327:33 1239:10,1239:13, 1267:42 tiresome [1] - 1263:371329:44,1330:14, task [4] - 1255:7, 1255:9, 1239:15,1239:25, theories [12] - 1271 :32, TITLE [1] - 1263:471330:15,1330:41, 1257:12,1278:33 1242:5, 1242:43, 1271 :35, 1272:34, TO [3] - 1323:43, 1337:33,1332:35,1333:1, Task [2] - 1233:25, 1257:9 1243:23, 1244:34, 1273:44,1275:7, 1359:281333:8,1333:12, tasked [1] - 1256:45 1245:36, 1248:20, 1275:11,1275:47, Tobruk [1] - 1254:201333:24,1333:38, taskS[1]-1256:37 1248:33,1249:19, 1276:5,1276:15, today [8] - 1233:4, 1233:6,1334:29,1334:38, Tatura[1] - 1272:40 1249:47,1250:36, 1284:32, 1285:43 1239:47,1271:29,1334:41,1334:47, taught [4] - 1236:40, 1250:44, 1251 :3, theorist [2] - 1273:24, 1284:39,1345:7,1335:11,1335:19, 1237:5, 1241 :13, 1252:11, 1252:32, 1338:24 1358:44, 1359:41335:36,1338:26, 1253:25 1252:42, 1252:46, theorists [6] - 1259:8, today'S[1]-1233:381339:28,1339:31, tea [1] - 1308:28 1253:1, 1258:2, 1272:1, 1273:46, together[4]-1283:6,1339:38,1344:38, teacher [1] - 1278:41 1261:10,1263:47, 1275:42, 1277:25, 1283:13,1311:32,1354:42,1355:31, Team [1] - 1235:21 1264:4,1265:16, 1277:40 1312:291356:3,1356:7, team [6] - 1235:29, 1265:26, 1265:30, theory[18]-1236:33, Tokyo [1] - 1308:271356:39,1356:44 1236:5, 1256:40, 1265:31, 1266:2, 1237:4, 1240:46, Tom [1] - 1275:36

Sydney's[11]-1245:10, 1256:42,1277:14, 1266:42, 1269:24, 1259:7,1273:26, tomorroW[2] - 1271 :29,1262:38,1267:26,

1351 :38 1270:11, 1270:36, 1274:1,1277:27, 1359:201268:25,1276:47, teams [1] -1256:29 1270:41, 1270:45, 1291:1,1291:2,1301:3, took [13] - 1255:3,1291:10,1293:43, Technology [1] - 1287:9 1271 :6, 1271 :16, 1302:27,1302:32, 1255:26, 1256:4,1316:1,1330:35,

television [1] - 1285:21 1271 :18, 1271 :20, 1303:13,1303:34, 1256:5,1274:1,1331:43,1335:41

temp[2]-1317:1 1271 :24, 1279:12, 1305:4,1343:11, 1278:12,1279:33,Sydney-based [1]-

TEMPERATURE[I]- 1283:15,1283:18, 1343:45, 1344:42 1290:41,1297:19,1235: 13

1344:30 1285:28, 1286:21, Therefore [2] - 1301 :30, 1318:35,1318:45,Sydney-stencilled [1]-

temperature [3] - 1240:1, 1288:16,1290:36, 1319:3 1348:30, 1356:251276:24

1240:3, 1344:24 1291:1,1292:40, therefore [5] - 1268:8, tooth [17] - 1340:8,Sydney/Kormoran [2] -

TEMPLATE[I]-1250:41 1293:18,1296:17, 1268:14,1292:44, 1341:7,1341:31,1233:9,1280:24

template [8] - 1242:15,1298:17,1298:22, 1320:8, 1327:29 1341:33,1341:37,

synoptic [2] - 1240: 19,1242:16,1243:17,

1299:13,1300:14, thinking [1] - 1317:25 1341 :45, 1342:4,1241:32

1247:45,1257:20, 1300:34, 1301 :16, third [10] - 1242:46, 1342:6, 1342:8,system[5]-1241:43,

1257:23, 1262:30,1302:15,1302:17, 1305:42, 1313:23, 1342:21, 1343:8,

1242:37,1245:16,1266:20

1302:40,1302:47, 1317:8,1317:10, 1345:4, 1345:8,1245:29,1245:32

temptation [2] - 1263:36,1304:15,1304:35, 1317:15,1317:38, 1345:32, 1346:40,

1264:221306:33,1309:14, 1317:43,1324:29, 1346:41,1347:11

T Ten [1] - 1280:341310:6,1312:20, 1357:43 top [9] - 1244:39, 1269:34,

tend [4] - 1258:32,1313:20,1314:14, third-last [1] - 1357:43 1269:38,1290:7,

1259:14,1311:42,1314:38,1315:33, thirst [1] -1278:27 1309:14,1316:15,T1261 [1] -1269:19 1317:23,1318:2, thirty [1] - 1323:6 1345:37,1349:7,1350:27table[I]-1242:40 1319:10,1319:16, threat [1] - 1277:6 1351:12Tactical [1] -1263:24 tended [1] - 1271 :431320:10,1320:30, three [27] - 1280:31,tender [13] - 1238:32, topic [1] - 1317:29tactical [8] - 1233:11, 1320:36, 1320:39, 1292:29, 1292:36, torn [5] - 1295:30,1239:4, 1239:21,1233:30,1233:35, 1323:24, 1323:29, 1292:45, 1293:43, 1295:33,1295:37,1250:38, 1263:44,1257:10,1258:33, 1323:34, 1323:39, 1297:12,1297:16, 1295:40, 1297:281265:11, 1266:8,1259:31,1260:17, 1325:2, 1327:9, 1297:24, 1297:32, torpedo [20] - 1272:41,1267:42 1273:7,1284:25,1327:20, 1327:41,

1323:17,1323:22, 1298:23, 1298:38, 1272:47,1274:13,tactically [1] -1265:45 1328:2, 1328:21, 1299:31, 1299:36, 1277:10,1279:35,Takahashi [6] - 1278:9, 1326:47,1337:31 1329:30,1331:31, 1299:41, 1299:46,tendered [3] - 1287:8, 1281:44,1281:46,1280:7,1280:43, 1333:23, 1337:8, 1300:4,1300:16,1337:19,1344:41 1292:44, 1293:36,1282:44,1283:7, 1337:33,1338:19, 1300:20, 1305:45, 1293:47,1295:22,1283:23 tendering [1] - 1271:4 1338:21, 1338:36, 1306:44,1307:7, 1295:29, 1295:36,talks [1] -1335:20 tends [1] - 1268:33 1339:14,1340:39, 1307:14,1307:28, 1295:45, 1296:2,tally [1] - 1355:8 term [3] - 1254:15, 1341 :18, 1342:20, 1307:30, 1312:25, 1296:5,1296:19,tampered [1] -1273:8 1339:47,1346:44 1343:3,1343:10, 1341:25 1307:33, 1328:36,tandem [2] - 1357:32, terms [8] - 1242:38, 1344:19,1344:45, Three [3] - 1234:7, 1328:39

1358: 18 1243:35, 1261 :40, 1346:39,1349:7, 1274:12,1300:5 torpedo-powered [1]-1266:30,1267:19,Tanglin[4]-1331:9, 1349:19,1350:45, throughout [3] - 1242:5, 1272:471331:12,1332:10, 1268:46, 1275:34, 1354:22, 1354:36, 1253:27,1277:371322:15 torpedoed [2] - 1293:35,

1337:38 1355:20, 1355:45, thumb [1] - 1263:7 1294:8terrible [5] - 1317:5,

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TRAN.022.0156_R

torpedoes [9] - 1305:2, 1254:30, 1254:31, 1281:4,1313:1 underneath [4] - 1293: 10, 1265:34, 1266:20,1305:18,1306:44, 1254:33, 1254:35, turning [1] - 1299:34 1293:11,1293:47, 1268:23, 1268:37,1306:45,1307:7, 1255:13, 1255:22, turret [1] -1294:1 1306:40 1269:14, 1269:28,1307:9,1307:14, 1255:30, 1256:2, 1V[2]-1262:41,1262:43 understood [3] - 1321 :41, 1269:38, 1273:9,1307:28,1307:30 1256:28, 1256:30, TwentY[I]-1288:41 1321 :45, 1354:40 1273:26, 1273:28,

torpedos [30] - 1292:29, 1256:31, 1256:47, twilight[3]-1246:12, undertake [1] -1238:5 1274:1,1275:39,1292:36,1293:30, 1257:2 1246:20, 1246:24 undertaken [1] - 1283:21 1275:44,1276:7,1293:31,1293:34, Training [7] - 1235:21, two [37] -1233:1,1233:7, undertaking [1] - 1321:5 1277:22,1278:12,

1293:43,1294:18, 1237:8,1237:10, 1236:32, 1237:26, underwater [2] - 1272:41, 1279:5, 1284:22,1295:12,1296:22, 1237:24, 1256:26, 1238:47,1239:41, 1277:11 1289:16,1293:10,1296:24,1296:25, 1256:27,1256:36 1242:1, 1245:30, undoubtedly [1] - 1293:1 1294:31, 1294:32,1297:7,1297:12, transcript [3] - 1325:17, 1254:46, 1259:26, unearthed [1] - 1278:43 1294:44, 1295:1,1297:16,1297:24, 1326:2, 1345:28 1260:9, 1261 :7, unequivocal [1] - 1274:33 1295:5,1298:13,1297:27,1297:32, transhipped [1] - 1324:35 1262:46,1267:15, unfamiliar[1]-1251:47 1298:20, 1302:22,1297:44,1297:47, transited [1] - 1236:46 1270:32, 1274:29, unforgiveable [1]-

1302:40, 1304:29,

1298:23,1298:39, translate [1] - 1278:39 1275:5, 1279:20, 1289:45 1307:45,1309:19,1299:31,1299:33, translation [1] - 1278:45 1281:39,1289:27, Unfortunately [1] -1237:2 1309:20, 1309:21,1299:36,1299:39, transmission [2]- 1291 :22, 1296:18, unfounded [1] - 1272:5 1309:24, 1310:14,1299:41,1299:46, 1332:36, 1333:3 1299:35, 1299:39, ungrounded [1] -1327:20 1313:9,1315:46,

1300:16,1300:20, transmit [1] - 1333:1 1304:40,1304:47, Unique [1] -1277:47 1317:23, 1317:24,

1300:30 transparent [3] - 1249:22, 1309:6,1311:2,1311:6, UNIQUE[I]-1283:181318:11,1322:6,

Total [1] - 1247:25 1250:17,1250:18 1312:2,1312:5, unit [11] - 1233:28,1322:45,1323:13,

total [2]-1246:30, travelling [4] - 1242:21, 1314:40,1323:16, 1235:8, 1254:9,1324:27,1326:33,

1283:29 1242:27,1243:39, 1340:27,1343:37, 1254:19,1255:33,1328:19,1329:8,

totality [1] -1289:4 1276:37 1358:36 1256:3,1256:7,1342:29, 1343:21,

totally[I]-1329:28 TRH [1] - 1232:25 TWO[3]-1308:25, 1256:15,1256:24,1347:39, 1349:23,

touch [3] - 1346:6, trialled [1] - 1236:45 1333:19,1341:24 1349:32, 1349:401349:26, 1349:31,

1350:19,1354:36 tried [2] - 1267:29, type [3] - 1245:33, United [2] - 1273:28,1349:37,1350:36

Tourist [1] - 1278:13 1339:21 1256:10,1305:7 1282:17up-sun [3] - 1262:24,

tourist [1] - 1278:21 troop [1] - 1308:36 typed [2] - 1238:24, university [1] - 1278:111268:23, 1268:37

tours [1] -1346:43 troops[1]-1238:10 1276:47 unknown [2] - 1324:5,update [1] - 1255:38

towards [15] -1242:22, trouble [2] - 1302:38, types[I]-1333:11 1339:22UPON[I]-1301:1

1247:2,1249:15, 1311:24 typescript[2]-1277:1, UnleSS[1]-1311:11upper[4]-1243:10,

1251:13,1255:28, trough [5] - 1241 :44, 1277:13 unless [6] - 1252:24,1243:11,1243:14,

1258:18,1260:5, 1242:7,1242:8,1244:5, typical [1] - 1340:37 1266:37,1312:45,1243:19

1263: 15, 1266: 16, 1244:41 typically [1] - 1280:32 1329:47,1346:32,urging [1] - 1280:36

1268:44,1276:3, true [7] - 1238:28, tyre [1] - 1340:23 1353:31USA[I]-1273:28

1279:31,1313:2, 1242:19,1281:18, unlike[1]-1261:33useful [2] - 1238:43,

1313:9,1344:17 1283:2, 1337:9, U unlikely[2]-1279:43,1241:19

towing [1] -1236:41 1351 :23, 1351 :24 1327:28usual [2] - 1332:43,

town [1] -1239:47 trust[1]-1316:40 unpalatable [1] - 1289:41 1342:23

Townsville [3] - 1235:3, trusted[1]-1316:40U-boat[I]-1311:17 utter[1] - 1335:46

unreasonable [3] -1235:17,1235:33 truth [17] - 1272:2,

UKAA,002,0036 [1]-1329:22,1329:27,

track [2] - 1267:38, 1268:3 1283:34, 1289:41,1263:21 V1329:28

Trade [1] - 1275:40 1289:46, 1290:3,UKAA,002,0043 [1]-

untenable [1] - 1334: 131263:46trail [1] - 1297:26 1290:28, 1290:32, untrue[1]-1334:13 vacuum [1] - 1275:1UKAA,010,0084 [1]-train [3] - 1234:18, 1290:44,1300:19, untruth [3] - 1296:38, Vaguely[1]-1316:131264:81236:32,1256:32 1307:25, 1311 :39, 1296:39, 1307:24 valid[1]-1241:20ultimate [2] - 1302:28,trainees [1] - 1237: 11 1316:33,1316:34, untruthful [1] - 1317:33 validity [1] - 1275:261311:18trainees' [1] - 1237:15 1330:38,1349:14, unusual [1] - 1313:28 valuable [2] - 1308:44training [48] - 1234:3, 1349:22 unable [1] -1283:40

unaccompanied [1]-unusualness [1] - 1306:28 values[1]-1240:15

1234: 15, 1234: 19, try [9] - 1237:14, 1240:12,1313:2 up [90] - 1234:18, 1235:20, van [8] - 1238:46, 1239:5,

1234:22,1234:33, 1240:15,1251:15, 1236:32, 1238:24, 1239:7,1239:28,1234:41,1235:7, 1258:25, 1258:40, Unaware [1] - 1299:37

1240:43, 1242:24, 1239:41, 1240:33,1235:20,1235:24, 1259:17,1268:9,1272:2 unaware [2] - 1296:43,

1299:381242:40,1244:12, 1241 :26, 1243:20

1235:25,1235:30, trying[10]-1259:37, 1244:40, 1244:43, VAN [1]-1239:111235:42,1235:43, 1260:8, 1262:40, under [17] - 1253:23,

1266:15,1267:47,1245:44, 1247:4, vanished [1] - 1338:26

1236:6,1236:10, 1266:30,1267:27,1272:37,1276:34, 1255:4, 1255:31, variance [2] - 1240:24,1236:47,1237:4, 1268:47,1270:12,1277:3, 1277:5, 1255:32,1256:16, 1241 :61237:25,1237:26, 1305:6, 1340:9, 1346:37 1256:18,1257:20,

1237:42,1241:13, tube [1] - 1277:11 1279:40, 1282:43, varied [1] - 1254:37

1284:19,1313:3, 1257:23, 1259:25, varies [1] - 1298:351253: 13, 1253: 14, TUESDAY[I]-1359:28 1260:2, 1261 :7, 1261 :8,1253:15,1253:17, turn [5] - 1260:16, 1315:10,1321:31, VARIOUS[I]-1271:10

1335:36, 1340:31, 1261:18,1261:21, various [5] - 1234:17,1253:18,1253:22, 1268:20, 1278:25, 1261 :26, 1262:24,1253:28,1253:38, 1279:8,1313:22 1341:38,1342:15 1235:7,1271:7,1332:5,

1262:30,1263:18,1253:39,1254:13, turned [5] - 1247:1, Under [1] - 1299:5 1339:21

1263:21, 1264:8,1254:18,1254:28, 1257:40, 1268:2, underlying [1] - 1274:43

1265:3, 1265:21,vector[5]-1248:1,

,19/1/09 (22) 28Transcripl produced by Merrill Legal Solulions

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TRAN.022.0157 R

29,19/1/09 (22)

1248:11,1249:7, visit [1] - 1335:39 warship [7] - 1277:8, 1257:14, 1257:16, 1339:91249:10,1249:40 visited [1] - 1283:39 1306:1,1306:16, 1257:18, 1258:29, whilst [4] - 1235:36,

vein [1] -1358:21 visual [8] - 1236:12, 1329:35, 1329:40, 1259:13, 1259:17, 1237:35,1255:2,velocity [6] - 1234:25, 1247:33,1263:33, 1329:42, 1332:27 1259:34,1260:16, 1266:15

1236:37,1243:30, 1263:37,1267:12, warships [2] - 1252:5, 1263:4, 1263:5, white[4]-1243:13,1248:12,1248:39, 1268:39, 1268:46, 1265:44 1266:13,1266:20, 1243:14,1259:101258: 15 1297:43 wartime [1] -1276:44 1267:4, 1268:21, WHO[I]-1279:12

verbatim [1] - 1325:22 visually[1]-1268:4 Warwick [1] - 1285:4 1275:32, 1280:38 whole [6] - 1256:29,versus [1] - 1246:40 vital [1] - 1280:39 WAS[I]-1359:27 weather-related [1]- 1256:47,1265:43,vessel [32] -1235:16, Vladivostok [1] - 1256:19 washed [1] -1349:31 1233:17 1271:39,1279:15,

1235:23,1235:32, vocal [1]-1332:20 waste[1]-1311:13 website [5] - 1288:42, 1334:451235:42,1245:40, VOiCe[9]-1312:24, Watch [7] - 1234:20, 1288:45,1344:12, widow[1]-1326:391247:33,1254:6, 1332:21, 1332:23, 1234:23,1234:27, 1344:22 willingly [1] - 1278:461255:31,1255:32, 1333:8,1333:13, 1234:42, 1253:20, WEBSITE[I]-1344:28 wind[57]-1233:20,1259:16,1259:28, 1333:17,1333:25, 1253:41, 1254:8 week [10] -1287:8, 1239:38, 1240:2,1259:30,1259:46, 1333:38, 1336:27 watCh[14]-1235:11, 1289:27,1296:45, 1240:30, 1240:40,1260:6,1264:24, volume [1] - 1269:35 1235:12,1236:1, 1316:44,1317:8, 1241:1,1241:2,1266:16,1267:27, 1236:3, 1248:43, 1317:10,1317:15, 1241:14,1241:15,1267:38,1268:1, W 1254:4, 1254:5, 1317:38,1317:43, 1241:19,1241:30,1268:4,1268:7, 1254:21, 1254:24, 1351:4 1241 :34, 1242:14,1268:31,1268:32, 1254:32, 1255:2, week's [1] - 1343:28 1242:15,1242:18,1268:40,1268:44, W,A[I]-1239:18 1255:43, 1304:40, weeks [9] - 1279:20, 1242:21, 1242:23,1268:45,1269:3, WA [4] - 1233:28, 1238:22, 1351 :30 1280:31,1281:2, 1242:27,1242:33,1279:15,1279:32, 1241:41,1256:7 watch-keeper [2] - 1236:1, 1291 :22, 1334:31, 1242:37,1243:1,1281:47,1282:5 WA-based [2] - 1233:28, 1236:3 1334:42,1340:27, 1243:3,1243:7,

Vessel [1] - 1256:25 1256:7 Watch-Keeping [7] - 1341:24,1341:25 1243:10,1243:18,vessels [5] -1234:34, wait [2] -1273:14,1328:12 1234:20, 1234:23, well-aimed [2] -1279:35, 1243:24, 1243:26,

1236:43,1266:4, waiting[1]-1328:18 1234:27,1234:42, 1281:44 1243:36,1243:37,1267:34,1280:3 Wales [2] - 1305: 1, 1253:20, 1253:41, well-known [1] - 1291 :3 1243:44,1244:10,

via[3]-1274:27,1285:4, 1326:40 1254:8 Wenneker [4] - 1308:26, 1245:24, 1247:44,1338:39 walk[I]-1332:9 watch-keeping [2]- 1308:29,1309:7, 1248:5,1248:7,1248:9,

Vic[2]-1339:43,1354:29 walked [1] - 1287:6 1235:11,1254:32 1327:39 1248:15,1248:18,video [2] -1289:10, War [16] - 1252:4, watches [2] -1237:12 West [7] - 1256:5, 1248:35, 1248:44,

1318:30 1252:36, 1256:25, water [13] - 1243:36, 1256:15,1274:35, 1248:46, 1252:20,

view[27]-1241:25, 1263:19,1269:29, 1243:38, 1244:43, 1310:34,1344:17, 1252:23, 1252:24,

1244:28,1245:12, 1269:36, 1275:2, 1253:18,1253:43, 1357:33,1358:19 1257:25,1257:28,

1246:36,1247:3, 1276:35,1277:14, 1254:41, 1259:9, weSt[13]-1241:4, 1257:32,1257:35,

1260:33,1260:43, 1277:38, 1278:1, 1260:15,1266:46, 1244:27,1246:9, 1259:20, 1260:20,

1261:15,1261:19, 1278:20,1278:27, 1272:46, 1274:22, 1302:18,1302:34, 1260:34, 1271:4,

1261:33,1261:47, 1278:43, 1282:23, 1317:1,1339:10 1302:45, 1303:6, 1344:43

1264:30,1269:41, 1323:3 Water [1] - 1255:2 1303:15,1303:40, Wind [1] - 1257:26

1269:43,1287:20, WAR[I]-1283:18 waterline[1]-1244:43 1303:43, 1304:25, wind-blown [1] - 1245:24

1292:42,1295:28, war [14] -1235:16, waters [5] - 1256: 12, 1304:42,1357:9 window[1] - 1291:91297:45,1300:11, 1235:23, 1235:32, 1256:18,1256:19, WEST[I] -1239:18 Winds [3] - 1337:38,1301:17,1306:3, 1254:5, 1255:31, 1274:2, 1335:37 westerly [1] - 1244:29 1338:4, 1338:111306:7,1327:13, 1255:32, 1278:23, waterways [1] -1256:13 Western[30]-1233:31, winds [3] - 1241 :22,1333:23,1333:24, 1280:19,1280:40, Watson [4] - 1234:17, 1235:5, 1239:35, 1258:30, 1344:421334:5,1351:1 1281:7,1282:17, 1237:8, 1254:33, 1242:3, 1256:4, Winter [1] - 1273:33

VIEW[I]-1239:26 1334:28, 1335:22, 1255:16 1256:15,1272:16, wireless [1] -1336:34viewed [2] - 1281 :26, 1335:24 wave [3] - 1243:38, 1273:23, 1274:3, wiser [1] - 1281 :46

1284:9 warfare[16]-1234:16, 1244:5, 1244:40 1274:6,1274:18, wish[1]-1313:16viewing[3]-1251:10, 1235:30, 1235:44, waves[1]-1243:15 1274:23, 1274:25, wished [1] -1355:7

1251:22,1288:38 1236:7,1236:10, wearing [2] - 1276:24, 1275:29, 1276:5, wishes [1] - 1264:26viewpoint [1] - 1277:43 1253:17,1253:18, 1325:24 1279:16,1281:19, WIT,024,0001 [1]-

views [8] -1247:36, 1254:32, 1254:35, WEATHER[2]-1239:9, 1291 :3, 1304:9, 1283:431265:8,1286:12, 1254:38, 1254:41,

1239:17 1310:37,1313:18, WIT,024,0003 [1] - 1278:51286:26,1286:28, 1254:45,1255:7, weather [37] - 1233:8, 1339:10,1339:41, WITH [2] - 1250:41,1286:31,1288:44, 1255:21, 1257:10, 1233:10,1233:17, 1339:43,1347:18, 1265:311295:43 1272:22 1233:30, 1233:34, 1347:19,1349:26, withdraw[1]-1335:26

visibility [9] -1244:46, Warfare [4] - 1237:9, 1237:13,1238:8, 1349:31, 1353:22 WITHDREW[3]-1253:1,1244:47,1245:12, 1254:45, 1255:3, 1238:9, 1238:21, whatsoever [1] - 1338:6 1271:18,1359:181245:17,1245:25, 1255:17 1238:43, 1239:1, Wheatvale [1] - 1285:4 WITNESS[7]-1253:1,1247:28,1252:26, warn [1] - 1359:3 1241:38,1241:39, whereabouts [2] - 1270:45,1271:18,1263:41 warning [1] - 1358:44 1241:40,1242:1, 1256:11,1302:9 1302:17,1320:39,

visible [3] - 1249:15, Warrandyte [1] - 1276:37 1242:12,1242:17, Whereas [1] - 1300:3 1338:21, 1359:181250:45,1252:40 WARREN [1] - 1253:5 1243:35, 1245:1, whereas [1] - 1243:37 witness [5] - 1253:33,

vision [1] - 1262:6 Warren [1] - 1233:24 1245:36,1247:43, Whilst [2] - 1261: 10, 1281:20,1281:22,

Transcripl produced by Merrill Legal Solulions

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1284:38,1306:29 1293:41, 1294:28, Zone [1] - 1235:39witnesses [4] - 1233:2, 1294:29, 1298:22, zone [2] - 1246:40,

1233:4,1296:23, 1298:25, 1305:43, 1334:441296:30 1308:42, 1318:8, zoom [1] - 1269:33

Wittwer [8] - 1299:15, 1318:25, 1318:32, Zuytdorp [3] - 1274:5,1354:4,1354:6,1354:7, 1318:33, 1333:35, 1274:31, 1352:301354:9,1354:10, 1337:14, 1343:1,

1354:39 1354:25,1358:15

woman [4] - 1278:10, wrought [1] - 1272:45

1354: 14, 1354: 19,1354:34 X

won[1]-1281:33

wonder [1] - 1298:28X's[2]-1355:32, 1355:37

Wong [3] - 1291 :4,1291:38,1292:8

XO [1] - 1256:3

wooden [2] -1276:43,Y1287:22

WOrd[3]-1311:7,1325:22,1333:44 yadda[3]-1318:40

WOrdS[7]-1281:16, yards [9] - 1248:41,1309:29,1334:4, 1251:44,1261:41,1336:5,1336:13, 1263:16, 1269:21,1336: 14, 1336: 16 1270:30, 1270:33,

works [3] -1248:10, 1270:38, 1270:461284:4,1312:1 Year[1]-1278:18

world [5] -1244:32, year[16]-1234:24,1256:13,1256:21, 1235:18,1242:5,1289:43,1291:16 1242:6, 1244:23,

World[5]-1252:4, 1254:38, 1272:31,1263:19,1276:35, 1275:37,1278:17,1277:38,1323:3 1310:15,1317:47,

worthwhile [1] - 1301 :31 1322:46,1325:37,wounded [1] - 1273:24 1339:2, 1339:6, 1355:7WP[I]-1276:41 year-long [1] - 1254:38wreck [2] - 1286:35, yearS[26]-1234:7,

1292:42 1237:26,1240:16,wreckage [1] - 1282:19 1240:46,1254:37,wrecked [1] - 1276:34 1277:38,1278:10,wreckS[7]-1271:46, 1278:19,1282:35,

1273:42,1273:43, 1283:13,1285:26,1274:21,1274:29, 1286:7,1286:19,1275:46,1288:33 1308:6, 1311 :3,

write [7] - 1246:28, 1311 :25, 1322:23,1279:2,1293:39, 1322:27,1322:28,1305:8,1318:23, 1322:30, 1322:31,1336:8,1356:37 1323:6, 1323:30,

writer[4]-1285:8, 1332:2, 1346:5, 1351 :451285:28,1288:8, yeoman [4] - 1252:38,1329: 19 1261 :3, 1261 :20,

writerS[1]-1327:16 1261:43writing [8] - 1278:42, yesterday [2] - 1287:6,

1285:29,1286:19, 1355:351287:42,1289:31, yield [1] - 1241 :291309:36,1317:28, yielded [1] - 1290:91318:41 York [1] - 1358:5

written [19] -1238:24, young [4] - 1278:9,1266:2,1272:10, 1279:2, 1334:43, 1335:81276:10,1279:4, yourself [5] -1258:38,1280:27,1286:17, 1285:15,1287:32,1287:31,1287:36, 1326:3, 1354:441293:39,1310:16,1310:47,1320:5, Z1320:25,1326:4,1336:25,1337:15,1352:23,1357:46 Zealandia[4]-1313:1,

wrote [19] - 1243:23, 1313:6,1313:7,1313:12

1280:31,1286:7, zero [2] -1248:7,1248:29

TRAN.022.0158_R

.19/1/09 (22) 30Transcripl produced by Merrill Legal Solulions