Peggie v RCN: Day 5 – Tuesday 29 September

Live Tweets

Nurse Sandie Peggie’s claim against the Royal College of Nursing continues at the Dundee Employment Tribunal. Today – RCN witnesses, Stuart Fraser and Gillian Tait

226 tweets

Good morning and welcome to Dundee Employment tribunal for Day 5 of Peggie v RCN. Snappers are waiting…

Live tweets follow. Court is sitting.
J judge
SF – Stuart Fraser RCN Officer
NC – Naomi Cunningham, Sandie Peggie's barrister
SP – Sandie Peggie

NC good morning SF
SF morning
NC I had asked you yesterday about visiting SP's colleagues to talk to them. Please turn to p358 of the bundle.

[pls not that my tweets are summaries or characterisations of what is being said and happening in court. nothing I tweet is a direct quote unless it is in "direct quotes"]

NC that is a letter to you from Margaret Gribbon (MG) dated 16 April [MG is SP's lawyer]. MG asked you what discos you were having with management about men in women's facilities. You didn't respond to that did you
SF don't recall
NC you couldn't have that disco with management

because the RCN's position was the same as management's. That TWAW and therefore have the right to use women's facilities.
SF don't know if that was the position of the health board. Do know that there were discos at the partnership health forum that I don't sit on

NC so this was all happening above your pay grade
SF not above my pay grade it was happening at a forum which I was not part of
NC need to go back to yesterday – could you look at p321. Mr Hay (DH – RCN's advocate) – took you to this email which appears to have been sent to a

number rather than an email address. you said it was connected to an address but you didn't check to see if it was connected to an email and sent to SP
SF no
NC so you don't have any definite knowledge it went to SP
SF all corr would have been sent in the same way

NC but no other email from you has a number in a To line like that email – so do you accept SP's evidence that she didn't receive it is true
SF all emails are sent to the email assigned to the case number – it's just been pulled off this way

NC but you haven't checked it did go to the proper email
SF no
NC we talked yesterday a little bit about training – two points. First – what if any training you have had and the gist of it about the diff ways the law treats holding and manifesting a protected belief

SF learned about the Grainger criteria – 5 ways of difference between expressing something that would be warranted in a meaningful society
NC sorry could you speak up
SF I think it's worthy of respect in a democratic soc
NC no it's whether you've been trained in the way…

that a belief ticks all the Grainger boxes – so it is a protected belief, but the diff between holding a belief and manifesting it
SF yes we learned what is protected
NC can you give and eg

SF if you manifested a belief in a way that was unlawful or manifested that belief in a work environment – it still needs to be within the law and workplace envs
NC is that all you can remember from that training
SF off top of my head just now

NC so you can't manifest it in any way you like
SF in a nutshell yeah
NC to a lawyer that's interesting – you've explained the limits on a belief, but you said nothing about the positive protection that workers have for reasonable manifestation of belief – was that omitted

from your training
SF don't believe so
NC because whole way RCN – not just RCN – but the whole way it's been framed is on the limitations of protected belief does not emphasise the positive protections enjoyed by workers

SF I wouldn't be comfortable saying my recollection reps the view of the RCN
NC the tribunal has heard about some of the engagement sessions after the SC judgment. Have Anderson Strathern (AS – RCN lawyers), given you any training on what it means for defence of women's rights

SF I haven't but I had a substantial period of bereavement and I know there was some training whilst I was away
NC are you aware of subsequent For Women Scotland case which went to inner house but not to the SC
SF yes

NC were you trained on the implications from that
SF can't remember
NC you heard of it – can you remember what it was
SF male and female toilets
NC it was about quotas for male and female membres of public boards
SF ah I'm thinking of a diff case

NC so you weren't aware that that case put it beyond doubt that men without GRCs could not be treated as women for the purposes of the EA
SF [doesn't seem to know much about this]
NC [is talking about FWS1 – BEFORE the SC judgment] this was quite an important thing for trades

unionists to know, wasn't it?
SF potentially
NC I think I am write there is a series of events put on by RCN for local activists called activist academy
SF yes
NC what is it

SF in ref to what
NC you said we have an AA – what is it
SF my understanding of it – we have one in England where a series of academies about training reps and keeping them up to date in support and representation – 3 types – learning, stewards and health and safety reps

NC and they get together and do training
SF I would have thought so I have not been involved in this
NC can you go to the smallest supplementary bundle – p51 – a tweet from a Freda Wallace
SF think it's a BlueSky post

SF we don't call them tweets any more
NC let's call it a post. Its from someone called Freda Wallace – this is from an AA event at the London HQ
SF I don't know who FW is – I know we hired that space out – anyone can hire rooms at HQ – not sure it's an RCN event organised by

the college or a member.
NC look at the top right hand corner of the whiteboard
J was this an event you were present at
NC on its face can you agree this appears to be someone called FW appearing at an RCN event
SF it says RCN Education and Disc – so I can see why you'd say that

NC looks like FW is training nurses about discrimination
SF not sure it's an RCN event
SF people can hire that space and use it freely
NC any reason why you are keen to intro the idea this is nothing to do with RCN
SF don't believe FW is a member of staff
NC but it is

known he is a member.
NC and if you look at the subsequent pics – he's dressed quite demurely at the event, but in the other pics he is dressed less demurely, isn't he
SF yes
NC if what p51 implies is true – that FW has been invited to speak at RCN events about discrimination…

… then in the light of the pics and posts on pp41 – 50 that is a serious reputational risk for the RCN isn't it.
SF RCN can't police peoples SM
NC "looking at those posts do you agree he is a thoroughly unpleasant and menacing ind who RCN should not be willing to associated with publicly"

SF if they are a member and I don't know if they are I believe there's a code of conduct they have to adhere to
NC not saying this is a matter for you to implement – but surely someone like FW should be expelled before their feet touch the ground the moment these pics come to

their attn.
DH don't answer that q. Judge this has been put to SF and he's said this is not his area to judge
NC in the past the RCN has notoriously has a serious misogyny problem and these posts suggest they haven't dealt with it

RCN has had previously in v senior roles has been as openly misogynist and menacing as FW. Any trade union, RCN activist ought to be fully aware of RCN's historic misogyny problem and ought to be shocked to the core by this material and ought to distance themselves and their union and if there is hesitation and reluctance to do so this is highly probitive of their
J you are putting to him that he should be expelled and he is saying it is not his area – doesn't know who FW is or if they are member, so putting to this witness when we have other Ws coming who are more senior and might be able to answer this. Not sure where you can go with it with this W.
NC I was wondering why – when they claim to have solved the misogyny prob it seems difficult for members of the RCN to struggle with images like this and say they were shocked by…
J you didn't ask if he was shocked
NC [to SF] you are familiar with the RCN CoC?
SF yes
NC and the pics and posts on pp47- 50… turn back to p32

NC reads from RCN CoC – so if you saw behaviour that broke the code you would report it.
SF if I saw those posts and had said they were a member of the RCN I would raise it further
NC because thats not "a high standard of personal conduct"?
SF yes
NC because you agree this is not a high standard of personal conduct
SF I think there would be an investigation, yeah

NC a couple of qs about the suspension and review meeting p353 [presumably SP's S&R meeting]

NC these are your notes of that meeting
SF yes
NC SP had been emphatic in that meeting that she loved her job in A&E and didn't want to move
SF yes
NC notwithstanding that you tried to persuade her to move
SF wasn't trying to persuade – just wanted to explore and explain

the possible options if NHS Fife didn't want to lift the suspension from A&E.
NC this suggests you failed to see that SP was being treated shockingly for standing up for the rights of women and single sex spaces – you thought she was in the wrong

SF fact was she was under disc. and my thought was to try to protect her and put distance between the person there were problems with
NC the obvious way to deal with it was to get the man who was in her changing room moved
SF but she was under investigation for her alleged

behaviour
NC that's because you hadn't spotted that her behaviour was a manifestation of her protected belief.
SF that's not the words that were said – that was some of the words that was said [starts talkin about process]
NC your starting point as a union rep is surely

that what a member tells you is true
SF I have no reason to disbelieve, but not acting before getting the whole pic makes a lot of sense
NC but you hadn't spotted SP objecting to a man in the F CR was a manifestation of a protected belief
SF she's entitled to that view – it

wasn't what sparked the suspension. It was how those views manifested, potentially.
NC at this point the charges hadn't been spelled out at all.
SF no
NC so you should have gone on what she told you which was that men can't be women, she expressed that and it was a manifestation of her protected belief and you should have gone forward on the basis of discrimination
SF possible
NC and the reason you didn't was because you hadn't been trained about the positive protections provided by Higgs and Forstater
SF no I think if I had put in a request for a legal review I don't think it would have got passed the 51% test as we didn't have the full info
NC did you clock this was a developing area of law
SF I believe it still is, yes
NC that being so – didn't it make it urgent to get some legal info about this topical thorny area?

SF if they continued the extension of the suspension, if they were dismissed – there were a number of ways this case could play out…
NC so even if your member was suffering ongoing discrimination…
SF not saying that
NC DU (Dr Upton) hadn't done anything make the disc ongoing as she hadn't seen him since xmas eve…

SF [missed answer]
NC my point about time limits – no contact between SP and DU since xmas even, so no reason to think there would be extended limit for any claim against him
SF no
NC so if there was a claim against him – it's urgent urgent isn't
SF yes
NC and it didn't occur to you there might be a claim against him did it
SF no
NC and that's cos everything in the RCN's culture was about TW being W
SF not the culture – the guidance we were working of
NC is this the services and public functions practive
SF yes
NC gives the game away that – it's about servives and public functions – not workplaces
SF that's where the board was getting it's guidance
NC and you didn't suggest that DU should be moved to another place of work so SF could return to the jon she loved.
SF don't recall having that convo
NC perhaps should have done
SF I'll concede that
NC I suggest you didn't because the whole culture at RCN is one of profound indulgence towards the claims of TiMs

SF wouldn't say that more to do with a subconscious idea that I don't agree with that nurses are more replaceable than doctors [I think he's talking about an institutional belief – but surely one of NHS rather than RCN]

NC pls turn to p264 – this was MG's disclosure that SP had suffered sexual abuse. On reading this you didn't suggest that SP might prefer a female rep
SF no I didn't
NC and I suggest that this is part of a culture where women's boundaries and dignity is not taken seriously

SF no I would disagree.
NC can we go to p370. Background to this is that DU had caused "chaos" at previously places of work with comments about misgendering and challenging people on which toilets to send him to
SF yes
NC and this was not taken into account in the investigation

SF no
NC and you didn't press for it to be taken into acc
SF no
NC relevant tho – he was "a serial troublemaker" and therefore relevant to the confronttation on xmas eve
SF it would have been diff
NC she told you where it happened
SF don't recall that
NC do you dispute…

… the board didn't know that this was where it was alleged to have happened
SF don't recall
NS it was discussed at an inv meeting that you attended
SF don't recall

NC even if you don't now recall that the board knew and you knew the hospitals that related to if SP was making those allegations and the board was refusing to inv – the board should have and you should have beenpoking them with a pointed stick to do that
SF MG was sending a lot of info on SP's behalf – it was quite unclear what instructions I was being given – it's unusual to get instructions from a sol – had very little contact with SP and MG would be saying she was doing stuff that made me think I didn't need to do anything.
NC this is a symptom of the prob at the RCN's indulgence of TiMs – if RCN pushed for an inv and found he was a problem it would be embarrassing – it goes against the narrative that TiMs are victims and their opponents are bigots
SF not sure if that's a q
NC it's a proposition [she states it again]
SF I would disagree with that

NC going to 2nd claim now p400
[SP wanted to and has raised a 2nd claim against NHS Fife for the way they handled the disc process. She wanted RCN to handle the legal side of it. RCN disagreed, and suggested it should be bundled in with her first. And refused to cover cost of any legal rep]

NC MG says discip report is evidence of further discrimination against SP and asks for forms to fill in to ask for legal advice. Then SP writes essentially making the same point. At top of p400 your forward to Norman Provan (NP) saying you're not sure if you can or can't support

this app. was this you thinking she might not qual for legal assistance (LA) because she already had lawyers involved.
SF potentially yeah
NC did you speak to NP at the time.
SF no don't think so
NC pls go to p404

NC that is MG asking you to forward a copy of the LA policy so she can make an applications.
SF yes
NC and at p408 is the answer is not to send her policy and app form – nor to say there is no form, she just needs to make a req – the answer is to say no

SF there were a few steps between that
NC there was never a formal req for assistance that SP wanted to make
SF we don't have forms – we forwarded the req to NP and he said no
NC yes, but SP asked for forms on LA and then next thing she hears is no
SF I disagree – me and SP had

a call arranged where i could explain we referred on the basis of prospects
NC but you never said – there is no app form – put it all in writing and we'll get back to you
SF MG had made it clear what SP was looking for assistance on – didn't think there needed to be any further

explanation
NC did you say you did fill out a req for NP
SF no req came from MG – forwarded it NP summarising the req – no unusual
NC the explanation given to SP was that it was not within NP's discretion to go beyond our legal offer and offer LA in this case

NC presumably part of your role is rep your Members and push back against your superiors.
SF I did say she should be supported
NC you did
SF yeah but it wasn't my dec to make – NP said it fell outwith our process.
NC can you turn to p818 pls

NC when you said to NP you thought it should be supported was that in writing
SF several discos
NC did anyone take any notes
SF don't think so
NC any emails?
SF no a disco at AS between myself and NP

SF I thought it was the right thing to do and reputationally I thought it was the right thing to do- but it was not my decision to make
NC is that why it took so long to get back to SP
SF don't think so no – just v busy

NC okay look at p118 – when the union sets out under Our Rights – the situation under which it will not offer LA – member behaving badly – and then if a M has taken LA advice elsewhere it "may" not be offered.
SF yeah NP said he'd never exercised his discretion in any sim case

in his career.
NC and you were right – reputationally – that the RCN should have taken this on – it was imp for all your female members potentially
SF yes
NC and there had already been quite a lot of press coverage of SP's case – it was already news

NC and it's right that unions are usually quite keen to take on strategic cases which might help all their members
SF yes
NC and when it does something high profile and important for large numbers of its members its usually something they're quite proud of

SF I guess
NC and you were right and NP was wrong
SF [long explanation, but essentially agrees without managing to criticise NP]
NC another reason you were right and NP was wrong was in the RCN rules on legal rep – it includes legal rep but is not confined to it
SF yeah
NC and you had been working with MG for months – she on the legal side and you on the workplace rep side
SF yeah I might have handled something slightly diff if MG was not involved.
NC yes but throughout all this you were exercising the discretion not to say not to SP because she was working with MG
SF yes we were on the workplace rep side and she was on the legal ET side, but this was quite an unusual situation – never happened to me before.

NC why not tell SP immediately the decision was taken not to back her – why wait from the decision taken at AS
SF to put it in writing so there was a record
NC it was more because the RCN would not want to back a woman against a TIM
SF no that never came up
NC and RCN had taken a side in the gender wars and that side was with the gender. ideology side
SF no
NC if RCN had taken SP's side there would have been "howls of fury" from the activists and members
SF potentially I don't think that should/would be a consideration
NC you said should then went to would – it was should wasn't it that was right
SF it was not part of the decision making process or thoughts
NC if the RCN had backed SP it would have kicked off – wouldn't it
SF potentially
NC and the way GI ran through RCN like a stick of rock was why you didn't spot the correct legal position SP was in
SF I would disagree
NC and that's also why RCN took lying down NHS Fife's decision to let a man into the F CR
SF no I would disagree with that
NC and that's why you didn't got and speak to SP's colleages about the issue
SF that would be diff to do – I take your point – we could have arranged to – but I didn't do that
NC did you ask your local activists to do that
SF it came up through the partnership forum and asked if it had come up through that and to be mindful of it. And we asked local reps and to this day we haven't had a single nurse come to us and bring us any concerns about changing facilities
NC did you ask local activists to go out and ask them to ask SP's colleagues – rather than wait for people to come to them
SF would n't do that in a conduct case as there are issues around confidentiality, but when we discussed it it seemed it was a non-issue, and that's what we got back from the other trade unions

NC You suggested a moment ago you wouldn't discuss an ind member's disc proceedings – but the activists didn't need to do that – the problem was there was a man using the women's CR and no one had yet asked the women nurses how they felt about that – wasn't it the local rep's job to ask the q

SF I agree it could have been done
NC should it have been done – with hindsight
SF yes with hindsight everyone could have done things diff
NC and isn't it necessary to make people feel safe after they've been bullied and demonised for coming forward to say they don't want men in their spaces

SF I don't think that that's what our membership believed – no one had come forward to complain about it
NC no indication – you know women who have objected to men in their spaces have been threatened with death, rape threats, demonised – "decapitate TERFs" – that

NC are you suggesting it's not a real problem – hasn't passed you by
SF no but you asked about this case and there was no one else coming forward to us

NC you're aware how toxic it is
SF yes on both sides
[missed a bit]
NC women working for FIfe Health board are a subcategory of the whole world – they don't exist outside the world
SF within our member it's not something that's come up within LPF APF the staff aren't reporting

anything around this issue
NC you know why – there's a vicious silencing of women who raise that – they're not going to come forward because they're frightened, aren't they
SF not sure
NC a woman who doesn't like man in her CR – she knows how viciously hostile it can be if she raises it – she doesn't know the view of her union. She could either go to her rep and say she doesn't want a man in her CR – she could reasonably wonder if her rep might think she is a bigot
SF I would hope not
NC think we've agreed what the world is like – why would she feel safe to raise it with her union rep
SF cos we're there to support them whatever their views are – I've had to rep people who've been accused of sex assault and child pornog – I don't agree with their views but they still get representation
NC she might be worried her union rep might think her rep believes she might be a bigot that is unpleasant
SF would hope she wouldn't
NC is there anything the RCN has ever said or done publicly that would give a woman comfort that her union wouldn't treat her as a bigot if she raised an issue with a man in her TW
SF I don't know
NC and do you think the progress flags, badges, banners, articles etc would help your union member
SF don't know
NC that's the whole message the union pumps out
SF you're asking me to agree with something I don't agree with
NC what I am suggesting is that if there is an issue for your female members which they have a reason to be fearful about it is your job to go and find out what they think about it
SF as I said there could have been lots of reasons why that didn't happen.

NC final q – p370 MG note to SF re SP – allegations about DU's conduct in two previous workplaces were set out and copied to you
SF I assume so –
NC and you recollect you were shown allegations against DU
SF I believe so yeah
NC thank you
[no further q]
J no qs

J re-ex?
DH just briefly judge – re last q – what is your recollection today of what you gleaned from the subs you were copied into by MG
SF not great – it was a couple of years ago now

DH point of clarification – you were asked qs about gauging views of RCN re access of certain inds to facilities – you mentioned in answer to one of those qs you said you or your colleagues could have asked and weren't sure it had come up –
you mentioned APF and LPF what are

they?
SF area partnership forum and local partnership forum between management and unions
DH how local is local –
SF LPF covers ind workplaces
DH and area?
SF the board
DH the health board…
SF yes

DH you were asked when you were taken to your notes of the call with SP – you see that you typed as you went along – how much care and attn did you give to your notes as you're talking to an ind – what does that look like
SP I try to type whilst the other person is speaking

DH thank you that was everything
J okay you are free to go or stay, but you musn't discuss your evidence with anyone to give evidence.
[he leaves]
J Gillian Tait is next
DH yes
J what is the timetable going forward.

DH after disco with my learned friend we are now not going to call Ms Jabbal, so just Ms Tait and Ms Marquis
So 1.5 hours for Ms Tait
NC my estimate of 3 hours for GT was over-estimation – I think we'll comfortably finish today
J and Ms M?
NC no more than 3

J so we'll be finished by the end of tomorrow for submissions on Thursday
[both parties agree]
J okay we'll rise for 10 minutes then restart at 1152 with Gillian Tait
[court rises]

[Gilliant Tait – GT – is in the witness chair and being affirmed]
J asks her to ensure she speaks up and into the mic – thank you Mr Hay
DH thank you judge…

DH yes GT good morning – full name/
GT – Gillian Elizabeth Mary Tait
DH you are employed by the RCN as a senior officer
GT yes
DH how long
GT since Nov 2020 as an O
DH when did you become an SO
GT interim in 2021 and then perm in 2022
DH any time with the RCN before then

GT was a local steward within NHS Fife for 11 years
DH what did you do for a living
GT nurse practitioner and then advanced nurse practitioner doing GP out of hours
DH a type of nurse –
GT – yes covered four areas during the night time –
DH one was Victoria Hospital – did you

meet SP
GT yes but I didn't know her that well
DH how long ago
GT bout 10 or 11 years ago – can't be sure
DH by 2024 as an SO you had some lm responsibilities and you report into NP
GT yes

DH and you would have been in Arran Fife Forth Valley and Tayside
GT and Ayrshire yes
DH always been in that patch
GT no as interim did Grampian Highlands Western Islands Orkney and Shetland
DH and then into Arran… etc
GT was some overlap up to Nov 2023 when my colleague

started and took over other patch.
DH there came a point when you became aware of a workplace issue concerning SP from 2023 into 2024
GT first time became aware was a case review between our officers in Feb 2024
DH what's a case review
GT as SO we meet with the Os to go through

cases and see they are progressing – a brief disco on what each case was about
DH how often
GT ideally monthly. but whilst taking over the patch we did it one to two monthly
DH one to ones with the Os or group sessions with the Os. Initially group, but now we do one to ones

[sorry that last sentence was GT]
GT but you can do it both ways
DH one O was SF
GT yes
DH SF was dealing with the SP case – what discos did you have with SF – what detail
GT that can vary – from first case review was that SP was under inv and she had sought legal advice (LA)

DH did you get more involved with SP
GT I took over SF's case during a period of absence by SF
DH when was that
GT June 2025
DH what was the reason – absence and cases needing attending to
GT yes
DH pls turn to p427 of the bundle

DH this is the end of an email chain – p437 – your first email sent to SP in June 2025, explaining why you are getting in touch as SF was off work and there was some disco around when a discip meeting was to take place
GT that's correct

DH and we see the response to that email – on p436 at the bottom – you get a reply from MG. Had you had any contact before thi response from MG
GT no
DH that's on 19 June – we see that SP is not looking for RCN assistance with the discip because they've made certain

descs about providing written responses.
GT [reads] yes

DH so made an intro, "you've been told assistance is not required – how did you then go about interacting with SP after that?"
GT "I would have responded back to SP directly and would expect to review her case monthly and see if she needed any further support"

DH so you send an email to SP on 26 June copying MG in – offering your own thoughts on approach to discip hearing
GT yes
DH on p435 next day told no workplace rep needed from the RCN at that stage – so that led to your monthly check in
GT yes and await discip outcome

DH did you come to understand that some rep was being asked for from SP
GT Colin Pullman RCN director scotland asked me to reach out to SP as she was asking for workplace rep
DH turn to p448 – this appears to be the next email on 30 July to SP – was this after CP asked you to

get in touch
GT that's correct
DH and we see on p448 – the third par "I'm writing…" [he reads about disco for workplace rep and returning to work] – why did you want a call with SP
GT always have a call when you take over a case. did put that in my first email with SP

always pertinent to have a call or a meeting with the person in person.
DH what are the advantages to that in addition to emails
GT allow me to understand it from their perspectives, allow them to ask qs, help them understand my perspective and to build a personal relationship

DH you got a reply on 31 July 2025 and SP says she had a sig toll on her and was not up to a call at that point. Did you respect that
GT absolutely respected that yeah
DH in later emails when messaging the claimaint – you made offers of discos – do you recall that

GT yes offered a call in most of the emails to Sandie to try and understand what she was looking for me to do.
DH don't think it's a disputed fact when you first come to contact SP – you send around 11 emails to SP looking to arrange a call or a meeting with her and SP declined

whenever you requested it.
GT yes it was over a year I made those offers, but she didn't take me up on any of them.
DH you were taking over some casework from SF – did you do casework in your ordinary duties
GT less of a caseload than the Os, but SOs were expected to take some

DH in your experience of dealing with cases – how unusual is it to not have any sort of verbal disco with a member when you are providing workplace rep
GT highly unusual – never had a circ when a member I'm supporting hasn't spoken to me in over a year.
DH did that have diffs?

GT yeah emails can be seen as different from how they are sent and read and respecting what a member requires, but it didn't allow me to do this in my usual way
DH can we go to p431

DH we have a letter from MG to NP dated 10 June 2025. This is not addressed to you – did you see it when you took over from SF
GT no

DH look at p432 – a req at the top of that page – "she is asking her union to lend it's weight…" [reads – SP wants RCN to write to NHS Fife to confirm no men will be allowed access to F CRs] is that consistent with what you understood she was asking
GT yes

DH and on p436 – an email chain between MG and RCN sol Ms Forrest [also in court today] – lated July 2025. Did you see emails between MG and the RCN's sols
GT no

DH we see if we go back to p449 email of 31 July – there's ref in the last par of SP's email to you directing you to look at the letters SP sent to the RCN's sols – what was this about
GT an attempt to ask what was the ask of the representation to support SP back to work

DH and is this your response over the page
GT yes
DH and looking at this you had gained an understanding the imp SP was placing on who would be accessing F CRs – is that right
GT yes

DH we see later that day on p451 – MG emails you on that date with some info you asked for about the line managers (lms) you should be getting in touch with. MG also says RCN should be raising issues with NHS Fife on behalf of all female members and then more on SPs views…

… you were asked to copy SP into corr you sent to Fife Health Board (FHB – but basically NHS Fife).
GT yes I did I think
DH in terms of the assurances you were seeking on behalf of SP – did you have any diffs asking NHS Fife for these
GT no no diffs
DH you email p456 David

Miller (DM) of NHS Fife copying SP in.
GT yes
DH anything from SP saying she was unhappy with the way you expressed yourself in that email
GT no

DH you get a reply from DM – you gave him a deadline of 18 Aug – why a deadline
GT keen to get a response for sandie
DH language in your email – 3rd par – SP "requires" assurance NHS Fife will provide single sex CRs – say "imperative" SP gets an assurance before she returns

How seriously are you taking this req from SP?
GT as seriously as I would a req from any member. I was taking this v seriously
DH you get a reply on 26 Aug p452 – you forward it on to SP as was DM's reply – but you forward it on and you ask SP what she wants done next

GT yes
DH p457 email from SP 29 Aug 2025 – can we go to p459… there are a no of reqs made by you from SP in this email. 3 reqs and then at p460 there is a req for you to send your letter to all RCN members so members can see RCN is supporting our rights

DH so you write to DM with those three numbered reqs, and you copies SP in, but you didn't sent a copy of the letter to all RCN members employed by NHS Fife
GT correct
DH why not
GT this was for an ind case

DH had you ever done so in the past
GT no
DH ever been asked
GT no
DH go back to p460 at top of page it says – why the request to copy all members "so that we know that you are now taking steps to defend our rights" who is the "we"
GT don't know

DH had any other Ms within NHS Fife raised issued about Ms in ss facilities
GT no at that time no other members had come forward on this issue

DH you copies DM in on your email to SP on 5 Sep 2025. Did you get any word from SP or an advisor expressing dissatisfaction with what you had put to DM
GT no not in relation to that email no

DH on the concept of other inds being interested in access to single sex facilities – if were you aware of other inds who were expressing sim concerns what would you have done
GT put it in as a collective group with consent – a group case where all members would be kept up to

date with all the corr relating to that case.
DH you did not flag to SP you were not going to send your email to DM to all members – why not
GT I was concentrating on the main point of her email and on reflection I should have told her it was a no or I would get back to her.

DH there's a response from DM to you on 12 Oct p469. You then contact SP on 21 Oct which is at p472
GT that's correct
DH you mentioned just in this email – "it's unhelpful that DM is unclear on specifics" – dissatisfied with DM's response?
GT unclear what the arrangements

would be and what that would look like for her. The reassurances were not specific for her.
DH you get a response from SP to you on 31 Oct 2025 on p479. SP makes reqs in the last par on p480 – that she reqs no calls or meetings with DM until he responds to a letter with DM

[sorry letter to DM] from MG. No ref to any concern being raised about your letter to DM sent to RCN members. At this point did you have any understanding of her being dissatisfied with your comms with DM on 5 Sep.
GT no that's why I offered a phone call to her.

We could have discussed it.
DH you action the reqs made of you by SP on 19 Nov on p481 – is that right
GT that's corr
DH further response from DM on 27 Nov p483 – he appears to be saying he's delaying giving a detailed response until after SP's 1st ET claim

DH and you express your own view on DM's suggestion
GT all boards have to work in partnership – yes there was an ET going on, but this affected all staff on the board
DH so you didn't agree SP should wait
GT no didn't agree she should have to wait for an impact assesment

nor to have to wait to return to work
DH and that's on p484
GT that's correct.

DH p513 SP responding to you on 5 Dec – a req is made of you in the second last par that it would help if the RCN made public its crits of DM and FHB as it appears neither your corr nor my own sols is having an impact – what did you make of this req to make crit public

GT that would not be an approach I would take to crit an ind on FHB. I was happy to check and take it to Senior Management to check – discussed it with Colin Pullman
DH their view
GT we would not normally do that, no

DH why not do it in this case – any thought made to making an exception in this case
GT no

DH you explain that decision to SP in an email from you to her on 15 Dec p514 to p515 – p515 second par you set out a draft email you propose to send to DM
GT yes

DH SP made a further request in respect of raising a collective grievance see that? [reads to it p516]
"many women are fearful of speaking out". Did you take any steps to attempt to engage whether member concerns were being expressed to RCN Os or reps
GT at that point not aware…

of any other members coming forward. Checked with RCN Direct to see if they had had any members. Asked admin to check to see if any members had raised any concerns. Wanted to make sure that no members in my awareness had come through to us.

DH we see an email chain in p517 – 518 certain emails from a Marie Mason – who is that
GT NP's PA
DH we look at foot of p517 to p518 – Ms Mason is emailing two inds?
GT part of RCND – not sure
DH MM is asking if any calls about toilets or CR have been made by Fife members

at their place of work. Was that as a result of your work.
GT yes I wanted to make sure we had info and clarity on it for SP.
DH and if we turn over we see search from 1 Jan 2023 to today that's Dec 2024 – "unable to find any enquiries from members" re issues with CRs

DH put out any other types of feelers
GT yes local stewards who do walkabouts on wards – stalls etc asked if they had any members approach them and none had raised any issues around toilets or CR in Fife

DH if a no of inds had come forward, were you aware, taking us up to date today has anyone come forward
GT no till today no one has come forward with any issues – I'm asking local stewards to keep me informed and no one has said anything – we had stall at roadshow in May

and no one reported anything from there
DH on p519 22 Dec you go back to SP and tell her there have not been any members who have come forward to raise the issue of single sex spaces in Fife for the purposes of raising a collective grievance
GT correct

DH p522 – email from SP to you in Jan 2026 – we see you respond to that on 16 Feb 2026 – p524
GT that's correct
DH there are some other emails concerning the status of an equal impact assessment at NHS Fife 24 Feb 2026 at p527, and 2 April p574 – 575, 11 May p578
GT confirms all are correct
DH last email from you to SP is in July 2026 – p591 – 592
GT correct
DH you checking in regarding support and assistance in return to work and asking if local stewards have any updates on provision of single sex facilities

and that you'd be happy to meet up or have a call. Any response to that email
GT no no response to that
DH from the comms from SP did you have any understanding she was unhappy with your workplace rep of her?
GT no
DH in your approach…

… were you approaching the matter any diff to any other member.
GT would be supporting SP the same way I'd support any other member
DH did any view you may hold of SP's beliefs sometimes called GC or SR – did that so far as you are aware colour your approach in respect

of what you chose to do or not do in your representation Ms Peggie
GT no not at all
DH no further questions
J we'll break for lunch and have xe at 2pm
[warns GT not to disco her evidence with anyone]
[time to have a look at the bundle…]

[we're back]

NC what do you understand about Forstater ruling
GT it would have been NHS Fife had harassed SP
NC not asking you about SP's first claim – I'm asking you about Forstater at the EAT – heard of it
GT not overly familiar with it

NC have a look and see if it rings any bells
NC does that sound familiar
GT aspects of it – may have been mentioned and one of the AS sessions we had
NC know anything about diff between holding a protected belief and manifesting a protected belief
GT no
NC mentioned SC judgment [explains it in a nutshell] – where you aware of a FWS judgment at inner house which didn't go to SC

GT darlington
NC no –
GT the one against the Scottish Ministers
NC yes – had anyone explained it
[not really]
NC so no one had explained to you that TiMs could not be treated as women on the basis of GI
GT okay not explained
NC no NP agreed with me that GI believe

that your inner belief determines your sex and GC people belief its biological – are you okay to accept that
GT yes
NC pls turn to p1025 – [a Pride IN Nursing logo on a Progress Pride flag]- know it
GT yes – it's related to Pride
NC specifically the pink and blue is related

to trans
GT didn't know that
NC NP agreed it was firmly ID'd with Gender Ideology (GI). Agree?
GT don't think I can as I'm not really familiar with it
NC back to p600 in the big bundle… this is a transcript of part of a chat on an engagement session that RCN ran on

the FWS in June this year. Were you aware of them
GT only when I read the bundle
NC so not aware at the time
GT no
NC have a read through p600 – p602
[she does]

NC now look at smallest folder on the desk in front of you pp24 to 29 pls
[GT does]
NC just pausing on p24 – do you know what TERFs stand for
GT not really
NC Trans Exclusionary Radical Feminist
GT know that only through reading the bundle – wasn't really aware before

NC extreme examples, but it's characteristic that GI belief is bitterly hostile to GC belief which it often calls hateful, transphobic and genocidal
GT hard to be sure without the full context
NC do you agree that's the general gist
GT hard to from my perspective
NC what is

your own positions – was FWS very bad news or do you agree that bio sex matters
DH don't answer that q – judge this is the motivation for action taken by ref to a belief – there's no suggestion that it hinges on this Ws belief. I would also say that of the most substantive

decision-makers this was not asked – so why ask of her – strikes me as not being relevant
NC I say it is relevant – the case is how the RCN acted as it did and I say the RCN's adherence to GI is part of the case and GI is hostile to the GC position so it is rel as to the decision maker's view on this case. If GT is an adherent to GI you can draw an inference as to the way she acted how she did
J what do you say to DH's point that this is the first W
NC not relevant that its relevant
J what's your view
NC nothing to do with whether its a possible or permissible q – it doesn't assist you. Either the q is properly put or relevant on its merits – whether I put it to anyone else doesn't arise

J i think it would be potentially rel DH as I have to determine why she made the decisions she did
DH we had discos about this and I am grateful to her for the pre-warning – I would be concerned if this was a line that would be embarked upon – presumably it needs a basis for the q – there may be points where I reserve my position if we are straying beyond the realms of reasonable enquiry,
J okay but on the basis I need to determine why inds did certain things I will allow that q
NC I'll state it again – "what is your personal position – do you think TWAW and FWS SC was bad news and people were rightly up set or do you agree with SP and think that biological sex matters"
GT "I agree with the SC ruling that a bio woman is a woman. I've been a reg nurse for 33 years and I have supported hundred s of members over 11 years and at no point has my persona opinion impacted how I supported a member, a patient or a relative over my career."

NC so you agree with SP
GT I agree with the SC ruling

NC can we go to p1106
NC have you seen that before
GT no
NC pls read it
[it's a RCN doc – can't see much more. hopefully all will become clear]
NC stop at p1111

J that will take some time – don't feel under pressure – just let us know when you've read that.

NC an you agree with me that is an uncritically positive piece about gender-affirmation surgery
GT struggle to confirm
NC makes surgery seem like a good thing
GT don't agree
NC at bottom of p1108 it complains about long waiting list for what's called gender-affirming care

NC says those waiting lists are a bad thing
GT in the context of the person waiting for it
NC and on p1111 third par from the bottom – Liz the nurse quoted throughout the article – training for GPs can't tell you how imp it is as many GPs say it's not their area – it's imp

we have better training to get gender dysphoria diagnosed so patients have access to hormones.
[GT is not engaging with this at all not offering opinions]
NC can we go to p1019 – in the search box it says "cite: rec.org.uk LGBTQ+" that's a search for

rcn.org.uk sorry
NC that's a search for LGBTQ on RCN website – there were about 60 results which came back – quite a lot of content referring to LGBTQ
GT according to this
NC next search is for "transgender" – 170 results

GT yes
NC do you agree that the expression LGBTQ is contentious – because there are a lot LGB people who say gender reassignment is nothing to do with them and shouldn't be lumped in with trans or queer.
GT can't really say
NC so you can't say LGBTQ is contested
GT not my area

NC if you search RCN site for "gender critical" you find 2 results. Do you agree that if those results show what they seem to show there is "strikingly more interest" in trans rights or trans claims that GC people and their concerns
GT first time I"ve seen this certainly more

info about the former.
NC any sense of what proportion of your membership hold broadly crit sex realist views
GT wouldn't be aware of the numbers
NC you agreed you hold broadly GC views
GT I would say it's something I haven't really though about if I hold GC views and not really in a pos where I had to think about it
NC you agree with FWS
GT I agree a biological woman is a woman

NC and a lot of the reasoning in the SC judgment was based on premise that whether someone has a male or female body has real practical consequences in the world
GT not sure I agree with that – as a nurse and in my role I am very inclusive of all members
NC those things don't have to be mutually exclusive

[explains. GT doesn't understand]
NC for the purposes of medicine if you're calc-ing doses of certain things or someone's having a heart attack – it's really imp to know the diff between a man and a woman
GT it's hard to comment on that
NC if a patient presents with abdominal

pain it's imp to know if they are a man or a woman
GT depends
NC if that person is not a woman you can rule out a whole lot of things
GT yes
NC so sex matters
GT it depends on the context

NC do you think your will have a chunk of members with GC views
GT I don't know the numbers
NC no we know you don't have the numbers – can we go to p84 – here is a request for info on the views of the RCN members. And we are told that the RCN doesn't collect that data

NC your members only women can get pregnant – it's a pretty safe bet that some of your members hold GC views – maybe most maybe not but a significant chunk
GT don't know because we don't have the data
NC but it's a safe bet that a large chunk think sex is real and matters

GT don't know – lots of diff members with diff beliefs. Diff for me to say
NC broad brush assessment – is it not obvious its likel to be a large minority
J she's given her evidence – she's not sure
NC you're sure a maj of your members are not flat earthers
GT eh
NC they don't think you'll sail to the edge of the world you'll fall off
GT agree
NC and they believe in gravity and the probably believe some will be vaccine deniers
GT not sure about members
NC no but you could hazard a guess
GT don't know as aI don't know their beliefs
NC in the same way most members are not flat earthers and accept gravity many believe that sex is real and matters
GT can't say – we're an inclusive org
NC and you're uncomfortable talking about that because the RCN has adopted GI and saying sex is real and matters is alien to your thinking
GT no that's not the case

NC can you go to p1051 – this is the first of 57 pages of what I've been rude enough to call RCN tat
GT merchandise! [she smiles, NC smiles]
NC flick through it – I've called this generic nursing merch some with an historical slant – some generic and some with a campaigning slant

NC and that's most of it
GT looks like it
NC turn to p1056 – a few specifics – pride enamel badge – on p1062 – progress pride I love nursing lanyard p1081 – another RCN pride enamel badge p1095 we see three buttons fair pay for nursing, future of nursing, pride in nursing

NC the last three are free for members
GT yes
NC paid for by RCN and funded by membership subs
GT not sure how it works
NC fair inferene?
GT yes
NC so there are four cats of merch. Generic, historic, pay campaigning and progress pride flag branded items – and you and NP

both agreed that PP flag is closely associated with GI
GT I disagree that we're in favour – we're inclusive that's why the badge is there
NC but it's not fair to GC people because it says its wrong – that is not the correct moral opinion
GT disagree
NC but PP flag is associated

with GI
GT so you say
NC but if I'm right there's not xtian merch, marxist merch, atheist merch – it's the only other belief merch
GT agree
NC why promote this belief system only other than RCN signing up to GI
GT not aware RCN is signed up to be v inclusive
NC so if GC nurses

say we don't feel very included – what about some GC merch in suffragette colours displaying a GC motto
GT it would certainly be a convo – not my role, but I would expect we'd have a convo
NC it would be a convo shut down v fast indeed you must know that
GT I disagree

NC your role with SP started when you took over from SF – I'll take this quickly – you offered to help SP with her disc, but MG told you SP didn't want help
GT correct
NC pls turn to p118

NC page from the On The Case leaflet – under "other advisors" – says imp to have confidence in the RCN and you take other legal advice the RCN may decide not to rep you. All of this and the warnings about not provding advice is about workplace rep as well as LA

NC so you could have bowed out and focused on supporting members without LA
GT still my role to support her – still an RCN member
NC go to p435

NC this is you pushing back on SP's wish not for RCN rep – saying she ought to accept it
GT this is me providing advice that she should attend
NC if she attended she could only have your rep as LA's not allowed to attend
GT [broadly accepts]
NC and you were firmly but politely

stood down on p435 by MG
NC and look at p446 – here is a note saying SP is looking for rep and that refers to a note on p425 and MG's req that RCN noted RCN letter to Darlington Trust – MG is asking RCN to follow the excellent example of Sarah Dodson [sic]

and exercise it's industrial muscle to help it's female members
GT from this – yes
NC p965 I may have misnamed Sarah Dodsworth – that is her letter of March 2025. Have you seen that before
GT no
NC pls read it

NC that's an exemplary letter – clear and to the point and asks the D trust to comply with the law
GT yep
NC and that's what MG was asking you to do for SP
GT once it came to my attn yes
NC pls turn to p448 in main bundle
GT you got in touch at end July 2025 after MG asked

on SP's behalf for workplace rep (WR) and MG referred you back to what SP wanted.
GT my understanding SP wanted WR and assurances to get her back to work
NC look at p447 second page of MG's letter to AS – 2nd par – "the RCN now has the benefit.. [reads to it]… trans women

… should not be allowed to use the women's facilities" [more reading]
NC she wants pos engagement on behalf of the union to get NHS Fife to comply with the law – understand the diff?
GT yes
NC look at p450

NC on 4 Aug – you are treating this as a purely ind matter – [reads to GT's letter] so this is a dispute between SP and FHB not as a matter of the RCN needing to take up cudgels on behalf of the whole membership
GT yes

NC see MG's response – she says this is a matter considers should be raising on behalf of all its members – 87% of membership are female [conts to read to it]
NC then she says large number of colleagues who disagreed with men in F CRs, but were fearful of speaking out

NC here MG is saying what SP needs is union to employer comms on behalf of the whole female workforce to ensure their rights are respected
GT clear from MG's perspective but [she goes on about the processes – SWAG Once for Scotland, local partnerships]

NC and MG says union is complicit in this culture of fear, but the pages I showed you from the website – goes further than a culture of fear – RCN is showing itself wedded to GI where it would be difficult to raise issues like this
GT totally disagrees – all members get

full support so I don't believe they are fearful
NC MG ends by saying she expects that RCN should take a stand for GC members as the unwavering support for people with oppo beliefs – she's not wrong about the unwavering support for GI
GT I would dispute that. we're inclusive

NC see the PP flag – at the top of DM's email
GT yes
NC it's ubiquitous
GT what does that mean
NC it's everywhere
GT [laughs] it's on this email
NC when you raise it with DM you treat it as a purely ind matter – it's not a wider issue

GT I was absolutely repping SP in that email yes

NC you have to prod him a couple of times – but he responds substantively on 26 August 2025 on p452/3 – he waffles a bit about comprehensive review and then promises single sex facilities for bio women – doesnt' he
GT yes
NC more waffle about complicated about complex

ongoing undertaking – looking at compliance – he's talking nonsense there isn't he? they either have to use their own sex or unisex alt
GT my understanding of his complex about impact assessment so that all protected chars were reviewed – lots of old bldgs in NHS Fife and

etc
NC but you don't do an Impact equality assessment to comply with the law – there may be complexities about adequate provision for those who aren't prepared to use facilities for own sex, but nobody can use facilites of the oppo sex is the law and easy
GT he means it in a

context of assessment of all protected chars
NC nonetheless he makes a commitment and that's good enough for you and you send it on to SP
GT I forwarded it to make sure she was happy and offered a call with her.
NC problem is this is not a clear policy to all staff.

all he's doing is saying there will be appropriate facilities for SP.
GT [sorry missed]

NC in here on p457 SP says she's still anxious – no clear universal declaration esp as DU said he considered himself a bio woman. so there was still some suspicion – it was reasonable for her of "suitable facilities for bio women" with some concern

GT if she was concerned then it was my responsibility to communicate those concerns
NC SP says still concerned RCN had failed to do anything or say anything in response to SC judgment about something which affects all female colleagues

GT it affects all members that we have a v good governance structure in place
NC and a year and a half after the SC judgment you have yet to produce a policy
GT we're working on it
NC at pace?
GT it's moving ahead, at pace

NC SP also told you her colleagues were upset about the situation – no reason to disbelieve her
GT yes that's why a phone call would have been useful. No reason to disbelieve her, but no one else come forward

NC understand people would be apprehensive approaching their union –
GT no reason to think so – people come forward about lots of things all the time
NC RCN promoting puberty blockers as a good thing, PP branding everywhere – only belief branding on sale in the merch shop

they'd have every reason to believe RCN had signed up to GI
GT no
NC and you know that out there in the world there has been vicious persecution of people expressing gender critical views
GT wouldn't know

NC heard of JK Rowling
GT yes
NC know her views
GT yes
NC know what she's been subjected to
GT no
NC heard she's been had rape and death threats for expressing her view
GT no not on twitter or facebook

NC but your members are
GT don't know that
NC some of them will be
[…]
NC you know the PP flag has been flying about its HQ since may this year
GT didn't know that – hadn't been down there this year

NC on p459 – suppression of discussion about SP's case in the workplace should be something you should really be interested in as a union
GT my understanding this was just about the disc
NC in par 1 – "staff have the right to discuss matters of common concern…[reads]"

NC that surely is something that every employer should allow and all unions should demand
GT in a respectful manner
NC you don't need to add that – you don't have to anticipate bad behaviour – staff must be able to disco these matters – inc female only spaces – you don't need to

tone police it do you
GT I think that's correct, but it needs to be context appropriate
NC well the employer may say yes its important that it's all respectful and within boundaries, but is it not important that the union defends this free right of assembly and speech

this par is not something you could object to as a union.
GT and from my perspective i did write to the union in my own words
NC p463 – let's have a look at it – her pt1 you've put in the middle as far as you've dealt with it – SP is concerned colleagues are being told

not to disco her case… [reads to it]
NC that's quite diff isn't it – she's asked to confirm that all staff have a right to disco all things in the workplace and you've asked them to ensure she won't be disciplined
GT yes I took it back to SP – that' why I would like to

discuss it with SP to check it before sending it.
NC she made it easy for you – all you had to do was copy and paste it – you decided to change it – leave out everyone else and copy and paste it
GT not sure – agree I changed it, wasn't aware and yes I brought it back to SP

NC reason I suggest its imp – she's been isolated – she's been told you're the only bigot who didn't want to undress in front of a man – that's how she was described in xe in the first case and she knew that wasn't true – but everyone was too frightened to come forward, that's why she wanted other colleagues to know they were free to talk about it.

GT that's why a call would be helpful

[convo goes back and forth about GT toning down of SP's requests – every time there is a point of diff – GT says a call with her would have been helpful to clarify and check she was happy.]

NC you're saying you couldn't write without naming her and get NHS Fife to confirm three things as this was all happening at a higher level
GT I was repping SP – trying to help her get back to work.
NC your interp of the email was wholly unreasonable – SP was talking about

union's failure to rep female employees – not her – it's all about general workplace rights. You have taken it on yourself to convert what she's asked you to do in a general please comply with the law – you've gone to a please do this with SP.
GT that's why it would have

been helpful to have a convo with SP.
NC I put it to you at the beginning that the first proposition was unexcpetionable – it's true of the other two… the second thing she asked FHB to understand is something no one could object to – it's the law.

GT agree
NC and no reasonable union could have any hesitation in asking an employer to confirm that
GT I did ask it in my email
NC you didn't ask it in those terms – you toned it down
GT put it in my own words
NC you didn't include the bit about treating GC belief as any other

characteristic and that's important as employers and unions have been reluctant to accept this
[…]
GT disagree I toned it down I put it in my own words I was trying to get SP to engage with me so we could discuss it and work on it but SP did not come back to me at any point

NC you said it would not have been to you to write a general letter saying pls confirm you intent to comply with the law – you didn't go back to SP and say I can't do that.
GT no and that's an error on my part – I should have checked and found out if it could b done and told her at the time.

NC did you check
GT can't remember
NC you said no members were coming through to you raising this issue – if I'm right why inds might fear being regarded or treated as bigots if they say they're not happy about a man in the F CR – it's not surprising they would not come forward

if they didn't know where their union stood.
GT no they come forward
NC the wouldn't they come forward if they were unhappy if there were a black person on their ward
GT they would
NC they would expect to be rebuffed

GT depends on context
NC in which context is it acceptable to object to having a black colleague on the ward
GT there isn't
NC and no one would come forward to complain about having to share a CR with a black or lesbian colleague
GT they would

NC one of the reasons that no one has come forward about a problem with a man in their changing rooms might be because DU left some time ago
GT accepts

NC what SP was asking for was RCN's public backing and you withheld it
GT no i hadn't had a convo with her to explain how the process work
NC it was because RCN had taken up a position consistent with GI
GT I disagree

NC no further qs
J can you look at p445 – when did you first see this letter
GT in the bundle
J and in relation to p431 – when did you first see that
GT that would be in the bundle also

J thank you. re-ex?
DH just one qu – you've had a lot of qs about that letter you wrote – when were you advised there was going to be a critique of what you wrote
GT when we were advised we were going to tribunal
J break there for the day start with Ms Marquis' evidence

J do you still want to do subs on Thu or after Ms Marquis' evidence
DH and NC Thursday pls
J thought so, but thought I better check

J okay back again tomorrow at 10am. Thank you.
[court rises]

I'm going to go back and write this up. If you would like to get the report first via email, please do subscribe – you'll also get a late night newsletter filling you in on all the out-of-court goings on…

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