Untitled 1

POLICE WITNESS STATEMENTS

In the case of

Regina -v- Michael John Smith

Witness Statement Page 1

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Mr ‘B’

Age of Witness (date of birth) Over 21

Occupation of Witness Security Service Officer

Dated 28 August 1992

This statement, (consisting of 2 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

On Saturday, 8th August 1992 I was present at about 9 am at a house in Ham, Surrey when I made a telephone call from that house. Today Detective Inspector MORRISSEY played to me an audio tape recording marked MG/1 which he unsealed in my presence and he showed me the telephone call print out marked MG/2. I can state that MG/1 is a true record of a telephone call I made to telephone number 549 5369 at 9.02 am on Saturday, 8th August 1992. The conversation went as follows. The phone was answered by a female who said “hello”. I said, “Hello, is it Michael Smith”, she said “Ur … he lives here, who’s calling”. I said, “This is George”. She said “who”, I said “George”. She said “Just one moment”. A male answered “Hello”, I said “Hello, is it Michael Smith”. He said “Yes”. I said “Hello, I am George speaking, I am a colleague of your old friend Victor, do you remember him”. He said “Yes”, I said “OK, that’s good, now listen it is very urgent for me to talk to you”. He said “Yes”. I said “You understand”. He said “Yes”. I said “OK, OK, but I think maybe we do this another way”. He said, “OK”, I said “You understand”.

Signed Mr B Signature witnessed by Martin Morrissey DI

No. 991A

Witness Statement Page 2

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Mr ‘B’

He said “Yes”. I said “OK, I think there is telephone at corner of Durlston Road and Cardinal Avenue, you know this”. He said “Yeah”, I said “OK”, you can maybe be there in fifteen minutes”. He said “OK”. I said “Yes OK, this is corner of Durlston Road and Cardinal Avenue”. He said “OK”. I said “fifteen minutes very important”. He said “OK”. I said “OK, I’ll ring you there bye, bye”. He said, “Bye” and I finished the call.

Signed Mr B Signature witnessed by Martin Morrissey DI

No. 991C

Witness Statement Page 3

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DCI Martin Charles Gray

Age of Witness (date of birth) Over 21 (19 December 1944)

Occupation of Witness Detective Chief Inspector 153284

Dated 18 August 1992

This statement, (consisting of 1 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

On Saturday 8th August 1992 at 8.28 am I broke the seal of a new audio tape which was placed onto a tape recorder attached to telephone number 081-940-2827 at a house in Ham. At 9.50 am the same day I removed the audio tape from the tape recorder. At 11.50 am the same day at Paddington Police Station I handed the audio tape, exhibit MG/1, to exhibits officer DS SINGLETON. The tape recorder attached to telephone 081-940-2827 produced a telephone call record print-out and at 11.50 am the same day at Paddington Police Station I handed the print-out, exhibit MG/2 to exhibits officer DS SINGLETON.

Signed M Gray Signature witnessed by

No. 991A

Witness Statement Page 4

Form MG 11(T)

STATEMENT OF DS Simon James STAFFORD

Age if under 21 Over 21

Dated 6 November 1992

Using a photocopied sectional enlargement of page 75 of the 1987 edition of the Greater London Street Atlas, I have indicated the approximate position of two British Telecom public telephone boxes, marked TK1 and TK2 respectively. I have also indicated the position of premises at 48A Burton Road, Kingston, marked HOME ADDRESS. I submit this map and title sheet with exhibit identification mark SJS/1 thereon

Further to my above statement, I have, with reference to the statements made by officers engaged in the surveillance of Michael J SMITH, on Saturday 8th August 1992, immediately prior to his arrest, indicated the outward and homeward route that SMITH followed after receiving a telephone call from Security Service Officer Mr ‘B’.

Signed S.J. Stafford DS Signature witnessed by

Witness Statement Page 5

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Peter Alexander HORDERN

Age of Witness (date of birth): 25 January 1954

Occupation of Witness: Detective Constable

Dated 12 August 1992

On Saturday 8th August 1992 I was present at a briefing given by DCI MacKENZIE in which he described a male and female who lived at 48a Burton Road, Kingston-upon-Thames. At about 8.30 am I was deployed with other officers in the vicinity of Burton Road. At 9.20 am I saw the male previously described to me leave 48a Burton Road and walk quickly east up Park Farm Road. As he walked he glanced at his watch. He was wearing a purple tee shirt, blue jeans and blue canvas shoes with no socks. At 9.40 am I saw the same man walking towards 48a Burton Road in Chesfield Road about 30 yards from 48a Burton Road.

Signed Peter Hordern Signature witnessed by

No. 991A

Witness Statement Page 6

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC James TUBBS

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer

Dated 12 August 1992

On Saturday 8th August 1992, I was engaged with other officers in an operation in the area of Kingston-upon-Thames. Following a briefing by DCI MacKENZIE, during which I was given the description of a man and a woman who I was told lived at 48a Burton Road, Kingston-upon-Thames, I was deployed in the area around that address. At about 9.20 am I saw the man previously described, dressed in a purple tee-shirt and jeans, jogging into Staunton Road, from the direction of the address, and then away North out of my view. A couple of minutes later I saw the same man, now walking North up Latchmere Road. I drove past him, and lost view. When I had turned round, and driven back, he was no longer in Latchmere Road. At about 9.33 am I saw the man again, walking out of Cardinal Avenue, into Latchmere Road, and South again in the direction of his address. I lost sight of him again. I regained vision, and tracked him down Staunton Road, losing vision again, just before he reached the junction with Kings Road. At 9.40 am I stood down, discontinuing any observation.

Signed J. Tubbs Signature witnessed by

No. 991A

Witness Statement Page 7

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Catherine PLUMMER

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer

Dated 27 August 1992

On Saturday 8th August 1992 I was engaged on an operation with other officers in the Kingston-upon-Thames area. I received a briefing from DCI MacKENZIE, during which I was given the descriptions of a male and female who I was informed lived at 48a Burton Road, Kingston-upon-Thames. I was then deployed in the area of that address. At 9.23 am, I saw a man dressed in a purple tee shirt, blue jeans, blue shoes, who I recognised from the previous description. He was walking in Cardinal Avenue, towards a telephone kiosk in Durlston Road. He went into the kiosk, with his left hand in his pocket. He then left the kiosk and back the way he came. Then he returned to the kiosk. He walked away and I think he was looking at something in the box. He then walked away back on the road he came in, Cardinal Avenue. At 9.25 am he came back to the kiosk, looking behind himself, then he sat on the wall. At 9.32 am he walked away again, half jogging back along Cardinal Avenue, towards Latchmere Lane. I then lost sight of him. At 9.40 am, I discontinued the observation.

Signed C. Plummer Signature witnessed by

No. 991A

Witness Statement Page 8

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Colin SIMPSON

Age of Witness (date of birth) 43 (9 December 1948)

Occupation of Witness Police Officer

Dated 25 August 1992

On Saturday 8th August 1992 I was on duty in plain clothes at Durlston Road, Kingston near the junction with Cardinal Avenue, close to a BT phone kiosk. At about 9.15 am I saw a man, whom had previously been described to me, walk briskly towards my location along Cardinal Avenue. He wore a pale purple shirt and pale blue jeans. For approximately one minute he stood both beside the phone kiosk and also in the kiosk. I took photographs of the man while he was at the phone kiosk. He then walked briskly away from my location northwards in Hollybush Road. A few minutes later at about 9.25 am he returned to my location. He stood beside the phone kiosk and then sat on the low wall beside the phone kiosk. I again took photographs of him. After a couple of minutes he walked away eastwards in Cardinal Avenue and out of my view. I submit photographs, CJS1, from un-retouched negatives which are retained in my possession.

Signed Colin Simpson D/C Signature witnessed by

No. 991A

Witness Statement Page 9

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Stephen BROWN

Age of Witness (date of birth) 40 (27 November 1951)

Occupation of Witness Police Officer

Dated 25 August 1992

On Saturday 8th August 1992 I was on duty in plain clothes in Tudor Drive, Ham close to the junction with Latchmere Lane, near a BT phone kiosk. At about 0925 hrs I saw a man in a purple shirt and light trousers enter Tudor Drive from Hollybush Road near the Cardinal Public House. He was looking towards me and did so for about 30 seconds. He then walked towards the shops away from me before ‘jogging’ back into Hollybush Road. During the time the man was within my sight he was about 200 yards away from me and my view was occasionally obscured by parked cars.

Signed Stephen Brown D/C Signature witnessed by

No. 991A

Witness Statement Page 10

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Kevin KINDLEYSIDES

Age of Witness (date of birth) 45 (9 December 1946)

Occupation of Witness Police Officer

Dated 20 August 1992

On Saturday 8th August 1992 I was on duty in plain clothes at Tudor Drive, Ham, near the junction with Latchmere Lane, close to a BT phone kiosk at that location. At about 9.25 am I saw a man in a pale purple shirt and pale slacks, possibly jeans, jog into Tudor Drive from Hollybush Road by the Cardinal public house. He stopped in front of the public house, by a pillar box, looking in my direction for about 30 seconds. He then walked around by the shops next to the public house, before slowly jogging away into Hollybush Road. During the time the man was in my view he was about 200 yards away and occasionally lost to my sight behind parked vehicles.

On Tuesday 11th August 1992 at about 2 pm I went to the Harrow-on-the-Hill area and took a number of black and white photographs in the Church Hill vicinity. These photographs, in an album, I produce as KK/1. The un-retouched negatives are retained in my possession.

Signed K. Kindleysides DC Signature witnessed by

No. 991A

Witness Statement Page 11

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC John COLLINS

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer

Dated 12 August 1992

On Saturday 8th August 1992, I was engaged with other officers on an operation in the area of Kingston-upon-Thames. Following a briefing by DCI MacKENZIE during which I was given a description of a man and a woman who were living at Burton Road, Kingston-upon-Thames. I arrived in the area at 8.30 am to take up observation. At 9.32 am in Kings Road I saw a man I recognise from the description at the briefing and from my fellow officers that morning. I saw him walking along Kings Road and enter premises which I thought was the newsagents. At 9.40 am I ceased observations.

Signed John Collins Signature witnessed by

No. 991A

Witness Statement Page 12

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DCI Hector MACKENZIE

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Chief Inspector

Dated 12 August 1992

On Friday 7th August 1992 at New Scotland Yard I was briefed by Detective Superintendent MacLEOD regarding a surveillance operation in the Kingston-upon-Thames area. On Saturday 8th August 1992 in that area, I briefed my Surveillance Unit regarding the male and female occupants of 48a Burton Road, Kingston-upon-Thames. I then handed over the briefing to Team Leader Detective Sergeant GREGORY-PARRY who deployed his team accordingly. He also recorded all transmissions contemporaneously, the officers being identified by their dedicated call signs which they endorse as correct by later signing their personally issued police warrant numbers against their respective recorded transmissions.

Signed Hector MacKenzie DCI Signature witnessed by

No. 991A

Witness Statement Page 13

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DS Keith GREGORY-PARRY

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Sergeant

Dated 12 August 1992

On Saturday 8th August 1992 following a briefing by DCI MacKENZIE, I deployed officers on an operation in the Kingston-upon-Thames area of London. During the course of the operation I kept a contemporaneous record of all transmissions made by those officers, the operation commenced at 8.30 am and concluded at 9.40 am.

Signed K. Gregory-Parry DS Signature witnessed by

No. 991A

Witness Statement Page 14

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DI Martin NICOLSON

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Inspector 14/159579

Address and Telephone Number New Scotland Yard, Broadway, London SW1

Dated 1 September 1992

This statement, (consisting of 3 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

On Saturday 8th August 1992 at approximately 9 am I was on duty in plain clothes in an unmarked police vehicle, registration F709 OUL in company with DS PEPE and DC KELLY and situated in Kings Road Kingston-upon-Thames, Surrey, while engaged on a police operation. At about 9.25 am as a result of information received via the police radio we went to Park Farm Road, Kingston where we parked at the North footway, facing East. At about 9.33 am I saw a white male wearing a purple ‘T’ shirt and blue jeans jogging South in Staunton Road across the junction with Park Farm Road and out of my sight. We turned the vehicle round and then parked at the same place but facing West. At about 9.37 am I saw the same man in the purple ‘T’ shirt and jeans, now known to me as Michael John SMITH, walking into Park Farm Road from Chesfield Road. He was carrying a newspaper as he walked in my direction on the South footway. Accompanied by DS PEPE I got out of the vehicle and approached SMITH while holding my Warrant Card opened towards him. I said to SMITH ‘I’m Detective Inspector NICOLSON, Special Branch’. SMITH stopped and took a step back. I took hold of his left arm and said ‘I am arresting you for communicating classified information to a hostile agency. This is an offence against the Official Secrets Act. You do not have to say anything unless you wish to do so but what you say may be given in evidence’. SMITH stared at me and DS PEPE said ‘Sir, we are police officers’. SMITH became tense and started to pull away from me at

Signed M. Nicolson D/I Signature witnessed by

No. 991A

Witness Statement Page 15

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DI Martin Nicolson

which point DS PEPE took hold of SMITH’s right arm. SMITH became more tense and then said, ‘What’s going on. I don’t want my neighbours to see’. DS PEPE told SMITH that he was going to handcuff him to prevent his escape and then applied the handcuffs to SMITH with his arms behind his back. As he was doing so SMITH was struggling slightly and looking in the direction of 48A Burton Road, his home address, he commented, ‘My wife’. SMITH was then escorted to the vehicle and placed in the rear seat, where he was accompanied by DS PEPE. I entered the front passenger seat and with DC KELLY driving we moved off towards Kingston town centre. SMITH demanded shrilly to know where he was being taken, and after being told that he was being taken to Paddington Police Station he began complaining about the handcuffs hurting him. I was aware as we drove South in Richmond Road that SMITH was becoming increasingly restless and all the while complaining about the handcuffs. At some point near to Kingston town centre, and while I was making a note of the arrest, SMITH suddenly started shouting loudly ‘I’m being kidnapped. Help me’, and he began struggling violently and was kicking at the front seats. As it was impractical to continue the journey I called for assistance and the use of a police van via the police radio and directed DC KELLY to stop the vehicle, which he did outside of John Lewis departmental store in Kingston. DS PEPE was managing to restrain SMITH in the rear seat until uniformed officers arrived at the scene. SMITH initially resisted attempts to be removed from our vehicle but was then taken out and transferred to a marked police van, escorted by DS PEPE and a uniformed police constable. This was at approximately 9.50 am. With DC KELLY I followed the van to Paddington Police Station, arriving at about 10.17 am. In the station yard DS PEPE escorted SMITH to my vehicle and in my presence and that of PS 19DD Anthony DAVIES, DC KELLY searched the rear seat area and recovered a watch and a newspaper which SMITH identified as his property. He was then taken into the Custody Suite where I related the facts of SMITH’s detention to the Custody Officer in his

Signed M. Nicolson D/I Signature witnessed by

No. 991C

Witness Statement Page 16

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DI Martin Nicolson

presence. In an Interview Room at Paddington Police Station later on this day, between 3.05 pm and 3.31 pm an interview was conducted between Michael SMITH, DS PEPE and myself. This interview was recorded on audio tape. I now produce the tape, seal number T497086, as exhibit MN/1. On Sunday 9th August 1992 at about 9 pm, in company with DCI GRAY, at Hirst Research Centre, East Lane, Wembley, Middlesex, I met with Dr Steven CUNDY, Director of this establishment, and Mr Gerald SWALLOW, the manager of Microwave and Packaging Division with Hirst Research Centre. I explained that I was engaged in the investigation of offences against the Official Secrets Act for which Michael John SMITH had been detained and asked them to examine a number of documents and articles which had been found in a search of premises controlled by Michael SMITH. These documents and articles were contained in sealed bags marked JS/14 - JS/38 inclusive. I asked Dr CUNDY and Mr SWALLOW to make notes of their assessment of these items. At the conclusion of their examination I asked each of them to sign, date and time their notes and then took possession of them. I now produce their original notes as exhibits, numbered as follows: Dr CUNDY’s pages 1 and 2 MN/2, pages 3 and 4 MN/3, page 5 MN/4; Mr SWALLOW’s pages 1 and 2 MN/5, pages 3 and 4 MN/6, page 5 MN/7. On Tuesday 11th August 1992 at Hirst Research Centre, East Lane, Wembley, Middlesex, I received from Dr Steven CUNDY an Official Secrets Act Declaration form signed by M J SMITH on 15th July 1986 and witnessed by G D PRICHARD. I now produce this document as exhibit MN/8. On Friday 14th August 1992 at Hirst Research Centre, East Lane, Wembley, Middlesex, I received from Dr Steven CUNDY the following items which I now produce as exhibits; the personnel file from Hirst Research Centre on Michael John SMITH (MN/9), a Hirst Research Centre Report dated July 1989 - June 1990 (MN/10), a Hirst Research Centre Report dated July 1990 - June 1991 (MN/11), a handwritten document in a yellow folder (MN/12), and an Audit Schedule printout for the QA Department at Hirst Research Centre (MN/13).

Signed M. Nicolson Signature witnessed by

No. 991C

Witness Statement Page 17

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DS Garry PEPE

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Sergeant 71/183110

Dated 12 August 1992

On Saturday 8th August 1992, I was on duty in plain clothes in an unmarked police vehicle in company with DI NICHOLSON and DC KELLY. At 9 am we were parked in King’s Road, Kingston, as part of a police operation. As a result of information received via a police radio we went at about 9.25 am to Park Farm Road and waited. We were facing East. At about 9.33 am, I saw a white man wearing a purple T-shirt, jeans with dark hair jog South in Staunton Road, across the junction of Park Farm Road and out of my sight. We turned the vehicle around and faced West against the North footway about 10/15 yards from the junction of Burton Road. I saw the same man wearing the purple T-shirt walk into Park Farm Road from Chesfield Road and walk West on the South footway. I noticed he was holding a newspaper. I now know this man to be Mr SMITH. DI NICHOLSON and I got out of the vehicle and approached Mr SMITH. DI NICHOLSON showed Mr SMITH his warrant card as did I. DI NICHOLSON said, “I am Detective Inspector NICHOLSON from Special Branch.” SMITH stopped and took a step backwards. DI NICHOLSON took his left arm and said, “I am arresting you for communicating classified information to a hostile agency, this is an offence against the Official Secrets Act” and cautioned him. Mr SMITH stared at DI NICHOLSON. I said, “Sir, we are police officers”, still showing my

Signed G. Pepe Signature witnessed by

No. 991A

Witness Statement Page 18

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Garry PEPE

warrant card. I took told of his right arm as he pulled away from DI NICHOLSON. SMITH tensed up and said, “What’s going on, I don’t want my neighbours to see.” I handcuffed SMITH, with his hands behind his back in order that he could not escape. He was placed in the rear nearside of the vehicle and I sat next to him. Mr SMITH complained that his handcuffs were hurting him. I tried to release one of the cuffs but he was moving around. He demanded to know where he was going and I told him we were going to the police station. I could not adjust his handcuffs to his satisfaction, although there was a space between his hands and the cuffs. I removed his watch in order to allow greater room and placed it between his legs. At the time of his arrest when handcuffed I took possession of his keys which he was holding. He continued to talk about his being handcuffed and was becoming agitated. As we passed Kingston Railway Bridge SMITH turned to me and stopped moving around and stared and said, “You’re not the police. I know who you are.” He leaned towards the door and shouted and screamed at the window, “I’m being kidnapped, help me, I’m being kidnapped.” I restrained him and calmed him down. We drove to outside JOHN LEWIS in Kingston and I put plastic cuffs on him and removed the metal ones. With the assistance of uniformed officers he was transferred to a marked police van, after refusing to get out of the car saying, I’m not getting out with all these people looking.” I sat next to SMITH in the police van with a uniformed officer present. SMITH was taken to Paddington Green Police Station. We arrived at the station and the van was searched. We then went to the unmarked police vehicle which he had been in earlier and retrieved his watch and newspaper. The facts of his arrest were related to the custody officer by DI NICHOLSON and I searched SMITH once his detention had been

Signed G. Pepe Signature witnessed by

No. 991C

Witness Statement Page 19

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Garry PEPE

authorised. I took possession of a quantity of tissues from his person (GP/1), a quantity of credit cards (GP/3) and a quantity of receipts (GP/2). At 3.05 pm I was present at an interview conducted by DI NICHOLSON of SMITH in the first floor interview room of Paddington Green Police Station. This interview was concluded at 3.31 pm.

Signed G. Pepe Signature witnessed by

No. 991C

Witness Statement Page 20

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Hugh KELLY

Age of Witness (date of birth) Over 21 (14 September 1953)

Occupation of Witness Police Officer

Dated 17 August 1992

On Saturday 8th August 1992 at 9.00 hours I was on police duty in plain clothes in an unmarked police vehicle, a Ford Sierra, index number F709 OUL, in Kings Road, Kingston-upon-Thames. As a result of information received from other police officers, via the police radio, at approximately 09.25 hours I drove the vehicle F709 OUL, with DI NICOLSON and DS PEPE as passengers to Park Farm Road, Kingston-upon-Thames and waited there having parked the vehicle against the North footway facing East. I then turned the vehicle round within approximately thirty yards and parked in a similar position but now the vehicle was facing West and was almost opposite the address of 48a Burton Road, Kingston-upon-Thames. I saw DI NICOLSON get out of the front passenger seat of the vehicle and DS PEPE get out of the off-side rear door of the vehicle as it was parked. I saw them approach a man in a purple ‘T’ shirt and blue jeans whom I now know to be Michael John SMITH. I was the driver of the vehicle and consequently this was the first time I had seen the man SMITH. DI NICOLSON and DS PEPE crossed over Park Farm Road whilst I remained in the vehicle. I saw DI NICOLSON and DS PEPE show their warrant cards to SMITH and engage him in conversation. I then saw DI NICOLSON take hold of SMITH’s left arm but I did not hear anything that was said. I saw SMITH begin to pull away from DI

Signed H. Kelly Signature witnessed by

No. 991A

Witness Statement Page 21

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Hugh Kelly

NICOLSON and DS PEPE get hold of his right arm. At this point I saw SMITH go very tense and I saw him say something but I do not know what. I saw DS PEPE place handcuffs on SMITH and I saw SMITH begin to struggle and look towards his flat at 48a Burton Road. DI NICOLSON and DS PEPE made SMITH walk across the road to the police vehicle (F709 OUL) in which I was sitting in the driver’s seat. They placed SMITH in the off-side rear of the vehicle as it was parked. SMITH was complaining to DS PEPE that his handcuffs were placed too tightly around his wrists. I then drove the vehicle away towards the centre of Kingston-upon-Thames. SMITH demanded to know where we were going and DS PEPE was attempting to calm SMITH down as we drove South along Richmond Road, Kingston-upon-Thames. SMITH suddenly started shouting, “I’m being kidnapped, help me”. It was a hot day and I was driving with my driver’s door window opened which I tried to close, this was not easy because SMITH began to struggle violently, the car began to rock and was very difficult to keep on the road. DI NICOLSON called for urgent assistance on the police radio and I heard him asking for a police van. I drove into Clarence Road, Kingston-upon-Thames and stopped the vehicle outside JOHN LEWIS Department Store. DS PEPE was leaning over SMITH and trying to restrain him. At this point uniformed officers arrived in three vehicles. SMITH continued to struggle and refused to get out of the police car. AT 9.50 hours approximately SMITH was escorted, eventually, by DS PEPE and a uniformed police officer into a waiting police van. DI NICOLSON and myself then got back into police vehicle F709 OUL and drove to Paddington Green Police Station as part of a three vehicle police convoy. We arrived in the yard of Paddington Green Police Station at 10.17 hours. DS PEPE then brought SMITH over to our police vehicle in which he had

Signed H. Kelly Signature witnessed by

No. 991C

Witness Statement Page 22

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Hugh Kelly

been placed initially after arrest. In the presence of DI NICOLSON, DS PEPE, PS 19 DD Anthony DAVIES and SMITH I searched the vehicle F709 OUL and from the rear seat of that vehicle I retrieved a wrist watch and a newspaper which SMITH then identified as belonging to him. SMITH was then taken into the Custody Suite at Paddington Green Police Station where DI NICOLSON gave the facts relating to SMITH’s detention to the Custody Officer. Whilst at Paddington Green Police Station DS PEPE and myself conducted a strip search of SMITH in the Force Medical Examiner’s Room. DS PEPE, SMITH and myself then returned to the Custody Suite to complete the procedure for SMITH’s detention.

Signed H. Kelly Signature witnessed by

No. 991C

Witness Statement Page 23

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Bruce FOX

Age of Witness (date of birth) Over 21

Occupation of Witness Police officer PC 101 SW

Dated 19 August 1992

On Saturday 8th August 1992 at 9.45 am I was on duty in full uniform with PC 225 VK SEYMOUR on mobile patrol in a marked police vehicle. I received a message via my PR to attend outside JOHN LEWIS PLC, Wood Street, Kingston, where plain clothes police officers had arrested a suspect who was now becoming violent. On my arrival I saw a blue Ford Sierra motor vehicle stationary in Wood Street. A marked police dog van was also on scene. The two officers from this vehicle went to the rear nearside door of the Sierra. The two Dog Patrol Officers opened the door, inside the vehicle sat on the rear seat was a man who I now know to be a Mr SMITH. A plain clothes officer got out of the front passenger seat of the vehicle and said to me, “this man has been arrested, I want him taken directly to DD.” Mr SMITH was in handcuffs and sat next to him was another plain clothes police officer. One of the dog handlers said to Mr SMITH, “Please get out of the vehicle and get into the van.” Mr SMITH said, “Let go or else, I’m staying here.” The incident had drawn a large crowd of local shoppers. Further attempts were made to persuade Mr SMITH to leave the back of the Sierra. Mr SMITH refused to leave. One dog officer took hold of Mr SMITH’s left trouser leg and pulled his leg out of the car and handed it to me. I held his leg. The dog handler then took hold of his other leg. He was then pulled out of the

Signed B. Fox Signature witnessed by

No. 991A

Witness Statement Page 24

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF PC Bruce FOX

vehicle. As he was half way out the dog handler said to Mr SMITH, “Are you going to walk.” He said, “Yes.” He then stood. Both dog handlers then took hold of Mr SMITH’s arms and walked him to the van. He was placed in the police van at 9.50 hours. I then sat in the rear of the van with a plain clothes detective. As soon as the van doors were closed the detective removed Mr SMITH’s handcuffs. He was then taken to Paddington Green Police Station where he was taken to the charge room by detectives. He arrived at Paddington at 10.17 hours. At no time was unreasonable force used on Mr SMITH whilst he was in my sight. All officers acted in a correct and polite manner with Mr SMITH. I searched the police van in Mr SMITH’s presence both before and just after his entering and leaving the van. On both occasions I found nothing of interest

Further to my above statement the plain clothes detective in the rear of the Sierra and who accompanied both Mr SMITH and myself in the van was a DS PEPE. The officer who directed that Mr SMITH be taken to Paddington Police Station was a DI NICOLSON. I now know that Mr Michael John SMITH is the man who was arrested on the above day.

Signed B. Fox Signature witnessed by

No. 991C

Witness Statement Page 25

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Jan SEYMOUR PC 225VK

Age of Witness (date of birth) Over 21

Occupation of Witness Police Constable (178740)

Dated 25 August 1992

On Saturday 8th August 1992 I was on duty in uniform employed as the driver of a marked police van, accompanied by PC 232VK FOX. At 9.45 am I heard over my personal radio that plain clothes officers required assistance with a prisoner who had become violent outside JOHN LEWIS’ department store, Wood Street, Kingston. Upon arrival, I saw a blue Ford Sierra motor vehicle stationary in Wood Street with a marked police dog van parked alongside. The two dog handlers went to the rear nearside door of the Sierra and PC FOX joined them. As I got closer, one of the plain clothes officers, DI NICOLSON, got out of the front passenger seat and said, “This man has been arrested, I want him taken directly to DD.” He indicated a male sitting in the rear of the Sierra, whom I now know to be Michael John SMITH. He was handcuffed and another plain clothed officer was sat beside him. One of the dog handlers said to SMITH, “Please get out of the vehicle and get into the van.” SMITH said, “Let go or else, I’m staying here.” Despite several attempts to persuade him to get out of the vehicle, SMITH continued to refuse. I then left the Sierra and went to the rear of my van to open the doors. As I returned to the Sierra, I saw PC FOX and one of the dog handlers start to lift SMITH from the Sierra. A brief conversation then took place and both the officers released SMITH and he stood

Signed Jan Seymour PC225VK Signature witnessed by

No. 991A

Witness Statement Page 26

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF PC Jan SEYMOUR PC225VK

up. He was then accompanied to the van by the dog handlers followed by PC FOX and the plain clothed officers. SMITH was placed in the van at 9.50 am and was joined inside the rear cage by PC FOX and one of the plain clothed officers, DS PEPE. I closed and locked the rear doors and then drove the van to Paddington Green Police Station arriving there at 10.17 am. SMITH was taken by officers who had been awaiting our arrival to the charge room and I had no further contact with him.

Signed Jan Seymour PC225VK Signature witnessed by

No. 991C

Witness Statement Page 27

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Robert COUCH

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer PC 519SW

Dated 25 August 1992

On Saturday 8th August 1992 at about 9.45 I was on duty correctly dressed in full uniform with PC466SW FIELD in Area Zero five six dog van, when I heard a message over the force R/T that police needed assistance outside JOHN LEWIS STORE in Wood Street, Kingston. On my arrival I saw a blue Ford Sierra motor car stationary in Wood Street. I saw two men sitting in the rear seats, and another man standing near to the vehicle, who on my arrival he introduced himself as DI NICHOLSON, and asked myself and PC FIELD to escort one male, who I now know to be Mr John SMITH to a police van that had pulled up behind me. We went to the rear nearside door of the Sierra. PC FIELD opened the door and said to Mr SMITH, “Please get out of the vehicle and get into the van.” Mr SMITH said, “Let go or else, I’m staying here.” Mr SMITH refused to leave the vehicle. I took hold of Mr SMITH’s left trouser leg, just above his foot and lifted his legs from the car. I was helped by another uniform officer, with PC FIELD he was assisted from the Sierra. PC FIELD said, “Are you going to walk.” He said, “Yes.” He then walked with our assistance and got into the back of a police van at about 9.50 am. He was then driven from the scene, escorted by a traffic patrol vehicle, and PC466SW and myself left the scene.

Signed R. Couch PC 519SW Signature witnessed by

No. 991A

Witness Statement Page 28

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Terence John FIELD

Age of Witness (date of birth) 18 March 1953

Occupation of Witness Police Constable 76/166431

Address and Telephone Number 5HQ Dog Section, Teddington Police Station

Dated 24 September 1992

On Saturday 8th August 1992 I was on mobile uniformed patrol in company with PC 519 SW COUCH. At about 0945 hrs I heard a force R/T message to the effect that police needed assistance outside the John Lewis Store in Wood Street Kingston. On arrival outside the store I saw a blue Ford Sierra motor vehicle stationary in the street. One man was outside the vehicle and I could see two people in the rear of the vehicle. The man outside the vehicle introduced himself as D.I. Nicholson and produced a warrant card he then asked myself and PC COUCH to assist in transferring one of the males from the back of the Sierra to a uniformed police van that had arrived on scene. I now know this person to be Mr John SMITH. I opened the Sierra door and said to SMITH “Please get out of the vehicle and get into the van”. SMITH said “let go or else, I’m staying here”. He refused to leave the Sierra and with the help of other uniformed officers SMITH was removed from the vehicle. I had hold of his left arm and my other arm was behind his back. When he was out of the vehicle I said to him “Are you going to walk” he said “yes”. He then walked to the police van and was driven away escorted by a traffic patrol car. I then left the scene.

Signed T. J. Field Signature witnessed by

No. 991A

Witness Statement Page 29

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DI Martin MORRISSEY

Age of Witness (date of birth) 23 October 1958

Occupation of Witness Detective Inspector (176793)

Dated 26 August 1992

On Saturday 8th August 1992 I was on duty at 9.30 am when, in company with DC WILLIAMS, I entered 48A Burton Road, Kingston-upon-Thames. I was in possession of a search warrant for the premises and also two further search warrants relating to two motor vehicles, a Datsun index KJH 249W and a Peugeot index D514 BLD. In the house at this time were DS BEELS, DS GILBERTSON and DC ROBSON, along with a woman I now know as Mrs Pamela Avril SMITH. I went into the house and to the lounge and remained there until DS BEELS told me he was about to leave the premises. This was about 9.50 am at which time I informed Mrs SMITH that I proposed to search the premises under the authority of a warrant and asked her to point out the keys to the motor cars and her house keys which she gave to me. At about 10 am the officers who were to conduct the search entered the premises, namely DS SMITH, followed by DS HUDSON, DS MALCOLM, DC ROSS, DC TYLER, DC RAWLINGS, DC COX, and Mr ‘A’ of the Security Service who was present in a solely advisory capacity. After a short assessment and briefing the search commenced at 10.30 am. I have drawn a sketch plan, not to scale, of the premises which I submit with exhibit identification mark MSM/1 thereon. I had been instructed as officer in charge of the search and also acted as exhibits officer for the search. The method

Signed Martin Morrissey D/I Signature witnessed by

No. 991A

Witness Statement Page 30

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DI Martin MORRISSEY

employed by the officers was, on finding an item they decided to exhibit, to make notes in their own notebook as to the circumstances of the finding as soon as practicable and then as soon as possible to bring the item to me, in an exhibit bag. I then recorded the handing of the item to me contemporaneously in an exhibit book and sealed, as necessary, the item in the officer’s presence and retained it in my possession until such time as it was collected and taken to DS SINGLETON, which transaction was again recorded contemporaneously. The search was conducted between 10.30 am and 9.30 pm on Saturday 8th August, 8 am and 9.30 pm on Sunday 9th August and 8 am and 4.45 pm on Monday 10th August. Outside these hours the premises were left in the occupation of DC ASHTON and DC MOORE. On the afternoon of Saturday 8th August for reasons of security and privacy I directed that the two motor vehicles for which I held warrants be driven to Kingston Police Station and this was done by PC 469 VK and PC 589 VK along with DC TYLER and DC RAWLINGS who conducted the search of the vehicles on Sunday 9th August. DC WILLIAMS, DC COX and DS MALCOLM were not present at the search on Monday 10th August. At the conclusion of the search of the premises and of the vehicles I endorsed the warrants as required and along with a ‘notice of powers and rights’ left copies at the top of the stairs on a sideboard, and in the glove compartment of each vehicle.

Signed Martin Morrissey D/I Signature witnessed by

No. 991C

Witness Statement Page 31

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Stephen UPSHALL 173985

Age of Witness (date of birth) Over 21

Occupation of Witness Police Constable

Dated 4 September 1992

On Saturday the 8th August 1992 I was on duty in uniform driving a marked police vehicle. As a result of information from PS 8 MORGAN, myself and PC 589 HEATH went to the vicinity of 48A Burton Road, Kingston. At this location I was met by plain clothes officers who handed to me a set of keys belonging to a silver motor vehicle index KJH 249W. I then drove the vehicle direct to Kingston Police Station where I placed the vehicle undercover and secured the vehicle. I then handed the keys to DC TYLER in the front office of Kingston. I completed a 132 entry (132/157/92). At no time did I search the vehicle.

Signed S. Upshall Signature witnessed by

No. 991A

Witness Statement Page 32

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Alan David TYLER

Age of Witness (date of birth) 41 (6 August 1951)

Occupation of Witness Detective Constable

Dated 25 August 1992

On Saturday, 8th August 1992, at approximately 10.10 am, I entered the premises of 48A Burton Road, Kingston-upon-Thames, Surrey, as part of a search team. Present on my entry were DI MORRISSEY, DS SMITH and DC WILLIAMS. Following a briefing and assessment of the premises I commenced a search of the bathroom, in company with DC RAWLINGS at 10.30 am. In respect of exhibits, the following guidelines were adhered to throughout the course of the search; in the case of each item, notes were made in my pocket book as soon as practicable after the finding, the exhibits were then placed in an exhibit bag and handed to DI MORRISSEY, the exhibits officer, as soon as possible after the initial finding. A chronological list of exhibits that I found or witnessed being found at the house now follows: At 7.40 pm I witnessed the finding by DC RAWLINGS of a quantity of correspondence and a miniature address book in the right hand drawer of the dresser in the hall (SR/1). The following day, Sunday, 9th August 1992, the search recommenced at 8.00 am. At 9.00 am I witnessed DC RAWLINGS find a business card in the name of ASPI MULLA, in the middle drawer of the dresser in the hall (SR/2). At 7.40 pm whilst searching the bedroom I found in an envelope on the floor on the far side of the bed to the door a bank statement in the name of MICHAEL JOHN SMITH, dated 5th August 1992 (ADT/1).

Signed Alan Tyler, Detective Constable Signature witnessed by

No. 991A

Witness Statement Page 33

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Alan David TYLER

Whilst searching the bedroom shelves in the chimney alcove with DC COX, I witnessed him find the following items: a Russian made slide projector at 8.10 pm (SC/8), a Kodak instamatic camera at 8.15 pm (SC/9), a map of Moscow at 8.25 pm (SC/10), a tennis racquet at 8.35 pm (SC/11). On Monday, 10th August 1992, the search of 48A Burton Road, Kingston-upon-Thames recommenced at 8.00 am. At 10.55 am I was handed 13 exhibits by DI MORRISEY for transportation to Paddington Green Police Station. These 13 exhibits were handed by myself to DS SINGLETON at Paddington Green Police Station at 12.05 pm. Upon return to 48A Burton Road, at 2.35 pm I found in the right hand drawer of the dresser in the hallway a receipt for the London Guitar Studio (ADT/2). The search of the house concluded at 4.45 pm that day. With respect to Mr and Mrs SMITH’s vehicles, on Saturday, 8th August 1992, under the instructions of DI MORRISSEY, a Datsun motor vehicle, index number KJH 249W and a Peugeot motor vehicle, index number D514 BLD, were driven from Burton Road to Kingston Police Station. The Datsun and Peugeot being driven by PC 469 VK and PC 589 VK respectively and followed in a police vehicle by DC RAWLINGS and myself. Both vehicles were parked and safely secured under cover in the Police Station yard, the keys being deposited and recorded with the Station Officer. On Sunday, 9th August 1992 I returned to Kingston Police Station with DC RAWLINGS and at 10.50 am in the Station yard we commenced a search of the Datsun motor vehicle, index number KJH 249W; adhering to searching guidelines throughout. At 11.40 am I witnessed DC RAWLINGS find one sheet of lined paper containing technical writing thereon in a plastic bag which was under the carpet of the front driver’s side floor well (SR/3). In the boot of the vehicle, at 12.15 pm I

Signed Alan Tyler, Detective Constable Signature witnessed by

No. 991C

Witness Statement Page 34

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Alan David TYLER

witnessed DC RAWLINGS find a blue holdall with white trim, inside which was a quantity of correspondence and components within a Sainsbury’s carrier bag, covered by a blue plastic carrier bag (SR/4). Together with DC RAWLINGS I returned to 48A Burton Road, Kingston with exhibits (SR/3) and (SR/4) which were handed to DI MORRISSEY at 1.00 pm. The search of the Datsun vehicle recommenced at 2.15 pm in the Station yard of Kingston Police Station, the searching officers again being myself and DC RAWLINGS. At 2.25 pm in the boot of Datsun, index KJH 249W, I witnessed DC RAWLINGS find a piece of paper with writing thereon, inside a carrier bag (SR/5). At 2.35 pm DC RAWLINGS and myself commenced a search of the Peugeot motor vehicle, index D514 BLD, in the Station Yard of Kingston Police Station. The search of this vehicle terminated at 4.00pm. Both sets of keys for the vehicles were returned to the Station Officer at Kingston once the cars had again been secured. A copy of the search warrant and notice of rights were endorsed as executed and left in the glove compartment of each vehicle. Exhibit (SR/5) was handed to DI MORRISSEY at 5.00 pm that day. On Wednesday, 19th August 1992, as a result of what I was told by DCI GRAY, I returned to Kingston Police Station where I met BOB ISTED, a photographer from SO3. I obtained the keys for the Datsun vehicle, index number KJH 249W, from the Prisoners Property Officer and between 10.40 am and 11.00 am I accompanied Mr ISTED while he took photographs of the vehicle. Particular attention was paid to the front driver’s floor well and to the boot area where the exhibits had been found. I thoroughly and carefully re-examined the front driver’s floor well and could find no evidence of any holes, damage or repairs. In view of the age of the vehicle it was in very good structural condition.

Signed Alan Tyler, Detective Constable Signature witnessed by

No. 991C

Witness Statement Page 35

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Alan David TYLER

Age of Witness (date of birth) 41 (6 August 1951)

Occupation of Witness Detective Constable

Dated 21 September 1992

On Wednesday, 2 September 1992, I initiated enquiries through the Driver and Vehicle Licensing Agency DLVA Liaison, TO25 (CTB), regarding the registered owner of a silver Datsun Cherry saloon, index KJH 249W. On Monday, 21 September 1992 I received a computer printout from the Driver and Vehicle Licensing Centre which showed that this vehicle has been registered to Michael John SMITH, 48A Burton Road, Kingston upon Thames, KT2 5TF, since 14 May 1983. The vehicle, currently licensed until 1 November 1992 is still registered in his name. I exhibit this DLVC printout as ADT/3.

Signed Alan Tyler, Detective Constable Signature witnessed by

No. 991A

Witness Statement Page 36

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Sian RAWLINGS

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Constable

Address and Telephone Number New Scotland Yard

Dated 24 August 1992

This statement, (consisting of 4 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

On Saturday 8th August 1992 at approximately 10.10 am, I entered the premises of 48A Burton Road, Kingston-upon-Thames, Surrey, as part of a search team. Present on my entry were DI MORRISSEY, DS SMITH and DC WILLIAMS. Following a briefing and an assessment of the premises I commenced a search of the bathroom together with DC TYLER at 10.30 am. In respect of exhibits, the following guidelines were adhered to throughout the course of the search: in the case of each item, notes were made in my pocket book as soon as practicable after the finding, the exhibits were then placed in an exhibits bag and handed to DI MORRISSEY, the exhibits officer, as soon as possible after the initial finding. A chronological listing of exhibits that I found, or witnessed being found at the house, now follows. A search of the bathroom and the kitchen did not produce any exhibits. At 7.40 pm I found a quantity of correspondence and a miniature address book in the right-hand drawer of the dresser in the hall (SR/1), which was witnessed by DC TYLER. The following day, Sunday, 9th August 1992 the search recommenced at 8.00 am. At 9.00 am I found a business

Signed S. Rawlings Signature witnessed by

No. 991A

Witness Statement Page 37

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Sian RAWLINGS

card in the name of ASPI MULLA, in the middle drawer of the dresser in the hall (SR/2), which was witnessed by DC TYLER. At 7.30 pm I found a RICOH camera and booklet in a brown holdall on a bedside trolley at the far side of the bedroom (SR/6), which was witnessed by DS HUDSON. Also at 7.30 pm I witnessed DS HUDSON finding a British passport in the name of Mr M. J. SMITH in the same location (RH/20). At 8.15 pm I again witnessed DS HUDSON finding another British passport in the name of M. J. SMITH in a navy suitcase which was on the floor next to the bookshelves in the bedroom (RH/21). In the said same navy suitcase, I found a map of the Eastern States of the USA and a map of Chicago with markings thereon at 8.20 pm (SR/7). At 8.23 pm in the navy suitcase I found an address book (SR/8). Both (SR/7) and (SR/8) were witnessed by DS HUDSON. On Monday, 10th August 1992, the search of 48A Burton Road recommenced at 8.00 am. At 10.55 am DI MORRISSEY handed a quantity of exhibits to DC TYLER. At 11.10 am I then accompanied DC TYLER to Paddington Police Station with the exhibits. Following my return to 48A Burton Road, at 2 pm, in the centre drawer of the dresser in the hallway, I found a quantity of photographs (SR/9). At 2.10 pm, in the left-hand drawer of the table in the bedroom, I found a quantity of receipts and photographs (SR/10). In the built-in wardrobe of the bedroom, also at 2.10 pm, I found a box containing documents (SR/11). A quantity of hotel books and maps of France were found by myself at 2.20 pm, in a brown holdall on the bedside-trolley at the far side of the bedroom (SR/12). In the right-hand

Signed S. Rawlings Signature witnessed by

No. 991C

Witness Statement Page 38

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Sian RAWLINGS

drawer of the table in the bedroom, at 2.25 pm, I found a quantity of maps, personal correspondence and receipts (SR/13). DS HUDSON and myself searched a bedside cabinet in the bedroom. At 2.45 pm I found a quantity of financial correspondence relating to Mrs P. A. SMITH (SR/14) which was witnessed by DS HUDSON, and at 2.50 pm I witnessed DS HUDSON finding a British passport, marriage certificate and international driving licence belonging to Mrs P. A. SMITH (RH/31). The search of the house concluded at 4.45 pm that day. With respect to Mr and Mrs SMITH’s vehicles, on Saturday, 8th August 1992, under the instructions of DI MORRISSEY, a Datsun motor vehicle, index number KJH 249W and a Peugeot motor vehicle, index number D514 BLD, were driven from Burton Road to Kingston Police Station. The Datsun and Peugeot being driven by PC 469 VK and PC 589 VK respectively, and followed in a police vehicle by myself and DC TYLER. Both vehicles were parked in the station-yard under cover and locked. The keys were deposited with the Station Officer at the Police Station. On Sunday, 9th August 1992 at 10.50 am in the station-yard of Kingston Police Station, DC TYLER and myself commenced a search of the Datsun motor vehicle index number KJH 249W; adhering to searching guidelines throughout. At 11.40 am I found one sheet of lined paper containing technical writing in a plastic bag, which was under the carpet of the front driver’s side (SR/3), which was witnessed by DC TYLER. In the boot of the Datsun, at 12.15 pm I found a blue holdall with white trim, inside which was a quantity of

Signed S. Rawlings Signature witnessed by

No. 991C

Witness Statement Page 39

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Sian RAWLINGS

correspondence and components within a ‘Sainsburys’ carrier bag, covered by a blue plastic carrier bag (SR/4), again witnessed by DC TYLER. I returned, together with DC TYLER, to 48A Burton Road with exhibits (SR/3) and (SR/4) which were handed to DI MORRISSEY at 1.00 pm. The search of the Datsun vehicle recommenced at 2.15 pm at Kingston Police Station in the station-yard together with DC TYLER. At 2.25 pm in the boot of the Datsun I found a piece of paper showing an address, which was inside a carrier bag (SR/5), this was witnessed by DC TYLER. At 2.35 pm we began the search of the Peugeot motor vehicle index number D514 BLD, again in the station-yard of Kingston Police Station. The search terminated at 4 pm. Both sets of keys for the vehicles were returned to the Station Officer at Kingston Police Station, Police Sergeant 20 VK. Warrants and notice of rights were left, shown executed, in the glove-compartment of each vehicle. Exhibit (SR/5) was handed to DI MORRISSEY at 5 pm that day.

Signed S. Rawlings Signature witnessed by

No. 991C

Witness Statement Page 40

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Robert Peter ISTED

Age of Witness (date of birth) 14 January 1952

Occupation of Witness Higher Photographic Officer

Address and Telephone Number 2-16 Amelia St, SE17, 0207 708 0508

Dated 19 August 1992

On the 19th August 1992 between the hours of 1040 and 1100 I went to Kingston Police Station and took seven (7) photographs of a Nissan Motor Vehicle and its contents. I now submit these photographs in an indexed album, exhibit No. RP1/1 the un-retouched negatives are held in the Photographic Section.

Signed R.P. Isted Signature witnessed by

No. 991A

Witness Statement Page 41

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Anthony HINE

Age of Witness (date of birth) Over 21

Occupation of Witness Photographer

Dated 27 August 1992

On the 26th August 1992 I took one photograph of exhibit No.JS/14 at Photographic Branch, 2-16 Amelia Street, London, SE17. The un-retouched negative is filed at the Photographic Branch under S/C 10193-92.

Signed A. Hine Signature witnessed by

No. 991A

Witness Statement Page 42

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DS Roseline Mary HUDSON

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Sergeant

Dated 25 August 1992

On Saturday 8th August 1992 at approximately 10.10 am, I entered 48A Burton Road, Kingston-Upon-Thames in company with other officers comprising a search team. Already present at the address were DI Morrissey, DS Smith and DC Williams. We were all briefed by DI Morrissey then commenced searching the premises at 10.30 am. Throughout the course of the search all exhibits found by me were entered into my pocket book and as soon as practicable were placed into an exhibits bag and handed to DI Morrissey, who was the exhibits officer. There follows a list of exhibits found by me in sequential order. At 10.55 am I found a red address book in a carrier bag in the downstairs hall. This is listed as RH/1. At 11.40 am I found a paperback copy of Tolstoy’s Anna Karenina on the bookshelf in the stairway (RH/2). These two finds were both witnessed by DC Cox. At 12.45 pm I found a quantity of National Westminster Bank cheque books and statements which were in a box in the upstairs hall (RH/3). At 3.05 pm I witnessed DC Cox finding a quantity of correspondence in the left inside pocket of a grey tweed jacket found in the hall (SC/1). I also witnessed DC Cox finding the following items; at 3.10 pm a quantity of desk diaries (SC/2) at 3.20 pm a black attaché case and two carrier bags containing

Signed R.M. Hudson Signature witnessed by

No. 991A

Witness Statement Page 43

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Roseline Mary Hudson

documents (SC/3). At 7.30 pm 1 Avo meter in box (SC/4), 1 Pie 1020 Radio (SC/5), 1 Aiwa Stereo System (SC/6) and 1 Kisho Radio cassette player (SC/7). These items were all found in the hall. At 8.00 am the following day, the 9th August, 1992, I recommenced the search at 48A, Burton Road in company with DC Cox. At 8.05 am a quantity of correspondence and letters were found in the top drawer of the sideboard in the hall (RH/4) along with some maps and documents relating to Portugal (RH/5). At 8.10 am a magnifying lens and black plastic slides (RH/6), a receipt for a Fujica camera, dated 29.10.77, with instructions and strap (RH/7) and a mens Seiko watch (RH/8) were found in the same drawer. At 8.30 am also in the top drawer was found a yellow metal gadget in a plastic case (RH/9). These finds were all witnessed by DC Cox. When searching the middle drawer of the sideboard in the hall the following items were found; at 9.00 am a quantity of slides (RH/10) at 9.05 am a pink folder containing correspondence (RH/11) at 9.10 am a quantity of correspondence (RH/12) and at 9.20 am a list of frequencies (RH/13). These finds were also all witnessed by DC Cox. The bottom drawer of the sideboard produced the following items; at 11.00 am a quantity of letters (RH/14). At 11.05 am a quantity of electrical equipment (RH/15). At 11.10 am a Fujica camera with accessories and films (RH/16) and at 11.15 am two pieces of paper (RH/17) and two bank statements (RH/18). These finds were also witnessed by DC Cox. At 18.45 pm I found three tennis racquets in the upper cupboard of the hall (RH/19). These items were not witnessed by DC Cox. At 7.30 pm I found a British passport in the name of Mr M J SMITH, which was found in a brown holdall on the bedside trolley in the bedroom (RH/20). This find was witnessed by DC Rawlings. Also at 7.30 pm I

Signed R.M. Hudson Signature witnessed by

No. 991C

Witness Statement Page 44

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Roseline Mary Hudson

witnessed DC Rawlings finding a RICOH camera in the same brown holdall at the same location (SR/6). At 8.15 pm DC Rawlings witnessed me finding a British passport in the name of M J SMITH which was found in a Navy suitcase which was on the floor next to the bookshelves in the bedroom (RH/21). At 8.20 pm I witnessed DC Rawlings find a map of the Eastern states of the USA and Chicago with markings (SR/7) and at 8.23 pm an address book (SR/8). These were both in the same navy suitcase on the floor next to the bookshelves in the bedroom. The search of 48A Burton Road was recommenced at 8.00 am on 10th August 1992. At 8.52 am, whilst searching the left hand drawer of the bedroom table I found a white envelope addressed to Mr M J SMITH, the envelope contained a letter and four separate sheets of paper (RH/22), this find was witnessed by DS SMITH. I then witnessed DS SMITH finding two brown envelopes, both of which contained a quantity of £50 notes (PMS/24) and (PMS/25). Between 10.05 am and 10.30 am a S03 photographer attended the premises searched and took photographs of exhibits RH/22, PMS/24 and PMS/25. At 8.30 am I found a yellow folder entitled ‘Mikes Investments’ (RH/23) a green folder containing correspondence (RH/24), three brown envelopes containing correspondence (RH/25) and a sheet of paper (RH/26). These items were all found in the left hand drawer of the bedroom table. At 12 noon I found three appointment diaries in a carrier bag under the left hand window in the bedroom (RH/27). At 2.20 pm I found a quantity of slides in the middle drawer of the sideboard in the hall (RH/28). At 2.25 pm I found a quantity of correspondence relating to the USA. In the navy suitcase next to the bookshelves in the bedroom (RH/29). At 2.30 pm I found a quantity of photographs in the top drawer of the sideboard in the hall (RH/30). At 2.45 pm on searching the bedside cabinet in the bedroom I witnessed DC Rawlings

Signed R.M. Hudson Signature witnessed by

No. 991C

Witness Statement Page 45

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Roseline Mary Hudson

finding a quantity of correspondence relating to the financial matters of Mrs P. A. SMITH (SR/14) and at 2.50 pm DC Rawlings witnessed me finding a British passport, marriage certificate and international driving licence belonging to Mrs P A SMITH (RH/31). At 3.30 pm in the pocket of a grey tweed jacket in the hall I found a travel ticket to Dieppe and exchange receipts (RH/32) and another quantity of receipts (RH/33). The search of the premises was concluded at 1645 hours on 10th August 1992.

Signed R.M. Hudson Signature witnessed by

No. 991C

Witness Statement Page 46

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DS Paul Molyneux SMITH

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Sergeant

Dated 17 August 1992

On Saturday 8th August 1992, shortly before 10 am, I entered the premises of 48a Burton Road, Kingston-upon-Thames. A woman who I now know to be Mrs Pamela SMITH had been arrested and was being escorted out of the premises. Following a briefing and assessment of the premises, I started to search the lounge of the flat at 10.30 am. Throughout the course of the search, the following guidelines were adhered to in respect of exhibits; in the case of each item, notes were made in my pocket book as soon as possible after the finding; the exhibits were placed in an exhibit bag and handed to DI MORRISSEY, the exhibits officer, as soon as possible after the finding. A chronological listing of exhibits found now follows. At 1.15 pm I found one videotape, with a business card attached to it, on the table in the lounge. This is listed as PMS/1. At 2.45 pm I found one computer monitor in the lounge (PMS/2). At 2.48 pm I found a quantity of computer discs in the lounge (PMS/3). At 2.53 pm I found one Diki storage device in the lounge (PMS/4). At 2.55 pm I found one computer keyboard in the lounge (PMS/5). At 2.56 pm I found one main computer unit in the lounge (PMS/6). At 3.00 pm I found a quantity of cable and mouse in the lounge (PMS/7). At 3.01 pm I found one CD Rom drive in the lounge (PMS/8). At 3.40 pm I found one curriculum vitae in

Signed P. Smith Signature witnessed by

No. 991A

Witness Statement Page 47

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Paul Molyneux SMITH

the name of Michael SMITH in the lounge (PMS/9). At 8.00 pm I found a quantity of financial correspondence in the lounge (PMS/10). At 8.05 pm I found a quantity of correspondence in the lounge (PMS/11). The following day, the 9th August 1992, I recommenced the search of the lounge at 8.00 am. At 1.00 pm I found one EMI identification card in the name of M J SMITH in the. lounge (PMS/12); at 1.15 pm I found two diaries and two address books in a plastic bag in the left hand side of the lounge (PMS/13). At 1.30 pm I found one British passport, cancelled, in the name of M J SMITH in the left hand side of the lounge (PMS/14). At 1.55 pm I found a quantity of financial correspondence in the left hand side of the lounge (PMS/15). At 3.00 pm I found an application form for membership to the Institute of Quality Assurance in the name of FREYRE-SANDERS (PMS/16); this was found in a plastic bag in the left hand side of the lounge. At 5.00 pm I found a British Aerospace business card in the lounge near the door (PMS/17). At 5.20 pm I found a reel to reel tape containing a note in the bottom right book case of the lounge (PMS/18). At 5.25 pm I found one TDK video cassette, containing a note in the sleeve, on the lounge floor (PMS/19). At 7.50 pm I found a quantity of Russian newspapers dated 1975 in a cardboard box on the floor of the bedroom which I had begun to search; this is PMS/20. At 7.52 pm I found a letter in a cardboard box on the floor of the bedroom (PMS/21). At 7.53 pm I found a copy of The Guardian Newspaper dated 1977 in a cardboard box on the floor of the bedroom (PMS/22). At 7.55 pm I found a quantity of technical paperwork in a cardboard box on the floor of the bedroom (PMS/23). The following day, the 10th August 1992, at 8.00 am I continued the search of the bedroom. At 8.55 am I found one brown envelope containing one thousand pounds cash in fifty pound notes (PMS/24) and

Signed P.M. Smith Signature witnessed by

No. 991C

Witness Statement Page 48

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DS Paul Molyneux SMITH

a further brown envelope with ‘Mike SMITH’ written thereon containing one thousand pounds cash in fifty pound notes (PMS/25). Both items were found in the left hand drawer of the bedroom table and their finding was witnessed by Detective Sergeant HUDSON. Just prior to the find, I witnessed DS HUDSON taking a white envelope from the same drawer of the bedroom table; when she opened it, there were four separate sheets of paper and a letter inside. She exhibited them as RH/22. At 9.40 am I found two sections of the Chicago Tribune dated June 1976 in the left hand drawer of the bedroom table (PMS/26). At 9.42 am I found a receipt for a Ricoh 500G camera in the left hand drawer of the bedroom table (PMS/27). Also at 9.42 am I found one street map of Vienna in the left hand drawer of the bedroom table (PMS/28). At 11.30 am I found a quantity of financial correspondence in a red document box found on the bedroom floor (PMS/29). At 11.35 am I found a quantity of financial correspondence in a red document box found on the bedroom floor (PMS/30). At 2.00 pm I returned to the lounge. At 2.45 pm I found a quantity of .financial correspondence in the front right hand corner of the lounge (PMS/31). At 3.30 pm I found a quantity of receipts on the lounge floor (PMS/32). At 3.40 pm I found a quantity of correspondence on the lounge floor (PMS/33). At 3.50 pm I found a quantity of correspondence on the lounge floor (PMS/34). The search was concluded shortly after this last find.

Signed P.M. Smith Signature witnessed by

No. 991C

Witness Statement Page 49

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Sean Niall COX

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Constable

Dated 26 August 1992

On Saturday 8th August 1992 at about 10.10 am I entered 48A Burton Road, Kingston-upon-Thames with other officers comprising a search team. Detective Inspector MORRISSEY was already present at the address, together with Detective Sergeant SMITH and Detective Constable WILLIAMS. DI MORRISSEY conducted a briefing and the search commenced at 10.30 am. I was detailed to search in company with Detective Sergeant HUDSON and throughout the search I made contemporaneous notes of articles found by me and those found by DS HUDSON which I witnessed. All articles found by me were placed in appropriate packaging and handed to DI MORRISSEY who was acting as exhibits officer. At 10.55 am I saw DS HUDSON find a red address book in a plastic carrier bag inside the entrance hall (identified as RH/1). At 11.40 am I saw DS HUDSON find a paperback copy of Anna Karennina by Tolstoy on a shelf by the staircase (identified as RH/2). At 3.05 pm in the pocket of a grey tweed jacket hanging in the upstairs hallway I found two Building Society payment books, one bank paying in book and one British Rail ticket for travel between London and Manchester (together these items are identified as SC/1). At 3.10 pm I found in a plastic carrier bag in the upstairs hall six desk diaries dated 1986 to 1992 inclusive (these are identified as SC/2). At 3.20 pm, in the upstairs

Signed Sean Cox Signature witnessed by

No. 991A

Witness Statement Page 50

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Sean Niall COX

hall, I found a black attaché case and two carrier bags all containing documents (identified as SC/3). At 7.30 pm I found the following items in the upstairs hall: one “Avo meter” in its box (SC/4), one “Pye 1020” radio (SC/5), one “Aiwa” stereo system (SC/6) and one “Kisho” radio cassette player (SC/7). DS HUDSON witnessed the finding of all the above items. On 9th August 1992 at 8 am together with DS HUDSON I recommenced the search of 48A Burton Road. At 8.05 am I saw DS HUDSON find letters and other correspondence in the top drawer of a sideboard in the upstairs hall (identified as RH/4). At 8.10 am I saw DS HUDSON find a glass lens and black slides in the top drawer of the upstairs hall dresser (identified as RH/6). Also found at 8.10 am: a receipt dated 29.10.77 for a Fujica camera with instructions and strap (RH/7) and a man’s Seiko watch (RH/8). At 8.30 am I saw DS HUDSON find, in the same drawer, a yellow metal gadget in a plastic case (RH/9). When searching the middle drawer of the upstairs hall sideboard I saw DS HUDSON find the following items: at 9 am, a quantity of photographic slides (RH/10). At 9.05 am, a pink folder containing correspondence (RH/11). At 9.10 am, a quantity of correspondence (RH/12). At 9.20 am a list of frequencies (RH/13). At 11 am I saw DS HUDSON find a quantity of letters in the bottom drawer of the hall sideboard (RH/l4). At 11.05 am in the same drawer I saw DS HUDSON find a Fujica camera with accessories and films (RH/16). At 11.15 am, again in the bottom drawer, I saw DS HUDSON find two pieces of paper (RH/17) and at 11.15 am two bank statements (RH/18). I then assisted in the search of the bedroom and found the following items: At 8.10 pm in the chimney alcove one Russian made slide projector (SC/8). At 8.15 pm also in the alcove one Kodak instamatic camera (SC/9). At 8.25 pm one map of Moscow (SC/10) and at 8.35 pm one tennis racket (SC/11),

Signed S. Cox Signature witnessed by

No. 991C

Witness Statement Page 51

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Sean Niall COX

these last were also found in the chimney alcove. My part in the search ended at 9.30 pm.

Signed S. Cox Signature witnessed by

No. 991C

Witness Statement Page 52

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF DC Michael ROSS

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Constable

Dated 21 August 1992

On Saturday 8th August 1992 I attended 48A Burton Road Kingston upon Thames and at about 10.30 am I started to search the bedroom of this first floor flat. Throughout the search the following guidelines were followed with regard to exhibits; in the case of each item I made a note in my pocket book as soon as possible after the finding, placed the exhibit in an exhibits bag and gave it to DI MORRISSEY, the exhibits officer as soon as possible. The following is a list of exhibits all of which were found in the bedroom. At 3.45 pm one one page map of Slough found in a shoe box under the dressing table (MR1). At 3.59 pm one ticket number 643419 Greek and one receipt dated 1970-197- found in a white handbag on floor under the dressing table (MR2). At 4.20 pm a quantity of correspondence found in a red bag on the floor under the dressing table (MR3). At 5.26 pm one envelope with name TERESA JIMINES and address thereon found in the bottom of the wardrobe (MR4). At 7.35 pm Curriculum Vitaes of Mrs SMITH found in the left hand side of a cabinet on top of the wardrobe (MR5). At 7.45 pm Education Certificates of Mrs SMITH found in the right hand side of the cabinet on top of the wardrobe (MR6). At 7.50 pm a quantity of used carbon paper found in the right hand side of the cabinet on top of the wardrobe (MR7)

Signed Michael Ross Signature witnessed by

No. 991A

Witness Statement Page 53

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF DC Michael ROSS

At 8.15 pm a quantity of correspondence found in the right hand side of the cabinet on top of the wardrobe (MR8). The search was continued on Sunday 9th August 1992 and I found the following exhibits in the bedroom. At 8.30 am one metal notebook holder and correspondence found in a drawer of the dressing table (MR8A). At 9.15 am a quantity of correspondence found in an upper drawer of the dressing table (MR9). At 11.05 am a quantity of correspondence found in a shoe box on the chest of drawers (MR10). At 11.55 am a quantity of correspondence found in the top drawer of the chest of drawers (MR 11). At 12.10 pm one address book and a key found in the top drawer of the chest of drawers (MR12). At 12.20 pm a quantity of correspondence found in a lower drawer of the chest of drawers (MR13). At 4.40 pm one old British Passport, number 040835F and one EEC passport, number 001707472 both in the name PAMELA SMITH found in a black shoulder bag under the table (MR14). At 4.50 pm a quantity of correspondence found in a black shoulder bag under the table (MR15). At 5.35 pm a quantity of correspondence found in a white bag under the table (MR16). At 6.10 pm a quantity of correspondence found in the left hand drawer under the bed (MR17). At 9.07 pm one miniature stamp album of East German stamps found in cardboard box of books on dresser (MR18). At 8.25 am on Monday 10th August 1992 one letter dated 5.6.73 found in a cardboard box on the dresser in the bedroom (MR19). At 9 am a quantity of correspondence in the dresser (MR20). At 9.45 am a quantity of correspondence on the middle shelf of the dresser (MR21). I left the address for the last time at 2 pm on Monday 10th August 1992.

Signed Michael Ross Signature witnessed by

No. 991C

Witness Statement Page 54

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF PC Dale MALCOLM

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer

Dated 27 August 1992

On Saturday 8th August and Sunday 9th August 1992 I was engaged in searching 48A Burton Road, Kingston with other officers and under the direction of Detective Inspector MORRISSEY. I began to search at 10.30 am 8th August and when I seized an item I would make a note regarding the seizure in my pocket book and then hand the item to Detective Inspector MORRISSEY. I was only involved in searching the bedroom and consequently the following list of items seized were found there. I conducted the search with Detective Constable ROSS and where he has found an item which I have witnessed I have indicated this. At 12.30 pm I found one Access slip, account 5224 0061 2943 4243 in a carrier bag on the floor beside the wardrobe by the door (DSM/1). At 12.33 pm I found one piece of paper with names and numbers thereon in the same carrier bag as DSM/1 (DSM/2). At 12.35 pm I handed DSM/1 and DSM/2 to DI MORRISSEY. At 12.55 pm I found one envelope and letter with 546 1397 thereon on the floor beside the wardrobe by the door (DSM/3) and at 1.03 pm I handed it to DI MORRISSEY. At 3.45 pm I witnessed the finding of a one page map of Slough found in a shoe box on the floor under the dressing table (MR/1). At 3.59 pm I witnessed the finding of one ticket number 643419 Greek and one receipt 1970-197 found in a white handbag on the floor under the dressing table (MR/2). At 4.10 pm I

Signed Dale Malcolm Signature witnessed by

No. 991A

Witness Statement Page 55

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF PC Dale MALCOLM

found a book of matches, “J.B. Cafeteria, Calla Millor, Mallorca,” on the floor under the dressing table (DSM/4). At 4.20 pm I witnessed the finding of a quantity of correspondence which was in a red bag on floor under the dressing table (MR/3). At 4.57 pm I found a piece of paper, “Richard FLETCHER, 104 Hemmingford Road” in a shoe box beneath the dressing table (DSM/5). At 5.15 I handed DSM/4 to DI MORRISSEY and at 5.17 I handed DSM/5 to him. At 5.26 pm I witnessed the finding of one envelope, “Teresa JIMENEZ, 44b St Lawrence Terrace, W10”, in a carrier bag at the bottom of the wardrobe on the left hand side (MR/4). At 7.30 pm I found a quantity of correspondence in a plastic wallet in a plastic carrier bag in the cabinet above the wardrobe (DSM/6) and at 8.20 pm I handed it to DI MORRISSEY. At 7.35 pm I witnessed the finding of CV’s of Mrs SMITH in the left hand side of the cabinet on top of the wardrobe (MR/5). At 7.45 pm I witnessed the finding of educational certificates of Mrs SMITH in the right hand side of the cabinet on top of the wardrobe (MR/6). At 7.50 pm I witnessed the finding of a quantity of used carbon paper in the right hand side of the cabinet above the wardrobe (MR/7). At 9.30 pm I stopped searching. At 8.00 am on Sunday 10th August I resumed the search of the bedroom. At 8.30 am I witnessed the finding of one metal notebook holder and correspondence in a drawer of the dressing table (MR/8). At 11.05 am I witnessed the finding of a quantity of correspondence found in a shoe box on the chest of drawers (MR/10). At 11.10 am I found one 1991 diary containing a quantity of correspondence in a shoe box on the chest of drawers (DSM/7) and handed it to DI MORRISSEY at 11.22 am. At 11.55 am I witnessed the finding of a quantity of correspondence in the top drawer of the chest of drawers (MR/11). At 12.10 pm I witnessed the finding of an address book and a key in the top

Signed Dale Malcolm Signature witnessed by

No. 991C

Witness Statement Page 56

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF PC Dale MALCOLM

drawer of the chest of drawers (MR/12). At 12.20 pm I witnessed the finding of a quantity of correspondence in the bottom drawer of the chest of drawers (MR/13). At 12.25 pm I found a quantity of correspondence in a black handbag on the floor beneath the chest of drawers (DSM/8) and handed it to DI MORRISSEY at 12.38 pm. At 4.40 pm I witnessed the finding of an old British passport number 040835F and one EEC passport 001707472 both in the name of Pamela SMITH in a black shoulder bag under the table (MR/14). At 4.50 pm I witnessed the finding of a quantity of correspondence in a black shoulder bag under the table (MR/15). At 5.15 pm I found twelve Natwest statements, current account 46385738, August 1987 to August 1990 in a clear plastic wallet on the floor beneath the table (DSM/9). At 5.15 pm I found nine Barclays statements, current account 70816213, September 1988 to March 1990 in the same clear plastic wallet as DSM/9 (DSM/10). At 5.35 pm I witnessed the finding of a quantity of correspondence in a white bag under the table (MR/16). At 6.05 pm I handed DSM/9 and DSM/10 to DI MORRISSEY. At 6.10 pm I witnessed the finding of a quantity of correspondence in the left drawer under the bed (MR/17). At 9.00 pm I found three maps of Austria and Belgium, and one guide book of Paris in a plastic carrier on the floor in front of the dresser in front of the chimney breast (DSM/11). At 9.07 pm I witnessed the finding of a miniature stamp album of East German stamps (MR/18) in a cardboard box of books on the dresser. At 9.25 pm I took the following items from DI MORRISSEY, took them to Paddington Green Police Station, and at 10.40 pm, handed them to DS SINGLETON: SR/6; RH/20; ADT/1; PMS/20; PMS/21; PMS/22; PMS/23; SC/8; SC/9; SC/10; SC/11; RH/21; SR/7; SR/8; DSM/11; MR/18.

Signed Dale Malcolm Signature witnessed by

No. 991C

Witness Statement Page 57

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Jacqueline Karen BISHOP

Age of Witness (date of birth) Over 21

Occupation of Witness Photographic Officer

Address and Telephone Number Metropolitan Police Photographic Branch

2/16 Amelia Street, SE17 3PY

0207 708 0508 Ext 242

Dated 10 August 1992

On 10.8.92 I went to 48A Burton Road Kingston and there between 10.05 and 10.25 hours I took four (4) photograph(s). These photograph(s) are detailed in the index of the photographic album S/C Reference No. 9483. This photographic album I now submit as Exhibit No. JKB/1. The unretouched negative(s) are filed in the Photographic Branch.

Signed J.K. Bishop Signature witnessed by

No. 991A

Witness Statement Page 58

Form MG 11(T)

STATEMENT OF Jeffrey SINGLETON

Age if under 21 Over 21

Dated 11 November 1992

I am employed as exhibits officer in the case of Regina v Smith and have been so employed since 8th August 1992. During my employment it has been necessary to split and separate certain exhibits necessitating the re-labelling of exhibits with ‘J.S’ identification codes. Details of these changes to relevant exhibits are as follows. On 9th August exhibit SR3, a sheet of lined paper containing technical writing was opened and rebagged complete, re-labelled as J.S.8. On the same day exhibit SR4, a quantity of correspondence and components, was opened and split, the removed contents were variously bagged and labelled as exhibits JS14, JS15, JS16, JS17, JS18, JS19, JS20, JS21, JS22, JS23, JS24, JS25, JS26, JS27, JS28, JS29, JS30, JS31, JS32, JS33, JS34, JS35, JS36, JS37 and JS38. The remaining contents were resealed as exhibit SR4. On 10th August exhibit SC3, one black attaché case etc, was opened and two pieces of paper removed, rebagged and relabelled JS39. On the same day exhibit RH22, one (1) white envelope addressed to Mr M.J. SMITH containing letter and four (4) separate sheets of paper was opened and most of the contents removed, rebagged and re-labelled exhibits JS40, JS4l, JS42, JS43 and JS44. The envelope remained as RH22. On 11th August exhibit PMS34 a quantity of correspondence, was opened, a photocopy of a letter removed rebagged and labelled JS48 whilst the residual correspondence remained as PMS34. On the same day exhibit MR20 was opened and pieces of paper removed rebagged and labelled exhibits JS49, JS50 and JS51

Signed J.R. Singleton Signature witnessed by

Witness Statement Page 59

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jeffrey SINGLETON

whilst the residual correspondence remained as MR20. On that day also exhibit CJS1, one (1) exposed 35mm film taken on 8/8/92 at about 9.15am, was opened by Detective Sergeant BEELS and certain contents removed rebagged and labelled as exhibits SJB22, SJB23, SJB24, SJB25 and SJB26. On 27th August exhibit SC3 was again opened and part of the remaining contents removed rebagged and labelled exhibit JS61, a quantity of technical documents.

Signed Jeffrey Singleton Signature witnessed by

Witness Statement Page 60

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF John Richard WELCH, B.Sc

Age of Witness (date of birth) Over 21

Dated 18 September 1992

LabRef: UQ/3426/92

I am a forensic scientist specialising in the scientific examination of documents and handwriting.

On the 11th August 1992 I took possession of a number of items including the following:

JS/41 Sheet of paper bearing writing including “PARLIAMENT HILL FIELD”

JS/42 Sheet of paper bearing writing beginning “STH HARROW”

JS/43 Torn piece of paper bearing writing beginning “JAN APR EVERY 4 MONTHS”

JS/44 Sheet of paper bearing writing beginning “KARL GEHRING”

JS/49 Two page letter written by Michael Smith and beginning “DEAR MR HILL”

JS/50 Two page letter written by Michael Smith and beginning “DEAR MRS THATCHER”

JS/51 Page torn from notepad bearing writing of Michael Smith

I examined these items briefly before returning them on the same day to D.C. Ashton

Signed John Richard Welch Signature witnessed by

No. 991A

Witness Statement Page 61

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF John Richard WELCH

LabRef: UQ/3426/92

of the Metropolitan Police. On the 17th August 1992 I again took possession of these items, together with other items, in order to make more lengthy examinations.

On the 10th September 1992 I took possession of a number of items including item JS/18.

JS/18 Four pages of notes relating to car radar written by Michael Smith

I compared the bulk of the writing in each of items JS/41, 42, 43 and 44 with the writing of Michael Smith in items JS/18, 49, 50 and 51. I found many similarities between these writings. No single similarity is conclusive but the combination of similarities leads me to conclude that the bulk of the writing in each of items JS/41, 42, 43 and 44 was written by Michael Smith.

If required and if called upon to do so I can prepare photographic charts which I can use in court to demonstrate reasons for my conclusions.

Signed John Richard Welch Signature witnessed by

No. 991C

Witness Statement Page 62

Form MG 11(T)

STATEMENT OF Mrs C (Stella RIMINGTON)

Age if under 21 Over 21

Dated 9 November 1992

I have been employed by the Security Service for 23 years. I have made a study of the techniques used operationally, by the Intelligence Services of the former Soviet Union and of Russia whose intelligence services have inherited most of the Soviet intelligence services resources and assets, following the break-up of the Soviet Union in 1991. This study includes information gained from the debriefing of defectors from the Soviet and Russian intelligence services and from the Security Service’s observations of Soviet and Russian intelligence officers in the UK. I am thoroughly familiar with these techniques. The objective of these intelligence services is to gather intelligence with the aim of gaining political, economic and military advantage for their parent state. Included in this aim is the intention to cause short or long term damage not only to the Western State in which their intelligence is gathered but also to other Western States. There are a number of methods used by Soviet/Russian Intelligence Services to facilitate such intelligence gathering activities; one is to seek to suborn and recruit citizens of a Western State who have access to classified information and persuade them to hand it over usually in return for money. It is in the interest of the intelligence officer and his agent that such activities do not come to the notice of the authorities in the Western State. To this end, Soviet/Russian

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 63

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mrs “C” (Stella RIMINGTON)

intelligence services have developed over the years particular ‘tradecraft’ practices designed to ensure the security of their operations, their officers and their agents. Meetings and other forms of communication between the officer and his agent are considered to be particularly vulnerable to the attentions of the security services in the host nation and there are many well established tradecraft practices designed to minimise this risk. Examples of these practices are:-

(a) Instructing an agent to follow a particular route to a meeting. A number of defectors have told us that this is normal practice designed to enable the officer to observe the agent and ensure he is not under surveillance. Douglas Britten, convicted under the OSA in 1968 was instructed to travel to meetings with his Soviet controller following a pre-arranged route.

(b) The use of marks made with chalk, drawing pens, sticking plaster etc. on walls, posts or similar or placing at a specific place a particular object, often an item of rubbish e.g. empty cigarette packet, orange peel etc to convey messages. Both marks and objects are placed so as to be readily visible to the passer-by without stopping. Different marks and objects indicate different messages to the agent and his controller and reduce the need for personal meetings or other communication which carry inherent risks. Dieter GEHARDT the South African naval officer convicted of espionage in 1983 and Geoffrey PRIME, the GCHQ officer convicted of espionage in 1982 both received messages from their Soviet controllers by means of chalk marks on telegraph poles and trees. An empty coca-cola can left in a specific place was also used by PRIME to convey messages.

(c) Selecting meeting places in open areas away from city centres, which are well used by the public and where a meeting would not attract undue attention but surveillance would be difficult and easily detected. I know from a number of defectors and from my service’s observations of Soviet/Russian intelligence officers that parks, quiet suburban areas, particularly suburban tube or

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 64

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mrs “C” (Stella RIMINGTON)

railway stations within the 25 mile limit are favoured.

(d) Arranging in advance regular times, meeting places and arrangements if contact is lost or broken. As with marks and signals this is a well established method by which intelligence officers reduce the need for personal contact with their agents and so lessen the risk of discovery. Hugh Hambleton convicted of espionage in 1982 and Harry Houghton convicted of espionage in 1961 and Britten all had regular pre-arranged meeting times, places and “fall-back” arrangements if contact was broken or lost. I have familiarised myself with the Michael Smith case and in particular have examined exhibits JS/41-44 inclusive and read the relevant parts of his interviews. I am able to state that the notes contained in those exhibits are typical examples of the tradecraft referred to above, designed to ensure the security of clandestine meetings with an agent. I formed that opinion on the basis of the following:

JS/41 describes marks to indicate “danger” - a vertical line, and “come next day” - a horizontal line. It notes what appears to be a meeting at Horsenden Hill on 25 September with arrangements for further meetings if that meeting is not kept or contact is broken. I have visited Horsenden Hill, a popular open wooded area with a large car park some 3 miles from Smith’s workplace at GEC, East Lane Wembley. It is typical of sites selected by intelligence officers for intelligence meetings. The other notes on JS/41 have no intelligence significance.

JS/42 contains a note which appears to relate to a meeting at “Roxeth REC” on a date in April. I have visited Roxeth Recreation Ground which is situated in a quiet suburban housing estate close to South Harrow railway station. This is shown in exhibit PA4. It is an open park area with restricted access and typical of sites selected by intelligence officers for clandestine meetings, this exhibit also notes arrangements for meetings at Perivale or Sudbury town tube stations if the contact is lost. The other notes on JS/42 have no intelligence significance.

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 65

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mrs “C” (Stella RIMINGTON)

JS/43 contains notes which appear to relate to regular contacts, possibly with a previously unknown person - “REC & GUARDIAN” probably refers to using the Guardian Newspaper as a recognition signal - carrying a particular newspaper is a common recognition signal. It also notes what could be signals for changed meeting arrangements, “green for next day” and “red for next Sat. pm”. The other notes have no intelligence significance.

JS/44 contains what appear to be arrangements for a clandestine meeting or meetings; details of signals - a vertical line for “danger” and a horizontal line for “come next day to agreed place” - a symbol, possibly a fire hydrant or notice board, for the location of the signal; details of another signal and location – “Abbotsbury Rd/Melbury coke can at bollard”. I have visited this location and it is shown in Exhibit PA3; details of a particular route dated 6 August, I have visited Harrow and can say that the route described in JS/44 “from bottom of hill walk up and (round Church Hill) into church” corresponds to the route up Peterborough Road from the junction with Kenton Road turning right into Church Hill which leads into St Mary’s Church, this route is shown in Exhibit PA1; details of meetings at Horsenden Hill; a list “get old project notes, biosensors, micromachining, micron-valve - give details about cut-backs, HTSC” which appears to be a list of requirements on which information is required. The other notes in JS/44 have no intelligence significance.

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 66

Form MG 11(T)

STATEMENT OF Philip ATKINSON, DET. SGT. 158766

Age if under 21 Over 21

Dated 6 November 1992

On Thursday 17th September 1992, in company with DI Martin MORRISSEY, I went to the vicinity of Harrow-on-the-Hill, Middlesex where I took a number of photographs, PA/1 refers. Later that same day, again in the company of DI MORRISSEY, I went to the Roxeth Recreation Ground, South Harrow where I took several photographs of that area, PA/4. On 1st October 1992 I travelled to Melbury Road, Kensington, W8. At the junction of Abbotsbury Road I took a quantity of photographs, PA/3.

Signed P. Atkinson DS Signature witnessed by

Witness Statement Page 67

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Steven Langford CUNDY

Age of Witness (date of birth) 28th June 1943

Occupation of Witness Physicist

Dated 10 August 1992

I am the Director of Hirst Research Centre. I have been employed by GEC since 1968 and have been the Director of GEC Hirst Research Centre since January 1987. On Sunday, 9th August 1992 I arrived at the premises of HRC in Wembley at about 8.30pm as the result of a telephone call to DI Nicolson who asked me to meet him as a matter of urgency that night. At about 9.00pm I met with DCI Gray and DI Nicolson who presented themselves as Special Branch Police Officers engaged in the investigation of offences against the Official Secrets Act allegedly committed by Michael Smith. I know this man to have been an employee of HRC up until 31.7.92 in the Quality Assurance Department. They showed me a quantity of documents and some components which were contained in a number of sealed bags. Between about 9.30pm and 12.00pm I examined these documents and articles and made notes assessing them accordingly. I have signed, dated and timed these notes and handed them to the officers while retaining a photocopy of them. My general assessment of the documents and articles is as follows: there has been a systematic attempt to obtain details of manufacturing procedures and piece parts relating to delay lines for the Rapier missile, a similar effort has been made in respect of surface wave acoustic devices, that collection included stolen

Signed S. L. Cundy Signature witnessed by M. Nicolson D/I

No. 991A

Witness Statement Page 68

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

material and material classified as RESTRICTED, and an effort has been made to summarise the objectives and aims of company confidential projects. The hand written documents are not of a type which need to be produced by anyone at HRC. Company confidential material has been removed without permission, some stolen from others files some copied from files which could have been held in the Q.A. department. Whilst I was not able to identify immediately all the articles shown to me, many of the components were recognisable as fairly out-of-date components in finished states, experimental devices and part processed semi conductor devices. No one person in HRC would need to have such a systematic collection of devices; they have been assembled by theft from several laboratories in the research centre.

Signed S. L. Cundy Signature witnessed by M. Nicolson D/I

No. 991C

Witness Statement Page 69

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Steven Langford CUNDY

Age of Witness (date of birth) 28 June 1943

Occupation of Witness Director Hirst Research Centre

Dated 24 August 1992

Further to my statement dated 10th August 1992, the documents and components shown to me on that day by DI Nicolson were in sealed bags marked JS/14 to JS/38 inclusive. On 24 August 1992 at GEC Hirst Research Centre I handed to Detective Constable Kelly daily time sheets (the signing in/out documents) maintained by the Q.A. department. Included in the list of personnel required to sign in and out on these documents was Michael John Smith. I exhibit these as SC/1.

Signed S. L. Cundy Signature witnessed by Kelly DC

No. 991A

Witness Statement Page 70

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Steven Langford CUNDY

Age of Witness (date of birth) 28 June 1943

Occupation of Witness Physicist, Director of HRC

Address and Telephone Number Hirst Research Centre

East Lane, Wembley, Middx. HA9 7PP

Dated 11 August 1992

This statement, (consisting of 9 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

Today at HRC I met with DI Nicolson who handed to me three sealed bags respectively marked MN/2, MN/3 and MN/4 which contain original notes that I made on Sunday/Monday 8/9 August 1992 in respect of a number of documents and components shown to me at that time. This statement is made from my notes. JS16 A handwritten document entitled ‘Rugate filters for SDI’ dated June 1992 with 1 of 2 written on front page though there were 3 pages in all. This refers to a project carried out at HRC. It has been running for about 2 years and is still current. Contract is placed by SDI(PO) (Strategic Defence Initiative Procurement Office) but technically is managed by the DRA labs at Malvern (RSRE). The USA project monitors come from the Wright Paterson Air Force Base. The documents were examined. My assessment is (1) It is a good but not very technically detailed description of how the work is carried out (2) There are descriptions of why the project is being sponsored by the DOD (USA Department of Defense) (3) There are descriptions of apparently ‘available’ backing information and details such as - software programmes have been

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991A

Witness Statement Page 71

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

written. No such documentation as JS16 exists in this building as being necessary for us to carry out this work. Therefore, Mr Smith certainly has no need for such a document. JS17 A handwritten document entitled ‘Micromachining Project’ dated June 1992 with 1 of 3 written on front page. This project has been running for about 2 years and is still current. It is largely a commercially confidential programme there being no immediate direct military significance. The document JS17 appears to describe the aims well but there do appear to be the occasional embellishments that I do not recognise such as the cryogenic cooling and spiral fluid diode. There are some correct details on how some parts of the devices are made but generally it is obvious that the papers have been written by a non specialist. Once again there is no need for anyone at HRC to create such a document within HRC. Mr Smith certainly had no need to create such a document. JS18 A handwritten document entitled ‘Quasi optic Car Radar’. This describes a commercial project still in existence. There is some detail here not quite right. However the breadth of the information relating to current achievements, current customers and potential customers for derivatives of the work is quite astounding. Very few people (3 at the most) in HRC are aware of all the detail explained here. Some considerable research has gone into producing this document. However once again there is no reason for the existence of such a document.

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 72

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

JS19 A handwritten document entitled ‘Micronvalve Project’ dated May 1992 with 1 of 1 written on the front sheet. This is a project which has been running for about 5 years and is current. Funding and therefore interest in this technology and its applications do include the DRA. There are some classified military implications though most of the information we generate at HRC is not classified. This summary is poor compared to the other exhibits above and contains what I initially considered as quite extraneous detail. My colleague Mr Swallow who was examining the exhibits with me, but making his own independent notes, told me that the one item I picked on as being extraneous was not, but it was transitory and not key to the project - that related to the novel bondwire applied to this project. This exhibit is a rough summary of what is going on. I was tempted to speculate that this project being widespread in HRC and involving a wide range of personnel contributing very special skills would present some problem to anyone trying to access key information. There is no reason whatsoever for such a document to be produced by any member of my staff undertaking their normal duties. JS20 A handwritten one page document entitled ‘Olfactory Research Project’ dated May 1992. This is a largely commercial project with potential military/policing applications such as ‘sniffing’ for illicit substances by Customs and Excise. Quite a good overall summary is generated here with one or two

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 73

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

surprisingly new and relevant details in particular the use of polysiloxane coatings. Experimental details recorded in this exhibit are good, in particular the use of pattern recognition to aid the identification of gases and vapours. It was however noteworthy that this project summary did not record who our main customer is nor the objective of that customer; that commercial customer has asked for extreme confidentiality from us and therefore the information is only available to those with a need to know. There are some military implications if and when this technology proves to be viable. This completed the examination, discussion and note taking from the handwritten exhibits. It is quite clear that there is no business reason why any of these documents should exist. These are very much the essence of leaking details - some considerable work has gone into obtaining seemingly relevant and sometimes accurate detail. But it is equally clear that none of the documents have been written by an expert and no overall management strategy/objective is exposed. They are what could best be described as ‘tasters’ - here is a summary of what is going on and what detail is readily available. Certainly Mr Smith would have no reason to have such documents in his possession. I was then shown exhibit JS38 and I recorded the following in my notes: JS38 A quantity of blueprints. I could not make detailed components on the precise technical details but

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 74

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

from my general knowledge I note: (a) Some blueprints had been removed from files for they had punched holes; (b) Some blueprints are copies; (c) One document is proprietary to HRC. Apart from the HRC property all the other drawings are the property of Cossor Electronics and are supplied to HRC to enable HRC to manufacture for Cossor Electronics F band delay lines. This is a microwave component we know is used by Cossor and incorporated by them in their equipment which in turn is supplied to BAe for the Rapier missile system. The documents are not marked as classified material nor are they identified as part of the Rapier system but all relate to military hardware which is still in manufacture. Mr Swallow and I were then shown exhibits JS22 to 32 inclusive and then JS37. Mr Swallow was immediately able to confirm that exhibit JS37 related to exhibits JS22 to 32 and that all the exhibits JS22 to 32 and JS37 were HRC manufacturing drawings for MKIII delay lines supplied to Cossor Electronics and eventually to BAe for the Rapier missile system. I was able to confirm that these were HRC documents. None of these documents were classified but they all relate to a military weapon system which is almost certainly classified. No one has authority to remove such drawings from the building. JS14 This was a brown envelope which was emptied in front of me to reveal a mixture of components part finished components and experimental prototypes. The mixture was sorted to reveal a group of Surface

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 75

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

Acoustic Wave filters some of whose serial numbers were recorded as 63-35-B-TT, 8744-2667 1750(587), 63/55 63.5 MHZ, 10/37/B/20, 63/35/P/B082, 10/37/B/69. There were various pieces of processed GaAs (gallium arsenide) which on examination proved to be MMIC’s (monolithic microwave integrated circuits) with experimental distributed wideband microwave amplifiers defined. There were two items I could not immediately recognise but they appeared to be silicon devices made here. In summary all of the components were fairly old some even up to 8 years old, none younger than 2 years old. The components would need to have deliberately assembled into this collection - there is no single room or activity group at HRC which could have generated all those devices. There is no reason for any single person to have access to such material which in any case belong to HRC. JS21 This exhibit is a very comprehensive set of copies of documentation relating to the manufacturing schedule of delay lines for Rapier manufactured at HRC for Cossor. Documents are from a ring folder and all are marked Company Confidential. There were also various other letters, modifications issued by Cossor to us, our own publicity material relating to general capabilities in delay lines. Most of this material would be lodged with the QA department following standard practice relating to a military project. With the exception of the single sheet of HRC publicity material, none of this documentation should be removed from HRC.

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 76

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

JS15 A collection of documentation and build schedules relating to Surface Acoustic Wave devices. A very comprehensive assembly of documents from various sources. Some of these documents would have been lodged with the QA department. However we noted the presence of controlled copies issued personally to Mr F S McClement and the presence of documents classified RESTRICTED issued to Mr F S McClement personally. This is a military classification. At the same time as making this statement DI Nicolson asked me various questions and asked for comments. (1) Does the name Karl Gehring mean anything to me? It does. K A Gehring joined the scientific staff at HRC in 1982 (or 3?) and was employed until 1992 when, through ill health, he was declared redundant. He is approximately 55 years holding duel Swiss and UK citizenship having been born in the UK. His particular expertise is in superconductivity and its application to devices. He has represented GEC HRC in national fora on this subject and therefore is well known. Immediately following the discovery of high temperature superconducting ceramics (by IBM scientists in Switzerland) he devoted his work to this new material. During his employment at HRC his home was at Oxford; he lived here in Wembley in a lodging house. Recently the family home moved to Sheffield. Being cleared to SECRET he was privy to details of some military applications of high temperature superconductivity. Following an attack of hepatitis A - almost certainly as a result of water contamination in Oxford because he was not alone - he

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 77

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

never recovered his health and seemed for several years to be suffering from PVFS - he was certainly high strung and apparently highly stressed. I was also shown the following exhibit: RH/9 I could not immediately identify this object. However I consulted a member of the staff at HRC Mr P Burton who although he was fairly certain he knew what it was he expressed reservations because at least one key piece was missing. He did however produce a virtually identical component which was complete and was able to confirm that the RH/9 component was a galvanometer mirror assembly with the mirror missing. Such a component is not made here but a number of these items have been purchased in the past for a product to develop a piece of equipment. The device is used to scan laser radiation and finds applications in document scanners, perhaps supermarket checkout scanners and any application requiring a faster scan of laser radiation. The device is too small to be of any military significance. DI Nicolson then asked me what I understood by the following terms - ‘Biosensors’, ‘Micromachining’, ‘Micronvalve - give details of cut backs’. All three refer to projects at HRC and I believe it can only refer to GEC because this collection of projects must be fairly unique in the world under one roof. The Micronvalve project recently has been subject to funding restrictions (April 1992) and at least one member of staff formerly employed in the team has been declared redundant. All three projects are dual technologies able to deliver commercial products as well as

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 78

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

military products. The micronvalve programme has perhaps the highest known military content. I was also asked what I understood by the initials HTSC. This can only be High Temperature Superconductivity. A current project at HRC.

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 79

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Steven Langford CUNDY

Age of Witness (date of birth) 28 June 1943

Occupation of Witness Director Hirst Research Centre

Dated 24 August 1992

On the 11th August 1992 DI Nicolson came to this office and he permitted me to copy a document marked JS/8 and asked me to research the meanings of the numbers and writing on that document. Since then I have discussed the nature of the document with Mr D G Barlow, Q.A. Manager, and Mr T.A. Elson, his deputy in the Q.A. department. We now find that the numbers are the sequence control numbers applied to incoming orders. An incoming order is received by our Accounts/Commercial staff. It is assigned a sequence number and copies of the order and the sequence control number are sent to (i) The Commercial Manager (ii) the Q.A. coordinator (Mr J A Parker) (iii) the project leader likely to be involved in executing the contract. All three are asked to comment on the acceptability of the order. No order is accepted unless Q.A. agrees. Document JS/8 contains numbers starting at 8896 (for an order dated 9.3.90) to 9358 (for an order dated 5.11.90 received in Q.A. department on 9.11.90). However the numbering is not consecutive. We have investigated whether there is any purpose behind the choice of numbers. Mr J.A. Parker would inform one of three Q.A.

Signed S. L. Cundy Signature witnessed by M. Gray DCI

No. 991A

Witness Statement Page 80

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

primes when an order was received for the attention of their respective areas. A selection of projects would therefore be generated for each of the primes: T A Elson, A W Youles, A H Nott. On examining the list in JS/8 we find that all three primes are involved. Therefore this list in JS/8 is not a single prime’s “attention list”. Further lists would be created when Q.A. system audits were planned. M J Smith T A Elson and D G Barlow would periodically draw up an “at risk register” - those projects where some special attention was needed because there were some criticalities (timescale, technology etc). We have examined such listings. They are not really as extensive as the list in JS/8 and, for instance, include numbers 09130, 09110 and 09138, numbers included in the time sequence represented in the JS/8 list but not included in that list. Therefore JS/8 is not an “at risk” register. We have considered whether these projects are placed within areas where M J Smith was asked to conduct a systems audit. I am assured that this is not the case; it is certainly not normal for such an associated list to be created and in some cases the selection represented by JS/8 fails this test. I therefore have to state that there is no known legitimate purpose for this list within Hirst Research Centre. In examining the projects named in that list we note that minor contracts are not recorded; we note that the majority of the projects are leading edge technologies where there are dual military and commercial objectives.

Signed S. L. Cundy Signature witnessed by M. Gray DCI

No. 991C

Witness Statement Page 81

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Steven Langford CUNDY

Age of Witness (date of birth) 28 June 1943

Occupation of Witness Physicist, Director HRC

Dated 14 August 1992

On Tuesday 11th August 1992 at Hirst Research Centre, East Lane, Wembley, I handed to DI Nicolson an Official Secrets Act declaration which was signed by M J Smith on 15th July 1986 and witnessed by Mr G D Prichard, a former Administration Manager at HRC. This document had been removed at my request from the files maintained by the Security Controller at HRC. Today, at Hirst Research Centre, I handed to DI Nicolson the following items: 1) The personnel file of Michael John Smith which, to the best of my knowledge is complete; 2) An annual report covering the period July 1989 to June 1990 issued by Hirst Research Centre to individuals within GEC under Company Confidential cover; 3) An annual report covering the period July 1990 to June 1991 issued by Hirst Research Centre to individuals within GEC under Company Confidential cover. In my previous statements I had been able to prove that certain named projects were indeed projects or activities carried out at Hirst Research Centre by reference to this latter report (item 3).

Signed S. L. Cundy Signature witnessed by M. Nicolson DI

No. 991A

Witness Statement Page 82

Form MG 11(T)

STATEMENT OF Steven Langford CUNDY

Age if under 21 Over 21

Dated 6 November 1992

This statement, (consisting of 5 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

On Friday 23rd October 1992 at Hirst Research Centre, Wembley, I met with DI Nicolson of Special Branch, New Scotland Yard and examined documents contained in a sealed bag marked SR4 and again viewed devices contained in a sealed bag marked JS/14, I make the following observations on these items from original notes made on that day and retained by me. QIR-FC-058 June ’88 Draft (a) Process flow chart for the construction of an infra-red imaging detector. This chart was acquired from the IRDL (Infra-red Development lab) and concerns the production of complete dewar assemblies for IR detectors based on CMT material (Cadmium Mercury Telluride). In the period up to March ’89 MR M J Smith was involved in Systems Audits and contract reviews in IRDL as part of his assigned tasks. The device constructed by following the process is not a classified object, however it is sensitive military material because the detector was destined to be the front end of a high quality infra-red imaging system which permits all weather and night time aircraft operations and night time visibility for gunners. There are no major commercial applications for this type of device because the costs are far too high for this quality of device. There are a few highly specialised applications in civil fields such as helicopter borne surveillance of electricity supply lines - looking for hot spots which may be the precursors of breakdowns. The dominant application of these devices is military. Knowledge of the application technology for CMT detectors and the know how in respect of the production of detectors effectively was and still is a U.K. technology, invented at what was

Signed S. L. Cundy Signature witnessed by

Witness Statement Page 83

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

RSRE (Malvern), now DRA (Malvern) and in production at Southampton by Mullards, now Philips, and GEC. Information shown to me is not classified but unquestionably of military significance and if that information was communicated to foreign powers it would be considered as damaging the U.K. military interest. QSI-DS 238 This is a provisional specification sheet for a video line buffer produced at HRC. The document and the product are both very old (1986) and of commercial interest only. The document was stolen from the Q.A. Reference Library, it being an original. QSI-DR-251 These are design rules issued by the Q.A. Department for the measurement of line widths in integrated circuit structures. This document was created in order to align the standards and methods of measurement at (what was) Marconi Electronic Devices Ltd, Lincoln (now GPS Lincoln) with those in use at HRC. Included in the process list (Section 1. SCOPE) and referred to again in pages 6, 7, 8 and 9 is the silicon-on-sapphire (SOS) process. The SOS is of military use - being one of the first and still the best radiation hard integrated circuit technology. There are some commercial uses relating to satellites - those satellites can be both military and civil operations. SOS technology was and still is unique to GEC in the U.K. but there are other sources in the world now - principally US military houses. This technology is still in use today. The document was stolen from the Q.A. Reference Library, it being an original. QSI-CD-250 dated November 2 1986. Q.A. produced documentation on how to achieve control of the specification of operations to be carried out to produce integrated circuits in silicon. An old document but the methodology described is still generally applicable. The document actually refers to the 1.5 micron CMOS process for IC production. Circuits produced by this technology have both military and commercial applications and are still in production in the U.K. and many parts of the Western world. QSI-PS-298 dated March 1987. This is a procurement specification for silicon-on-sapphire wafers. This document contains all our know how on how to qualify incoming SOS wafers and grade the quality. This quality affects radically the yield of SOS IC’s in production. SOS technology is unique to GEC in the U.K. and there is strong military interest and

Signed S. L. Cundy Signature witnessed by

Witness Statement Page 84

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

military applications dominate. We note one of the suppliers is Japanese but this does not mean that this document is generally seen by all comers. QSI-PS-296 dated February 1987. This, like the previous document, was stolen from the Q.A. Reference Library. It is a procurement specification for silicon wafers for CMOS integrated circuit production. Unlike SOS, CMOS circuits have both military and civil uses. This document not nearly so sensitive as the above document - the specification is not unique and would be known by many manufacturers. QSI-DS-239 dated April 1986, stolen from the Q.A. Reference Library. This is a draft data sheet for IC’s used for signal processing. Data sheet and its information not of direct military significance however, as the data sheet suggests, the devices described would find application in radar processing which would be of military significance. QSI-DS-237 dated March 1987 another document stolen from the Q.A. reference library. It is a draft data sheet for a cascade arithmetic logic unit. No military application referred to in the sheet but would find application in radar signal processing. AN/102 Issue B Sept 1987 An application note provided to users of monolithic microwave integrated circuits (MMIC’s) giving general precautions and warnings about the use of Gallium Arsenide (GaAs) mmic’s. There is no immediate military significance to this note, however MMIC’s are largely only used for military purposes (costs high, performance high) and therefore recipients of this note were highly likely to be only military users. After these items there were 5 (five) specification sheets for specific GaAs mmic’s namely: GM 1208 A 8 - 12 GHz mixer Sept 1987, GP 1208 A 8 - 12 GHz 1 bit Phase shifter June 1987, GA 1801 A 0.5 - 18 GHz amplifier Aug 1987, GS 1802 A 2 - 18 GHz SPDT PIN switch June 1987, GM 9888 A 94 GHz mixer June 1987. These are devices which HRC was producing in prototype form at the time. HRC was unique in this period in its capabilities in high frequency GaAs MMIC’s. Worldwide there were several companies in the U.S.A., all established with heavy military funding, at a comparable technical level. All the components relate to potential radar systems - they all represent typical radar components but at the time of prototyping and of conducting the R & D into the production technology there were

Signed S. L. Cundy Signature witnessed by

Witness Statement Page 85

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

no specific military radar projects. Knowledge of the characteristics and capabilities of the circuit would certainly be of use to a foreign power because of the early warning they give in respect of likely future radar systems. We note that in Exhibit JS/14 there are a number of part finished, part mounted and finished semiconductor devices. These devices have now been sorted and identified by sub-numbers within Exhibit JS/l4. Amongst those devices we identify the following: SLC1. Various versions, 4 in all, including the version referred to in the data sheet GA 1801 A, of the 0.5 - 18 GHz distributed amplifier. This together with the data sheet is of much more significance. Now demonstrated to those skilled in the art is how to make the specified device. The very wide bandwidth of the device is only of military use. SLC2 A finished device corresponding to data sheet CM 9888 A. 94 GHz is a frequency used for terminally guided munitions and the mixer was designed as part of such a system. The combination of the device and the specification sheet now demonstrate to those skilled in the art how to make the device and knowledge of its functioning enables countermeasures to be devised. Because I could not readily identify further components contained in Exhibit JS/14, my colleague Mr D E H Smith who is an expert in SOS devices was asked to identify further exhibits. These were given sub-numbers as follows: SLC3-5 contains 3 versions of the same chip identified in GEC as MA734. This chip was designed and made at HRC. It is a processed test chip - it has no functionality - but it is a control circuit which is run through a 5 micron SOS process to test particular processes and to confirm that the process is in specification. SOS devices made by the process and its subsequent improvements were uniquely for military or space purposes. SLC6 is a chip designated MA931A. It has been manufactured by a 5 micron SOS process. It is a Reed-Solomon encoder for satellite communications. In this instance the customer was ESA. But the process was and is still generally used to produce military circuits. I then examined a document prepared by Mr A. P. Pople dated 23.2.1984 concerning Joule Thomson minicoolers. These coolers are used for CMT infra-red imaging systems. The information contained in the document is unclassified

Signed S. L. Cundy Signature witnessed by

Witness Statement Page 86

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Steven Langford CUNDY

and probably contains public domain information. However developments of this cooler design are still in use today for military systems. There were 8 “Techbriefs” being publicity material relating to HRC and its general capabilities and products. There is no military significance here. Documents were from the period 1985-1987. There were 5 items in all containing public domain information, being newsletters, GEC journals and newspapers as follows: 2 in-house newsletters, 1 GEC journal of Research, 2 copies of GEC’s in-house newspaper dated April 1992, June 1992. I make the following general observations about Exhibit SR4 and the re-examination of the components contained in Exhibit JS/14 which have now identities SLC1 … 5. The material relating to CMT and infra-red imaging is of obvious military significance and of National importance because of the UK’s lead in this technology. The combination of specification sheets and actual GaAs MMIC’s creates a significant body of knowledge and potential know how for third parties. Because of the expense of this technology and because of its frequency range this technology is only of real military significance; the spec. sheets and devices actually related to prototype devices for generic future radar systems (the ‘building blocks’). The combination of process related sheets, device specification sheets and actually SOS devices also creates a useful body of information for third parties. Once again the extreme expense and radiation resistance of this technology limits the market applications and interest to military and space applications.

Signed S. L. Cundy Signature witnessed by

Witness Statement Page 87

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Gerald Herbert SWALLOW

Age of Witness (date of birth) over 21 (12 May 1933)

Occupation of Witness Manager Microwave & Packaging Division

Dated 10 August 1992

I have been employed at Hirst Research Centre for some thirty four years and am now the manager of the Microwave & Packaging Division of HRC. On Sunday, August 9th 1992 at about 9.00pm and as a result of a telephone call received by me at my home I came to HRC where I met with DCI Gray and DI Nicolson who presented themselves as Special Branch police officers engaged in the investigation of offences against the Official Secrets Act allegedly committed by Michael Smith. I know this man to have been an employee of this company in the quality department until July 1992. They showed me a quantity of documents and some components which were contained in a number of sealed bags between about 9.30pm and 12.00pm. I examined these documents and articles and made notes assessing them. I have signed, dated and timed these notes and handed them to the officers whilst retaining a photocopy of them. My general assessment of the documents and articles is as follows: Much of what I have seen is directly applicable to the design, manufacture and assessment of devices such as microwave delay lines and surface acoustic wave devices which have been produced at Hirst Research Centre for incorporation into units which form part of the

Signed G. H. Swallow Signature witnessed by M. Nicolson D/I

No. 991A

Witness Statement Page 88

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gerald Herbert SWALLOW

Rapier Missile System. This information is quite extensive and gives detailed specifications for all marks of this component up to those currently being produced together with parts lists, component drawings and processing techniques used during manufacture. Delay lines of this type have only been produced by Hirst Research Centre for military applications. Among the items examined were a range of surface acoustic wave devices the particular application of which is not known to me at this time. Among the documents examined are several carrying the military classification RESTRICTED which were originally issued to an engineer at HRC currently still engaged on research at HRC. On no account should documents of this nature be removed from the Hirst Research Centre or be seen by someone who has not been cleared in the usual way. I can only assume that they were removed without the knowledge of the engineer concerned at some time within the last few years.

Signed G. H. Swallow Signature witnessed by M. Nicolson D/I

No. 991C

Witness Statement Page 89

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Gerald Herbert SWALLOW

Age of Witness (date of birth) over 21 (12 May 1933)

Occupation of Witness Manager, Hirst Research Centre

Dated 24 August 1992

Further to my statement dated 10th August 1992, the documents and components shown to me on that day by DI Nicolson were in sealed bags marked JS/14 to JS/38 inclusive.

Signed G. H. Swallow Signature witnessed by M. Gray DCI

No. 991A

Witness Statement Page 90

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Gerald Herbert SWALLOW

Age of Witness (date of birth) 12 May 1933

Occupation of Witness Manager, Microwave and Packaging Division

Hirst Research Centre

East Lane, Wembley, Middx. HA9 7PP

Dated 11 August 1992

Today at HRC I met with DI Nicolson who handed to me three sealed bags respectively marked MN/5, MN/6 and MN/7 which contain original notes that I made on Sunday/Monday 8/9 August 1992 in respect of a number of documents and components shown to me at that time. This statement is made from my notes. JS16 A handwritten document describing work on Rugate filters for SDI. This looked like an “appetite wetter” for transmission elsewhere and gave rudimentary information on this type of device which could be used for example to protect pilots from incoming laser radiation re goggles, cockpit covers etc as radiation filters. It is my opinion that Mr Smith could not have access to this information in his Q.A. role. JS17 Micromachining. These handwritten notes give general data on the micromachining projects at HRC which are currently commercially orientated. Diagrams are of recently achieved structures, not current designs not for military applications but applications to cooling power devices have been discussed. Some details are

Signed G. H. Swallow Signature witnessed by M. Nicolson DI

No. 991A

Witness Statement Page 91

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gerald Herbert SWALLOW

accurate, e.g. ceiling with negative resist on nickel plated structures which is for prototype use only. The information on forming techniques is fairly accurate. Mr Smith had no formal employment in this project to my knowledge. JS18 Quasi Optical Car Radar. Quite an extensive survey of the whole range of Quasi Optic programmes. Some details fairly accurate. Much of the information is not published. The information on patch trimming could only be obtained from “Blue Books” or by discussion with the engineers concerned. There is no reason why this should have been done. All the information gathered together covers a long period of work. The references to detection of gas clouds etc. and to Lear are surprising since there is as yet no Q.A. involvement being only at the discussion stages. JS19 The Micronvalve Project. The handwritten information is sketchy but accurate as far as it goes. The information on bonding techniques is not, to my knowledge, published since the whole project is of a developmental nature. There is no reason why anyone not concerned with the project should know of the mounting and bonding techniques which are features to this device. JS20 I have no personal knowledge of this project and am therefore unable to comment. JS38 This bag contained information pertinent to Delay Lines. Engineering drawings examined are known to have originated in Cossor Electronics Harlow Essex and constitute procurement

Signed G. H. Swallow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 92

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gerald Herbert SWALLOW

specifications for an ‘F’ Band Delay Line supplied by HRC to Cossor as a microwave component for their OCF which is part of the Rapier Missile System. The drawings seem to be original Cossor issue and could not have been copied in this format in HRC since we have not got the type of machine needed. One drawing details the manufacture of a more recent box for a MKIII Delay Line, in itself of little value. Mr Smith has no authority whatsoever to remove drawings from HRC, some of which have apparently been taken from a file evidenced by the holes punched in one edge to facilitate binding. JS22-32 inclusive JS37 These bags contained drawings, all originating in HRC, pertinent to a MKIII Microwave Delay Line. This line is hermetically sealed and operates in F Band. Possession of this set of drawings would enable lines to be manufactured by someone with the appropriate facilities. No one at HRC has the authority to remove a set of drawings of this type from the building. This delay line is fitted to many of the later marks of OCF used in the Rapier Missile System. JS33-36 inclusive. These are parts lists for the components for the MKIII F Band Delay Line which give all drawing numbers for manufacturing drawings. They refer to the drawings detailed in JS22-32 - JS37. They also carry the marks of punch holes which suggest they have been removed from a file. Packets of samples. They appear to be S.A.W. filters originating

Signed G. H. Swallow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 93

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gerald Herbert SWALLOW

from HRC. Five filters were shown carrying Advanced Technology Component Labels. Serial numbers carried are:- 63-35-B.77., 8744-2667(1780/1587) . 63/35/P/B082. 10/37/B/20. 10/37/B/69. Various other discreet part processed Surface Acoustic Wave Devices were also seen together with a range of semiconductor devices such as GaAs amplifiers and un-encapsulated chips most of which are quite old and probably gathered over a period of time from various laboratories within HRC. JS21 All documents, though many out of date, relate to the specifications for a MKIII F Band delay line, 26.4 uSec. as specified by Cossor Electronics for incorporation into the Rapier Missile System O.C.F. (Operator Confidence Facility). The Cossor Procurement Document with its NATO number SAN-70-2 is copied complete, along with a copy of a letter to me dated 30 Sept 82 and data sheets of microwave measurements made as a series of S29 lines. Accompanying these is a photocopied version of our Company Confidential manufacturing instructions for lines of this type giving all manufacturing and measuring processes in great detail. On no account should this document have passed outside the Hirst Research Centre without the consent of very Senior Management which to my knowledge has never been given. The folder also includes a generally available leaflet or Techbrief describing the HRC capability on delay lines. JS15 This folder contains a

Signed G. H. Swallow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 94

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gerald Herbert SWALLOW

wealth of information, including drawings on the manufacture and test of Surface Acoustic Wave Filters. One complete document is Commercial in Confidence but the file contains at least two documents which carry the classification RESTRICTED. One of these was issued to an engineer currently working at HRC, namely F.S. McClement and could only have been removed without his knowledge. The documents also include letters from M.O.D. personnel to HRC staff members of the period.

Signed G. H. Swallow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 95

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Dennis Geoffrey BARLOW

Age of Witness (date of birth) 44 years (3 March 48)

Occupation of Witness Quality Manager

Hirst Research Centre

East Lane, Wembley, Middx.

HA9 7PP 081 908 9000

Dated 11 August 1992

I am the Quality Manager of the Hirst Research Centre. I head the Quality Unit which consists of 9 people. I have headed this department for 7 years. My department is responsible for the operation of the quality system to the satisfaction of NATO approval AQAP 1, as supervised by MOD. From Dec 1985 to July 1992, Mr M J SMITH was a member of the department. From 1985 to 1987, Mr SMITH was engaged as a Quality Engineer; this involved him performing activities associated with QA of the following technologies. 1. compound semiconductor processing for microwave integrated circuits which could have military uses. 2. Infrared detectors, also with possible military uses. 3. Semiconductor products associated with microwave and power applications. In this role, his access to classified information was extremely unlikely, as his activity concentrated on processing rather than products. His position would not grant him the right to see or possess anything concerning information, blueprints, component

Signed D. G. Barlow Signature witnessed by M. Nicolson DI

No. 991A

Witness Statement Page 96

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Dennis Geoffrey BARLOW

manufacturing drawings in connection with the Rapier missile, of which this company has provided components. I can think of no reason for anyone in my department to possess any component in relation to the Rapier project, or have any authority to remove it from the HRC premises. Since 1987, Mr SMITH has organised and operated the internal quality audit programme at HRC. This involves reviewing and confirming the effective implementation of management systems and procedures. In this role, he would have access to all activities of the HRC except personnel or classified matters. I knew his clearance was up to confidential, hence restricted his activities to non-military. Again, in respect of any activities associated with Rapier, this was beyond his access. While taking this statement, DI NICOLSON showed to me a number of documents contained in clear sealed bags. They were opened by him in my presence. I make the following comments on the contents of those documents by reference to the exhibit numbers written on those bags. JS18 (Quasi Optical Car Radar). Written for someone else. Contains more information than I would expect for someone performing a QA job. First 3½ pages contain commercial information. Last two paragraphs indicate potential military application. Peter BRIGGINSHAW, a senior engineer and expert, mentioned by name. JS20 (Olfactory Research). Would have accepted these notes for own purposes and

Signed D. G. Barlow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 97

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Dennis Geoffrey BARLOW

information. JS17 (Micromachining Project). Basically commercial information. Could not date its preparation. I can think of military applications, but document does not state any. Amazingly detailed. JS19 (Micronvalve ). Basically commercial information technology has radiation hardness benefits which could make it of military interest. Wording suggests it is an update report. JS16 (Rugate Filters). References MOD establishments clear military applications, ref to SDI. The notes indicate a deep interest in technical and business details. This aspect has not been obvious in Mr SMITH’s past at HRC. My general view on the exhibits I’ve been shown is that if they were for personal use, I would expect them to be in a notebook with other areas of technology, and worded in a different style (as a personal record). I would have expected to be aware of such notes. The notes seem focussed and written for a third party, and extend beyond normal QA professional needs. Finally I was shown an untitled single sheet of paper contained in a clear sealed bag marked JS8. I have considered the contents of this and make the following observations. The number refers to an internal HRC contract reference, and the words give a general description of the contract activity. There is no obvious reason for their selection, but many have purely defence funding or

Signed D. G. Barlow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 98

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Dennis Geoffrey BARLOW

relevance. I do not understand the compressed format and have never seen this form of listing before. I do not understand why intermediate contracts of a similar nature have been omitted. I cannot understand why such a document would be created.

Signed D. G. Barlow Signature witnessed by M. Nicolson DI

No. 991C

Witness Statement Page 99

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Dennis Geoffrey BARLOW

Age of Witness (date of birth) 44 years (3 March 48)

Occupation of Witness Quality Manager

Hirst Research Centre

East Lane, Wembley, Middx. HA9 7PP

Dated 20 August 1992

I am the Quality Manager of the Hirst Research Centre and have been for 7 years. Today from 11.00 am at Berkhamsted Police Station DS WALSH showed me a number of documents contained in bags which he opened in my presence. I have been asked to assess each document. I make the following comments on each document by reference to the exhibit numbers on those bags. JS38 contains blueprints from Cossor Electronics and relate to the ‘F’ Band Delay Line for Rapier OCF MKII as stated on the drawings. Michael SMITH, who was a member of my department between December 1985 and July 1992, may have had access to them in 1986. I would not expect these to be in his possession either at the Hirst Research Centre or at his home. One blueprint is a GEC original of the box design for the ‘F’ Band Delay Line MKIII. This drawing gives clear manufacturing dimensions and tolerances, and again should not be in his possession. JS22-JS36 inclusive are GEC manufacturing drawings for the ‘F’ Band Delay Line MKIII parts, which whilst not indicated on the drawings appear to be for the Rapier OCF. Possession

Signed D. G. Barlow Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 100

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Dennis Geoffrey BARLOW

of these documents would give clear manufacturing information. JS15 contains documents generally relating to manufacture and test of S.A.W. devices, surface acoustic wave devices, which would assist a third party to establish the S.A.W. manufacturing process. One document titled “Demonstrator Programme, Requirement Specification Band Pass Filter Assembly” and marked ‘Restricted, Commercial In Confidence’ indicates its military application on page 2 in that it states “the filter is to form part of an IF receiver incorporated in an airborne guided weapon”. None of the JS15 documents should have been removed from the HRC (Hirst Research Centre). JS21 contains a letter to HRC from Cossor Electronics dated 30/9/82 in which reference is made to the delay line and the need for a NATO number. JS21 also contains detailed manufacturing information for delay lines in the form of company confidential documents, and copies of test reports. JS37 contains eleven GEC drawings relating to the ‘F’ Band Delay Line MKIII for the Rapier system, and these give extensive dimensions and tolerances on piece parts. Whilst he could have seen these drawings at work, he should not have had them in his possession. RH9 contains a highly specialised component. I am not able to comment on it. SR4 contains a mixture of ‘public domain’ documents and company confidential documents. One document of particular interest is the “Infra Red Detector Configuration Flow

Signed D. G. Barlow Signature witnessed by A. Walsh DS

No. 991C

Witness Statement Page 101

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Dennis Geoffrey BARLOW

Chart” which is marked ‘Commercially Most Secure Authorised Eyes Only’. This is used primarily for expensive detectors used in military surveillance applications. Mike SMITH may have been involved in writing the document, but again it should not have left the HRC. JS14 contains a mixture of components, chips and part assembled components. All appear to date from 1986/7 and are used for military purposes. Included are S.A.W. filters, high frequency gallium arsenide chips and radiation hard silicon on sapphire integrated circuit chips. All appear to be manufactured by HRC. Overall, all of the above relate to activities probably involving Mike SMITH during 1986 and 1987. I would not expect him to be involved with these items after 1987 and would not expect him to have them in his possession since he left employment at the HRC. Through my employment at the HRC, I can state that HRC is engaged on defence contracts for HM Government. I have been shown RH13 and RH17 and RH26 and PMS23. I can make no comment on these as they appear to relate to non-HRC activities.

Signed D. G. Barlow Signature witnessed by A. Walsh DS

No. 991C

Witness Statement Page 102

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Sqdn Leader Colin BAGLEY

Age of Witness (date of birth) 27 February 1939

Occupation of Witness Project Officer, Current Rapier System

Dated 11 August 1992

I am an RAF Squadron Leader currently posted to the Ministry of Defence (Procurement Executive). I have been a Rapier Project Officer for 5 years. Today I was made aware of enquiries by DCI Gray and DI Morrissey into a possible breach of the Official Secrets Act, I have been shown various articles in marked bags. These comprise engineering drawings, specifications and electronic components. I recognise these articles to relate to the Operators Confidence Facility, OCF, an item of test equipment used to test a Rapier by the operator, daily, when deploying and setting up the system. In my opinion these items have a military application only and could be useful to an enemy. Additionally, I believe that knowledge of these drawings and processes could be commercially beneficial in terms of military production.

Signed C. Bagley Signature witnessed by M. Morrissey DI

No. 991A

Witness Statement Page 103

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Sqdn Leader Colin BAGLEY

Age of Witness (date of birth) 27 February 1939

Occupation of Witness Project Officer, Current Rapier System

Dated 24 August 1992

Further to my statement of 11th August 1992 I have today been shown plastic envelopes with exhibit identification marks JS/22, JS/23, JS/24, JS/25, JS/26, JS/27, JS/28, JS/29, JS/30, JS/31, JS/32, JS/33, JS/34, JS/35, JS/36, JS/37 thereon, relating to engineering drawings specifications and electronic components. I have previously been shown these items by Detective Inspector MORRISSEY on 11th August 1992. I can confirm that these are the same items that I saw previously with the exception of the blueprints which are not available today.

Signed C. Bagley Signature witnessed by M. Morrissey DI

No. 991A

Witness Statement Page 104

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Squadron Leader Colin BAGLEY

Age of Witness (date of birth) 27 February 1939

Occupation of Witness Royal Air Force Engineering Officer

Dated 28 October 1992

I am a Rapier Project Officer within the Ministry of Defence Procurement Executive and have been so employed for 5½ years but with a total of 9 years Rapier experience. The classification of the Rapier project is Restricted although the classification of the drawings and diagrams of the Operators Confidence Facility (OCF) is at either Unclassified or Restricted level. Rapier is a Short Range Air Defence weapons system used to defend military airfields and other similar strategic areas. It is in-service with the Army, Royal Air Force, United States Air Force and a number of overseas countries. The OCF is a test facility used by an operator to test the functions of the Information Friend or Foe and Surveillance Radar within the Rapier system; these are the means by which the system detects targets. The ‘F’ Band delay line delays a received signal by a specific period of time and then re-transmits it to seduce the Rapier system into believing that the signal is derived from a target within the operating range of the system and thus prove that the system is functioning correctly. The OCF is manufactured by Cossor Electronics and although it still forms part of the current Rapier system it is no longer in production. The ‘F’ Band delay line is an obsolete component. By modelling from OCF drawings and diagrams it would

Signed Colin Bagley Signature witnessed by M. Nicolson D.I.

No. 991A

Witness Statement Page 105

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Squadron Leader Colin Bagley

be possible to back calculate and obtain some understanding of the design parameters and functions of the prime unit, i.e. the Surveillance Radar. Knowing this kind of detail, particularly any frequency sensitive data, could reveal information that could be used by a possible enemy for jamming (the electronic means of disabling a Radar) thus preventing the detection of potential enemy targets by the Rapier system. The individual diagrams and drawings on their own have no significant security classification, they may only attract a higher classification when part of a complete system.

Signed Colin Bagley Signature witnessed by M. Nicolson D.I.

No. 991C

Witness Statement Page 106

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Gordon Stephen SMITH

Age of Witness (date of birth) 17 July 1939

Occupation of Witness Project Manager, Ministry of Defence

Dated 11 August 1992

I am the Project Manager for the Rapier Air Defence System Project. I have been so employed for 3 years. I am aware of police enquiries into a possible breach of the Official Secrets Act. Today at about 10.10 am I met with Detective Chief Inspector GRAY and Detective Inspector MORRISSEY who showed me various articles in marked bags. Having examined drawings, specifications and assembly schedules together with a number of components it is evident that they relate to the OCF of the Rapier system. The OCF, the Operators Confidence Facility, forms part of the test equipment for the operational Rapier system. The Mark 2 version being applicable to Field Standard B1, FSB1, and the Mark 3 version to Field Standard B2, FSB2. The last FSB2 system to be produced will be available to enter service in September this year. I am of the opinion that the loss of this information would be prejudicial to the interests of the UK, and the other users of the Rapier system, that is to say our

Signed G. S. Smith Signature witnessed by M. Morrissey DI

No. 991A

Witness Statement Page 107

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Gordon Stephen SMITH

Allies. In my view this information has only a military application. In my view this information might also be useful to an enemy.

Signed G. S. Smith Signature witnessed by M. Morrissey DI

No. 991C

Witness Statement Page 108

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Gordon Stephen SMITH

Age of Witness (date of birth) 17 July 1939

Occupation of Witness Project Manager, Ministry of Defence

Dated 24 August 1992

Further to my statement of 11th August 1992. Today Detective Inspector MORRISSEY has shown me drawings, specifications and assembly schedules which I have previously seen on the 11th August 1992. I notice that these are in plastic envelopes marked with the following exhibit identification marks JS/22, JS/23, JS/24, JS/25, JS/26, JS/27, JS/28, JS/29, JS/30, JS/31, JS/32, JS/33, JS/34, JS/35, JS/36 and JS/37. These are the same items I refer to in my previous statement, with the exception of some blueprints which I have been told are not available to be seen today.

Signed G. S. Smith Signature witnessed by M. Morrissey DI

No. 991A

Witness Statement Page 109

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Peter Leonard KNOWLTON

Age of Witness (date of birth) Over 21 (16 September 1939)

Occupation of Witness HPTO, Ministry of Defence

Dated 10 August 1992

I am Project Officer working within the Ministry of Defence and have worked on the Rapier Project for approximately 3½ years. Today, I was asked to meet Det. Ch. Insp. GRAY at the Ministry of Defence HQ, Metropole House, Northumberland Road and was asked to examine articles marked JS/14 to JS/38 inclusive. I was asked to express an opinion on the sensitivity of these articles in the context of national security and their usefulness to a foreign power. In my opinion, the articles seen do not on their own expose the country to any risk or exposure should they or the information reach a foreign power. However should the same information be added to other information known to be from the same Rapier or other system they could and would be able to be used for a purpose which may be of use to a foreign power.

Signed P. Knowlton Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 110

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Andrew WALSH

Age of Witness (date of birth) Over 21

Occupation of Witness Police Officer

Dated 26 August 1992

On Tuesday 11th August 1992, in company with DS STAFFORD, I attended the Defence Research Agency, (DRA) which is based in Malvern, Worcestershire, in connection with enquiries into an alleged offence against the Official Secrets Act 1911. In my possession were exhibits AW/2, AW/3, AW/4, AW/5 and AW/6. These exhibits are true copies of the exhibits identified as JS/16, JS/17, JS/18, JS/19 and JS/20 respectively. I prepared these copies in advance as the original exhibits, JS/16 to JS/20 inclusive, were to be examined elsewhere, and the pressing nature of the enquiry due to the prisoner’s continued detention in custody indicated that it would be inappropriate to delay my enquiry to be in possession of the original exhibits. Whilst at the DRA, between approximately 10.15 am and 3.20 pm I presented the exhibits AW/2 to AW/6 inclusive for examination by various scientific personnel, namely Professor K LEWIS, Mr M LEWIS, Mr LAMBERTON, Mr DEADMAN and Dr BROWN. After their examination each of the scientists prepared a statement regarding his observations on the contents of the documents relating to their areas of speciality.

Signed Andrew Walsh DS Signature witnessed by

No. 991A

Witness Statement Page 111

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Meirion Francis LEWIS

Age of Witness (date of birth) Over 21

Occupation of Witness Civil Servant

Dated 11 August 1992

I am currently responsible for the optical signal processing section at DRA Malvern. Prior to this I was in charge of research into surface acoustic wave (SAW) devices at RSRE Malvern in the period from 1977 to 1985. Today I was shown a number of documents labelled AW/2 to AW/6 inclusive by DS Walsh and asked to comment on their sensitivity in relation to an alleged offence under the Official Secrets Act. One of these documents labelled AW/6 relates to the use of surface acoustic wave and bulk acoustic wave devices as detectors of gas. The principles of operation, the device sensitivity, and principles of gas identification mentioned in this document have been published in the open literature. The document indicates, however, that device fabrication is now reproducible, and briefly indicates the fabrication process and form of the response of the device to exposure to a gas. The particular gas or gasses studied are not revealed. This information might be of use to a foreign power as gas sensors are of value in both civilian and

Signed M. F. Lewis Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 112

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Meirion Francis LEWIS

military applications. In my opinion the knowledge that such sensors can be made reproducibly, and processed to reveal the make-up of a gas sample, could be prejudicial to the interests of the United Kingdom. If details of the gasses involved have been or were to be revealed this would further compromise the United Kingdom. I am willing to attend court and give evidence in camera if necessary.

Signed M. F. Lewis Signature witnessed by A. Walsh DS

No. 991C

Witness Statement Page 113

Form MG 11(T)

STATEMENT OF Meirion Francis LEWIS

Age if under Over 21

Dated 3 November 1992

Further to the statement given on 11th August 1992 in which I assessed documentation identified as AW/6, I have today been shown document JS/20, the original of AW/6, a further quantity of documents contained in JS/15, and six SAW devices in JS/14. I make the following observations on these documents and devices. Most of the documents and all the devices relate to surface acoustic wave (SAW) devices. These operate by converting an electrical signal to the form of an acoustic wave on the surface of a crystal like quartz, and then reconverting it to electrical form. The surface acoustic waves are similar to waves on the sea. During the device operation the electrical signal is modified, for example delayed, or filtered so as to pass only frequencies of interest. These devices are of considerable commercial importance, for example there is one in every TV set and video recorder. They are also of military importance because they work at appropriate frequencies, provide a high-fidelity response, and are small, rugged and reliable. The six examples I have examined from JS/14 are all narrowband filters and quite possibly have a military purpose. None is related to gas-sensing. The notes in JS/15 comprise a set of intimate details on the processing of SAW devices, and their mounting and packaging, and test procedures. They also indicate the personnel involved. The details included relate to the substrates, their orientations, polishing, backface preparation, packaging, electron beam evaporation procedures for the metallization, bond formation, the mask alignment jig operation, tuning circuits, and mounting adhesives. One document (Demonstrator Programme Requirement Specification Bandpass Filter Assembly) relates to a filter

Signed M. F. Lewis Signature witnessed by S. Stafford DS

Witness Statement Page 114

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Meirion Francis LEWIS

developed as a demonstrator for the receiver in an airborne guided weapon. Another relates to an ESA project, and is concerned with space qualification of the SAW devices. One document (ABSTRACT FOR INCLUSION IN PD9002) relates to a spinel delay line providing 30 microseconds delay at 3 GHz. This is not a SAW device, but a bulk acoustic wave device used in RAPIER. This information is valuable to a foreign power as it provides intimate details of the manufacturing processes of SAW devices, and the means of testing same. The applications of these devices are diverse, but some are definitely military applications as is clear from these notes.

Signed M. F. Lewis Signature witnessed by S. Stafford DS

Witness Statement Page 115

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Harry Alexander DEADMAN

Age of Witness (date of birth) Over 21

Occupation of Witness Government Service

Dated 11 August 1992

I am section leader of the millimetre-wave radar section for seeker applications. I have been working in this field for 10 years. I have been shown exhibits AW/2 to AW/6 by Det. Sgt. Walsh. My professional expertise extends to AW/4 and AW/5 only. I have been asked to express an opinion on exhibits AW/4 and AW/5 as to their sensitivity and possibility of contravening the Official Secrets Act. Exhibit AW/4 describes a millimetre-wave quasi-optical car radar technology aspect. The application of the technology to car radars is strictly commercial. However, the exhibit contains a paragraph which identifies the specific application of this technology to missile systems and therefore would be of use to an enemy. Exhibit AW/5 describes a specific part of technology for micron valves. It is a statement of technology for which there are no specific applications planned at the moment. In my professional opinion exhibit AW/5 does not contravene the Official Secrets Act.

Signed H. A. Deadman Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 116

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Keith Loder LEWIS

Age of Witness (date of birth) Over 21

Occupation of Witness Government Service

Dated 11 August 1992

I am Head of the Thin Fibre Optics Section at DRA Malvern and Project Officer for an SDI sponsored programme researching advanced concepts for spacecraft sensor protection. Today I was shown a group of documents labelled AW/2 to AW/6 inclusive by DS Walsh and asked to comment on their sensitivity in relation to an alleged offence under the Official Secrets Act. Of these documents, the one labelled AW/2 referred to a programme of work currently being carried out at GEC Hirst Research, for which I am technical sponsor. The document highlights the current state of progress on this contract and identifies the fact that an extension has been agreed until 1994. Whilst many of the technical details have been published in the open scientific literature, document AW/2 makes a connection between the devices produced and their application for laser protection particularly in the SDI context. It also identifies a major point of contact in the USA. Taken as a whole, the document identifies certain aspects of the laser

Signed K. L. Lewis Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 117

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Keith Loder LEWIS

threat and methods for its countermeasure and in so doing compromises the security of the State. It also prejudices the UK government’s relationship with the US, particularly in respect to the US government’s views of the UK’s ability to protect the dissemination of information in a classified area of work. If necessary I would be willing to attend court and give evidence in camera.

Signed K. L. Lewis Signature witnessed by A. Walsh DS

No. 991C

Witness Statement Page 118

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Hugh Murdoch LAMBERTON

Age of Witness (date of birth) Over 21

Occupation of Witness Government Service

Dated 11 August 1992

I am Head of ERI division at DRA Malvern, responsible for research on Electro-Optics sensors, a topic which includes cooling technology for infra-red detectors (cryogenic cooling). I have 25 years experience in research, mainly in Electro-Optics. Today I have been shown a series of documents marked AW/2 to AW/6 by DS Walsh in connection with an enquiry under the Official Secrets Act. I am only qualified to comment on document AW/3. The section on Cryogenic Refrigeration has some ambiguity in that the achieved performance “19 K cooling in 1 sec” could refer to a rate of change, in which case it is unremarkable. If however, it refers to a final temperature of 19 K achieved in 1 second, the technique would be outstanding. The cooling loads quoted are not sufficient by about 2 orders of magnitude for military use as an IR detector cooler. I consider that the data is of industrial or civilian relevance rather than military. I consider that the work reported is at the leading edge of technology. I do not feel qualified to assess how much value this would be to a foreign power.

Signed H. M. Lamberton Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 119

Form MG 11(T)

STATEMENT OF Hugh Murdoch LAMBERTON

Age if under 21 Over 21

Dated 3 November 1992

Further to my statement made on 11 August 1992 I have today been shown a set of documents marked SR4, which was opened in my presence. I have inspected the contents and I have made the following assessment. One of the documents in SR4 is entitled ‘Infra-Red Detector Configuration Flow Chart’ and is dated June 1988. This document discloses commercially confidential industrial information, giving full details of the process, in flow chart form, for the production of Cadmium Mercury Telluride (CMT) TED IR detectors. These are state of the art military components. GEC-HRC manufacture these devices for incorporation in UK military Thermal Imaging equipment (UK Thermal Imager Common Modules - UK TICM). These equipments are state of the art military systems, in an area where the UK is a world leader (with the USA). Although not specifically classified, this information would be very valuable to foreign powers and disclosure would be damaging, in that it could be used to develop a military capability, which did not previously exist. This would reduce the current UK Technological Military Advantage. I suggest that PD/TASS, MOD, as the procurement office for Thermal Imagers should be consulted. A second document in SR4 concerns Joule-Thomson (JT) minicoolers, and is dated 23 February 1984. These devices are used in the UK TICM to cool IR detectors. JT minicoolers are largely, but not exclusively, military components. The document details, in general terms, the handling processes required when installing JT minicoolers into Thermal Imaging equipments. Most of the information is readily available in manufacturers open literature and hence disclosure would not be damaging.

Signed H. M. Lamberton Signature witnessed by S. Stafford DS

Witness Statement Page 120

Form MG 11(T)

STATEMENT OF Alison Meryl HODGE

Age if under 21 Over 21

Dated 3 November 1992

Today, Tuesday, 3rd November 1992, I was shown documents contained in SR4 and objects contained in JSl4. I make the following observations: The information includes documents and samples from a specific silicon microelectronic technology, namely silicon on sapphire. Device fabrication and research was undertaken at the GEC Hirst Research Centre but has now been terminated at that site. Production continues at the GEC Plessey Semiconductors site in Lincoln, their technology is based on that developed at HRC but has been modified and advanced since. Silicon on sapphire technology has been developed with considerable support from MOD over a period of 15 years or so, with a view to its incorporation in military systems specifically. Technically there are claimed benefits of the technology for civil applications, but in practice the technology has been exploited almost exclusively for its tolerance to radiation so that it has remained a military specific technology predominantly. Commercial, as well as military satellites, also use this technology. Specific information in the documents such as Design Rules of Standard Linewidth Measurement Structures, CD Specification, indicate the state of the technology at the document date. The specifications for incoming material 100mm silicon on sapphire wafers, 100mm p-type epi wafers for Cmos show the characteristic of the starting material used for device manufacture. This is important as the start material can influence device performance, especially in the military specific applications such as those requiring radiation tolerance. These specifications also include approved suppliers implying that these have been selected for some reason.

Signed A. M. Hodge Signature witnessed by S. Stafford DS

Witness Statement Page 121

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Alison Meryl HODGE

Two documents are drafts of what a typically used as marketing literature. These are the video line buffer and signal stream product family. This, or a later draft, may therefore have been released openly. The ‘Advance Information’ sheet on the Cascade ACU is similar but the attached detailed description may have been retained as company information. Allied to the technical process information referred to above, the product information (of the same era) can be used to deduce the possible capability of the company at the time. Technically, their capability is now a generation or more behind that being produced by the GEC Company as their state-of-the-art. However, as military systems are developed over periods of many years and remain in service for tens of years, then the technology discussed is likely to be in military systems and hence of military relevance for some time to come. The latest state of the art is described, at least superficially, for another part of the GEC organisation concerned with the manufacture of silicon devices (not silicon on sapphire) in the centre spread of the “Topic GEC newspaper” June 1992 issue. It is hence possible to deduce how the company is advancing its technology since about 1986-87, if one is aware of the general developments in the field. The objects SLC3, SLC4, SLC5 are all individual SOS chips. These have been produced with equipment similar to that at GEC HRC in the period up to mid 1980s. They appear, at first sight, to be test structures rather than functional circuits. These could, if functional, still yield valuable information about the performance of the process and any devices made using it. More detailed examination, by experts could be used to deduce the specific problems being addressed by such test structures and hence where there were technical concerns at the time. The characters CQC3 near the chip identifies (only visible with a microscope) may relate to quality control. The chip SLC6 is marked MEDL CELLSOS MA931A. This suggests that Marconi Electronic Devices Limited were involved with the design and/or manufacture of this circuit. This could therefore be used to

Signed A. M. Hodge Signature witnessed by S. Stafford DS

Witness Statement Page 122

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Alison Meryl HODGE

indicate the state of the manufacturing capability rather than that at this research laboratory. As a circuit, an expert may be able to deduce information about its function and performance.

Signed A. M. Hodge Signature witnessed by S. Stafford DS

Witness Statement Page 123

Form MG 11(T)

STATEMENT OF Michael ALLENSON

Age if under 21 Over 21

Dated 3 November 1992

I have examined the following documents from SR4 today Tuesday 3rd November 1992 at DRA Malvern

1. AN/102 Monolithic microwave integrated circuits storage, handling precautions.

2. Advance and preliminary information sheets on the following MMICs:

M1208A 8-12 GHZ mixer, GP1208A 4 bit phase shifter 8-12 GHZ, GA1801A 0.5-18GHZ amplifier, GS1802A PIN diode switch, GM9888A 94 GHZ balanced mixer.

These documents represent part of a venture by GEC to launch these chips for sale on the open commercial market, and I judge the information would be freely available on request or at trade exhibitions. The chips have application in both military and commercial systems. No link with military systems was found in SR4, generic military application data has appeared in the public domain for example GEC Journal of Research Vol 4 No 2 1986. (1) For GM9888A the commercial applications are limited, reference (1) identified Terminally guided sub munitions as a potential application for chips at this frequency.

I also examined at DRA Malvern on 3rd November 1992 five packages of devices from JS14. These contained MMIC chips as follows.

1. SLC1 - Blank proforma label. Contains 1 chip, a travelling wave amplifier GEC17 - 11a 1987 probably 0.5-18GHZ, either an early or final version of GA1801A.

2. SLC1 ceramic carrier with two bonded up chains of chips. One made up from 1 x GEC 17 - 11a, 2 x GEC 17 - 11 b one from 3 x GEC 17 - 11a.

Signed A. M. Hodge Signature witnessed by S. Stafford DS

Witness Statement Page 124

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Michael ALLENSON

3. SLC1 labelled: Bender rejects from T-CSF 2 x DC6001 contains two travelling wave amplifier chips both GEC manufacture probably DC to 12GHZ. It is probable that the T-CSF referred to on the label is the French company Thomson - CSF.

4. SLC1 labelled 5 of D6001 for photo’s. Similar devices to 3, a slightly different design.

5. SLC2 Box labelled GM9888A, contains a single chip with bond wires attached. This is the 94 GHZ mixer GM9888A in its waveguide probe version.

The MMIC technology research programme and specific chip designs were funded by MOD and by GEC companies, including the military system companies, this was primarily with military application in mind. The chips were being offered for sale, it is probable the most likely market would be in military system, commercial applications also exist. There may be limitations on the export of this technology to former Eastern Block countries, I am not familiar with the detail. The chip samples could be used to gain some very limited information on the commercially sensitive semi conductor process methods. However, this is a field where the circuit design methods and the general elements of the technology have been published worldwide in the scientific literature.

Signed M. Allenson Signature witnessed by S. Stafford DS

Witness Statement Page 125

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF John Richard WEATHERLEY

Age of Witness (date of birth) Over 21

Occupation of Witness IFF Programmes Executive

Dated 24 August 1992

I am a Programmes Manager for Cossor Electronics Ltd. having been employed at Cossor since 1980. Primary work involves Identification Friend or Foe (IFF) related to military projects. Today DS Walsh visited my place of work and asked me to examine two packages of exhibits which were identified as JS21 and JS38. I recognise these to be documents relating to the purchase and specification of a component developed in conjunction with GEC Hirst for the Rapier OCF product. All documents are copies. The documents would normally be provided to GEC Hirst in order to assist with the purchase of component items. I recognise the letter dated 30th September 1982 (from exhibit JS21) as being generated by myself during specification discussions. JS21 are documents defining the component specification requirements. JS38 are copies of Cossor drawings used to confirm requirements as part of procurement exercise. JS21 and JS38 both relate to the delay line component at various build standards. The component is used to provide a delay

Signed J. R. Weatherley Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 126

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF John Richard WEATHERLEY

in time for received radio frequency signals. Applications can include both military and civil radar systems of the appropriate frequency band. The frequency band specified is appropriate to the Rapier primary radar frequency. This information in conjunction with classified product and system information may be useful for establishing Rapier system performance parameters. The use of delay line with the OCF application as a test system could only be useful to a competitor or foreign power as a minor element of a much larger data base. The documents were produced as part of a development contract for HMG as part of a performance upgrade programme for Rapier build standards. The OCF product which uses the delay line is defined by a classified document. None of the documents JS21 and JS38 are classified within Cossor Electronics Ltd. In conclusion I would suggest that the data contained within the documents does not cause any security problem in its own right. However frequency information of a general nature may be useful in conjunction with other system data gathered.

Signed J. R. Weatherley Signature witnessed by A. Walsh DS

No. 991C

Witness Statement Page 127

Form MG 11(T)

STATEMENT OF Dr David Ian WEATHERLEY

Age if under 21 Over 21

Dated 7 November 1992

I currently occupy the post of Scientific Adviser (Land) within the MOD, in which capacity one of my responsibilities is that of maintaining a technical overview of all Land systems-related research and procurement programmes, operational requirements and operational capabilities.

On Thursday 5th November 1992, in my office at the Ministry of Defence, Whitehall, London, SW1, I met with Detective Inspector Nicolson and Detective Sergeant Stafford, both of Special Branch, New Scotland Yard, who advised me that they were investigating offences against the Official Secrets Act. I was asked to examine a number of documents and devices contained in sealed bags, with a view to assessing their significance. In making my assessment I made reference to statements, each dated 3rd November 1992, which had been made by Michael ALLENSON, Alison HODGE, Hugh LAMBERTON and Meirion LEWIS, all of whom I know to be scientists employed at the Defence Research Agency in Malvern, and to a statement, dated 28th October 1992, which had been made by Squadron Leader Colin BAGLEY who I know to be a project officer in the Procurement Executive of the Ministry of Defence. The documents and devices which I examined are broadly dealt with in six categories:

1. Handwritten Notes (Exhibit Nos. JS16, JS17, MN15 - a photocopy of JS18, JS19 and JS20).

(a) Olfactory Research: The technique described has applications in Chemical and Biological Defence, and in the detection of substances for Internal Security purposes.

Signed D. I. Weatherley Signature witnessed by M. Nicolson D/I

Witness Statement Page 128

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr David Ian WEATHERLEY

The statement of achievable sensitivity is of concern, since it provides an indication of the likely performance of future UK detection systems.

(b) Rugate Filters for SDI: The Rugate filter process is well known, but the provision of information on the number of rejection notches realisable with UK design processes, and the description of the techniques which are necessary to increase the radiation hardness of filters, have significance because they enable some performance characteristics of possible future UK defence systems to be deduced.

(c) Quasi-Optical Car Radar: The technique described has potential military applications for example in robotics, automatic route-finding and obstacle avoidance, and smart weaponry, but I believe that the information presented is not of a sensitive nature.

(d) Micron Valve Project: The Micron Valve technology is of Defence relevance because it offers the prospect of providing a means by which future sensors and systems might be hardened against radiation weapons. The information presented describes how specific fabrication techniques improve device performance, and gives an indication of the degree to which future UK military systems might be protected.

(e) Micromachining Project: This is another technology which has potential application to the radiation-hardening of future sensors and systems. The performance details are sufficient to indicate the UK state-of-the-art, and to indicate the likely feasibility of Defence applications.

In general the level of technical detail is relatively low, but all items have Defence or Internal Security relevance. There is some indication of an underlying theme of providing information on fabrication techniques and processes, a theme which recurs in the further assessments described below.

2. Rapier Missile System - Build specifications and blueprints for the F-band Delay Line MK III for use in the OCF (Exhibit Nos. JS21 to JS38 inclusive). The material examined provides details of techniques employed to fabricate a delay line based on a technology which has now been rendered obsolete by technological advances. I

Signed D. I. Weatherley Signature witnessed by M. Nicolson D/I

Witness Statement Page 129

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr David Ian WEATHERLEY

consider that the benefits to the recipient of this information would be purely military ones, for instance to allow a deduction of some Rapier operating parameters in order to aid the development of technical and operational countermeasures for use against a system which is operationally deployed.

3. Silicon On Sapphire Technology (Documents contained in Exhibit No. SR4, and devices contained in Exhibit No. JS14). This is another technology of considerable Defence relevance because of its ability to provide radiation-hardened components for sensors and weapons systems, and its high cost mitigates against wide commercial exploitation. The information examined could be used to provide an estimate of the likely degree of radiation hardness of future UK systems, and could aid development of improved hostile weapon systems.

4. Gallium Arsenide Technology (Documents contained in Exhibit SR4, and devices contained in Exhibit No. JS14). This is another highly-relevant area of technology, because it offers the prospect of signal processing devices which are much more capable than those currently available. Potential applications are in many areas, but particularly those of smart weapons, radars and Electronic Warfare systems. The information examined provides an indication of UK device capabilities and of the likely performance of future military systems. It also provides details which could help potential future adversaries develop countermeasures or equivalent capabilities.

5. Surface Acoustic Wave Technology (Documents contained in Exhibit No. JS15, and devices contained in Exhibit No. JSl4). Surface Acoustic Wave (SAW) devices are widely used in a variety of military systems. Details of design and fabrication processes could be used to enhance the performance of devices available to a potential aggressor, thus to allow the development of more capable military systems.

6. Thermal Imager Technology (Documents contained in Exhibit SR4). The UK is in the forefront of Thermal Imager technology, and thus our military platforms

Signed D. I. Weatherley Signature witnessed by M. Nicolson D/I

Witness Statement Page 130

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr David Ian WEATHERLEY

have a significant performance advantage over their likely adversaries. The UK lead stems from unique capabilities in the exploitation of materials and fabrication processes, in particular with regard to Cadmium Mercury Telluride (CMT) which is used for high performance detectors. The information examined, in particular the production process flow chart, could provide a potential aggressor with sufficient guidance to be able to develop a comparable capability which would erode the UK military advantage.

I believe that the documents and devices which I have examined comprise a set of information which could be damaging to UK Defence capabilities if it were to be provided to any one of a number of potential future aggressor nations. This belief is based on my knowledge and experience of a wide range of Defence requirements, priorities, programmes and operational procedures, and on my regular contact with the technologies represented by the information assessed.

Many of the technologies are the subject of restricted technology transfer, as defined in the COCOM procedures. Of particular concern is the underlying theme of fabrication technologies and processes relating to integrated circuit production, an area in which the UK is at the forefront of world capabilities. This is an area which has a direct bearing on the ability to develop and produce sophisticated weapons systems, and which is protected by the COCOM restrictions. The appearance of information related to the UK military Thermal Imager programme is of particular concern.

Signed D. I. Weatherley Signature witnessed by M. Nicolson D/I

Witness Statement Page 131

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF James Frederick WILDISH

Age of Witness (date of birth) 24 September 1939

Occupation of Witness SSO Ministry of Defence

Dated 10 August 1992

I am a Senior Scientific Officer employed with the MOD Scientific and Technical Security Branch and have been so employed for the past 26 months, prior to which I have been employed with the MOD for 26 years. Today I was asked to meet Detective Chief Inspector GRAY at the MOD HQ Metropole Building and was asked by him to examine articles marked JS/14 to JS/38 inclusive. I was asked to express my opinion as to the sensitivity of these articles in the context of national security. Having examined these articles it is my opinion that individually they do not pose a threat to the security of the nation. However, combined with more detailed information and technology of weapon systems in particular, they could be of benefit to a foreign power.

Signed J. F. Wildish Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 132

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Karl Adrian GEHRING

Age of Witness (date of birth) 54 (21 February 1938)

Occupation of Witness Unemployed

Dated 27 August 1992

My formal scientific qualifications are, B.A Physics 1962, and a D. Phil 1966 in Physics. I held research fellowships for a total of twelve years at two Oxford Colleges in succession. This involved mostly research in Solid State Physics. (Solid State is that branch of physics which seeks to understand why solids behave the way they do). From approximately 1978 to 1984, I worked for Thor Cryogenics Ltd, Oxford, as development manager and later technical director. One of Thor’s major products was super conducting magnets. I was a research scientist at Thor Cryogenics in respect of new technology. I left Thor Cryogenics in September 1984 and joined G.E.C. Hirst Research Centre. Initially, I was a research scientist, however, by about 1986 I was the Divisional Manager for super conductivity devices. This made me responsible for both methods of fabricating super conducting devices, using thin-film technology. (Thin-film technology is the deposition of a very thin film of a useful material on to a clean surface of a carrier material, thus enabling useful devices to be manufactured). The other responsibility was developing applications of these super conducting devices. The major applications were in the fields of

Signed K. A. Gehring Signature witnessed by R. Gilbertson DS

No. 991A

Witness Statement Page 133

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Karl Adrian GEHRING

military and medical technology. Whilst employed as Divisional Manager at G.E.C. Hirst Research Centre, I was managing the biggest industrial research effort in the field of thin film super conductivity in the country. I am an expert in following areas respecting the technology of super conductivity. i) Super Conducting materials These are materials which conduct electricity without electrical resistance. ii) Thin Film Super Conducting Devices These I have previously explained. iii) Electronic Applications of Super Conductors The application of super conducting devices in a military, medical and commercial sense.

I have lectured on both the science and technical/industrial applications of super conductivity. (super conductivity in a very basic sense is the property of a material, which when cooled to a very low temperature enables electrical current to pass through it without electrical loss). The entire field of super conductivity was revolutionised in 1987 when a new family of materials which become super conducting at temperatures significantly higher than temperatures of previously known super conductors was discovered. This was because the impediment to the commercial exploitation of the previously known super conductors was the cost and complexity of the cooling mechanism. The new super conductors could be cooled conveniently and cheaply. As a result of that it made the technology of super conductivity i) more compact and lighter for military application. ii) Viable for commercial exploitation. During my time as Divisional Manager of G.E.C. Hirst Research Centre I was concerned in the development of the applications of these new materials. The best example of a novel device employing super conductors is an ultra sensitive detector of magnetic fields. This could be used

Signed K. A. Gehring Signature witnessed by R. Gilbertson DS

No. 991C

Witness Statement Page 134

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Karl Adrian GEHRING

for military applications, such as the detection of submarines, and for medical applications such as the detection of electrical signals in the human brain. In my opinion the discovery of these new super conducting materials has immensely important implications for future electrical and electronic technologies. Products made with these materials will command markets worth billions of pounds. I have been asked if I know a Mr Michael John SMITH, who worked at the G.E.C Hirst Research Centre. I did know him because I met him professionally over the past five or six years. I did not know him well, I never met him at any social occasion whatsoever. I know no more about his professional responsibilities, other than the fact that he worked in the Quality Control Department of G.E.C. Hirst, and it is in this capacity that I met him. The ‘West’, including Japan are the leaders in the field of super conductivity. Eastern Europe has a small effort in the field which is poorly equipped and financed.

Signed K. A. Gehring Signature witnessed by R. Gilbertson DS

No. 991C

Witness Statement Page 135

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Malcolm MacLEOD

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Chief Superintendent

Dated 1 September 1992

On Friday 7th August, 1992 as a result of information received in Special Branch concerning an alleged breach of the Official Secret Act, I conducted separate briefings in respect of a proposed police operation which was to be put into effect on Saturday 8th August 1992. The first briefing was with Detective Chief Inspector MacKENZIE concerning a surveillance requirement in the vicinity of 48A Burton Road, Kingston-Upon-Thames. The second briefing was with Detective Inspector MORRISSEY and concerned the execution of a search warrant in respect of the premises at 48A Burton Road and two vehicles namely a Peugeot motor car index number D 514 BLD and a Datsun motor car index number KJH 249W. The third and final briefing was with Detective Inspector NICOLSON and concerned specific instructions concerning the arrest and subsequent removal to Paddington Green Police Station, Michael John SMITH and his wife Pamela Avril SMITH. These instructions were put into effect on Saturday 8th August 1992. As the senior investigating officer I attended Paddington Green Police Station where I took charge of the investigation. Between Saturday 8th and Tuesday 11th August, 1992, I conducted a series of interviews with Michael John SMITH, born 22.9.48, formerly a Quality Systems Audit manager with G.E.C., Hirst Research Centre,

Signed M. MacLeod Signature witnessed by

No. 991A

Witness Statement Page 136

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Malcolm MacLEOD

North Wembley. The interviews, which were recorded on audio tape, were conducted in Interview Room 2 of the Secure Unit at Paddington Green Police Station in strict compliance with the Police and Criminal Evidence Act. The tape recording machine was operated by Detective Sergeant BEELS who assisted me in the interviews. Mr SMITH was legally represented throughout by the Duty Solicitor Mr Richard JEFFRIES of Tucker Solicitors. The interviews took place as follows:

1) Saturday 8th August 1992, 5.50pm to 6.41pm

2) Saturday 8th August 1992, 7.13pm to 7.34pm

3) Sunday 9th August 1992, 2.08pm to 3.36pm

4) Sunday 9th August 1992, 4.15pm to 6.47pm

5) Sunday 9th August 1992, 9.12pm to 9.21pm

6) Monday 10th August 1992, 4.57pm to 5.55pm

7) Monday 10th August 1992, 8.19pm to 9.16pm

8) Monday 10th August 1992, 9.52pm to 10.08pm

9) Tuesday 11th August 1992, 10.20am to 10.23am

10) Tuesday 11th August 1992, 10.26am to 11.24am

11) Tuesday 11th August 1992, 12.21pm to 12.58pm

12) Tuesday 11th August 1992, 5.27pm to 6.33pm

13) Tuesday 11th August 1992, 8.23pm to 9.50pm

14) Tuesday 11th August 1992, 10.20pm to 10.48pm

I was present in the custody room at 11.24pm on Tuesday 11th August 1992, when the Custody Officer formally charged SMITH with offences of espionage contrary to Section 1 of the Official Secrets Act, 1911. The charges were read over to SMITH by the Custody Officer. He was cautioned but made no reply.

Signed M. MacLeod Signature witnessed by

No. 991C

Witness Statement Page 137

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Stephen John BEELS

Age of Witness (date of birth) 34 years

Occupation of Witness Detective Sergeant 59/171167 (S.O.12)

Dated 23 August 1992

This statement, (consisting of 6 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

Between Saturday, 8th August 1992 and Tuesday, 11th August 1992 at Paddington Green Police Station, as part of an investigation into suspected offences against the Official Secrets Act, 1911, I was present at a series of interviews of Michael John SMITH, a man who I knew to have been arrested in connection with the investigation. The interviews were recorded on audio tape cassette and the recording equipment was operated throughout by myself. All interviews took place in interview room number two of the secure unit of Paddington Green Police Station and all times stated were taken from my own wristwatch. Each master tape cassette was sealed in the presence of SMITH and signed by him.

1. On Saturday, 8th August 1992 between 5.50 pm and 6.41 pm an interview took place which was tape recorded. Present throughout the interview were Michael John SMITH, Richard JEFFERIES (Solicitor representing SMITH, from ‘TUCKERS’ solicitors), Detective Superintendent Malcolm MACLEOD and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/1 and SJB/2.

Signed S. Beels D/S Signature witnessed by

No. 991A

Witness Statement Page 138

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Stephen John BEELS

2. On Saturday, 8th August 1992 between 7.13 pm and 7.34 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. One master tape cassette was used, I identify this master cassette as SJB/3.

3. On Sunday, 9th August 1992 between 2.08 pm and 3.36 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Three master tape cassettes were used. I identify these master cassettes as SJB/5, SJB/6 and SJB/7.

During this interview an audio tape cassette was played and at the end of the interview the tape cassette was sealed and signed by me in the presence of SMITH, his solicitor and Detective Superintendent MACLEOD. I identify this tape cassette as SJB/4.

4. On Sunday, 9th August 1992 between 4.15 pm and 6.47 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Five master tape cassettes were used. I identify these master cassettes as SJB/8, SJB/9, SJB10, SJB/11 and SJB/12.

Signed S. Beels D/S Signature witnessed by

No. 991C

Witness Statement Page 139

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Stephen John BEELS

5. On Sunday, 9th August 1992 between 9.12 pm and 9.21 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. One master tape cassette was used. I identify this master cassette as SJB/13.

6. On Monday, 10th August 1992 between 4.57 pm and 5.55 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/14 and SJB/15.

7. On Monday, 10th August 1992 between 8.19 pm and 9.16 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/16 and SJB/17.

8. On Monday, 10th August 1992 between 9.52 pm and 10.08 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. One master tape cassette was used. I identify this master cassette as SJB/18.

Signed S. Beels D/S Signature witnessed by

No. 991C

Witness Statement Page 140

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Stephen John BEELS

9. On Tuesday, 11th August 1992 between 10.20 am and 10.23 am an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. One master tape cassette was used. I identify this master cassette as SJB/19.

10. On Tuesday, 11th August 1992 between 10.26 am and 11.24 am an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/20 and SJB/21.

11. On Tuesday, 11th August 1992 between 12.21 pm and 12.58 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/28 and SJB/29.

During this interview a series of five photographs were shown to SMITH and these were sealed in exhibit bags and signed by me in his presence. I identify these photographs, in order shown, as SJB/22, SJB/23, SJB/24, SJB/25 and SJB/26.

Signed S. Beels D/S Signature witnessed by

No. 991C

Witness Statement Page 141

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Stephen John BEELS

12. On Tuesday, 11 August 1992 between 2.56 pm and 3.47 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Constable Jonathan SAY and myself. Two master tape cassettes were used. I identify these master cassettes as SJB/30 and SJB/31.

13. On Tuesday, 11th August 1992 between 5.27 pm and 6.33 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Four master tape cassettes were used. I identify these master cassettes as SJB/32, SJB/33, SJB/34 and SJB/35.

During this interview at about 5.58 pm the recording machine stopped, approximately one minute after a change of tapes. The two tapes were removed from the machine and, in order to preserve their integrity, were placed in an exhibits bag and sealed in front of all present. The seal was signed by Richard JEFFRIES and myself.

14. On Tuesday, 11th August 1992 between 8.23 pm and 9.50 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. Three master tape cassettes were used. I identify these master cassettes as SJB/36, SJB/37 and SJB/38.

Signed S. Beels D/S Signature witnessed by

No. 991C

Witness Statement Page 142

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF Stephen John BEELS

15 On Tuesday, 11th August 1992 between 10.20 pm and 10.48 pm an interview took place which was tape recorded. Present throughout the interview were Michael SMITH, Richard JEFFERIES (Solicitor), Detective Superintendent MACLEOD and myself. One master tape cassette was used. I identify this master tape as SJB/39.

On Tuesday, 11th August 1992 I was present in the custody suite of Paddington Green Police Station when, at 11.24 pm, Michael SMITH was charged with offences against the Official Secrets Act, 1911, the charges were read over to him and he was cautioned by the Custody Officer. SMITH made no reply.

Signed S. Beels D/S Signature witnessed by

No. 991C

Witness Statement Page 143

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Jonathan Peter SAY

Age of Witness (date of birth) Over 21

Occupation of Witness Detective Constable 03/172857 (SO12)

Dated 14 October 1992

On Tuesday 11th August 1992 I was at Paddington Green Police Station involved in the investigation into suspected offences against the Official Secrets Act 1911.

Between 2.56 pm and 3.47 pm I was present at an interview which took place in interview room number two of the Secure Unit of Paddington Green Police Station. The interview was tape recorded. Present throughout the interview were Michael John SMITH, Richard JEFFERIES, (solicitor representing SMITH, from ‘Tuckers’ solicitors), Detective Sergeant BEELS and myself. Two master tape cassettes were used. Each master tape cassette was sealed in the presence of SMITH and signed by him.

Signed Jonathan Say DC Signature witnessed by

No. 991A

Witness Statement Page 144

Form MG 11(T)

STATEMENT OF Jonathan Peter SAY

Age if under 21 Over 21

Dated 6 November 1992

This statement, (consisting of 15 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

Following the arrest of Michael John SMITH on 8th August 1992, I have examined financial documents found at his home, 48A Burton Road, Kingston-upon-Thames, Surrey and report here my findings and conclusions as to his financial dealings.

Michael John SMITH is the owner and is resident at 48A Burton Road, Kingston-upon-Thames, Surrey, KT2 5TF, a first floor maisonette consisting of one hallway, one lounge, one bedroom, one bathroom/toilet and one kitchen. The mortgage on the property is of the endowment type and is held by the Abbey National Building Society (account no. KT 20989) in the names of Mr M.J. and Mrs P.A.SMITH. It was taken out on 31st August 1979 for the amount of £17,081.00. The current monthly repayment is £114.22. This is paid out of the National Westminster Joint account. There does not appear to have been any cash payments to the Abbey National mortgage account. Between 02.12.85 and 31.07.92, when his employment was terminated, SMITH has been paid a salary by GEC Marconi Ltd. In April 1989 his salary was increased to £15,325.00 and in April 1990 to £16,700.00. In April

Signed J Say Signature witnessed by

Witness Statement Page 145

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

1991 his annual salary was raised to £18,200.00 and remained at this level until his redundancy (Exhibits PMS/34, PMS/32, RH/33, PMS/10). SMITH has contracted out of the state earnings related pension plan and currently has a personal pension plan no. ********** with Standard Life Assurance Company, PO Box No. 4, 23 Annandale Street, Edinburgh, EH7 4BP. This plan does not require payments from the holder other than his normal National Insurance contributions. A percentage of these are transferred by the Department of Social Security in an annual payment to the Assurance Company. A payment of £1002.08 was received for the tax year ending April 1992 and has been invested with the ‘pension with profits’ fund. No total value of the fund has been found for 1992, however the total value of units at 1st September 1991 was £3391.63 (Exhibits PMS/32, PMS/34, RH/33). Neither SMITH nor his wife have any County Court judgements recorded against them. SMITH has the following bank accounts. Two at the National Westminster Bank, Feltham Branch (a current account no. ********, and a joint account no. ******** with his wife Pamela). He has a savings account no. X3997760 at the Abbey National Building Society, 59 Eden Street, Kingston-upon-Thames. He is also the holder of a National Westminster Access card no. 5224 0061 2943 4243. Authority to apply for Production Orders was granted by Superintendent M. MacLeod on 09.08.92. On the same day Notices of Application were sent by fax to:

a) The Manager, National Westminster Bank Plc,

48, The Centre, Feltham, Middlesex.

Signed J Say Signature witnessed by

Witness Statement Page 146

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

b) The Secretary, Abbey National Plc,

21 Prescot Street, London, El.

c) The Fraud Manager,

National Westminster Bank Access

Premier House, Victoria Avenue,

Southend on Sea.

At 11.00 on Tuesday 11.08.92, at the Central Criminal Court, the Orders were granted, uncontested, in chambers by Judge Michael Coombe. Copies of these applications and orders I produce as Exhibit JPS/9. An examination of his current account no. ******** reveals it to be an extremely well run account £1,677.45 in credit on 11th August 1992. The credit turnover in the 6 months to June 1992 was £6,719.00. The credit turnover for 1991, 1990 and 1989 is as follows:

1991 £13,105.20

1990 £12,995.67

1989 £13,178.06

There have been only two deposits into the current account in 1992 other than his regular payments from GEC Marconi Research. These were a deposit of £5.41 on 18.03.92 and a deposit of £200 on 20.03.92. Enquiries reveal this latest transaction to be a cash deposit of the following notes: two by £50, four by £20, and two by £10. In 1991 there was only one deposit into the

Signed J Say Signature witnessed by

Witness Statement Page 147

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

account other than his wages. This was for the sum of £300 on 04.01.91 and was a cheque drawn on Norweb Plc. In 1990 there were six deposits, totalling £527.59, other than wage credits. These were as follows:

09.01.90 £45.23

05.03.90 £15.16

19.03.90 £50.00

20.04.90 £55.00

11.07.90 £12.20

17.10.90 £350.00 (cheque drawn on Abbey National Plc)

The current account pays five regular standing orders as follows:

Amount

Payable to

Direct Debit/ Standing Order

£160.00

£26.00

£25.00

£ 23.20

Joint account

Institute of Quality Assurance

AB Trust Management

Royal Bank of Scotland

Royal Borough of Kingston

Monthly Standing Order

Annual Standing Order

Monthly Standing Order

Monthly Direct Debit

Signed J Say Signature witnessed by

Witness Statement Page 148

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

The £25.00 per month payment to ABTRUST Management refers to a savings plan managed by Abtrust Unit Trust Managers Ltd of 99, Charterhouse Street, London, EC1M 6AB. The chosen plan is Abtrust Far East Emerging Economies Fund: FEEE 297. A statement dated March 1992 shows a February 1992 total of 1895.35 units held including reinvested dividend (Exhibits PMS/32, RH/33). The £25.00 per month payment to the Royal Bank of Scotland refers to a regular savings plan with Save and Prosper Securities Ltd, Sovereign House, 16-22 Western Road, Romford. The chosen fund is The Save and Prosper European Smaller Companies Fund (Exhibits PMS/32, RH/33). The handling of the account follows a regular pattern. The salary cheque goes into the account and the account gradually dwindles through cheques issued, and standing orders paid, to a small balance. Excess amounts at the end of the pay period are transferred by cheque to the Abbey National Savings account. A noticeable feature of the account is the lack of recent cash withdrawals. None of the cheque stubs (dating back to the beginning of 1990} show any cheques made out to “self” or “cash”. No cash withdrawals have been made via Automatic Till Machines (A.T.M.) from this account in 1992. In 1991 there were 16 withdrawals from A.T.M.s totalling £820.00. These occurred only in the first half of the year ending on 12th August 1991 after which no cash withdrawals appear to have been made. However, in 1990 the A.T.M.s were used fairly regularly throughout the year (Exhibits PMS/10, SC/1). In 1990 there were regular cheques to Sainsbury’s (20) and Savacentre (5) grocers from SMITH’S current account. No cheques were issued to these

Signed J Say Signature witnessed by

Witness Statement Page 149

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

concerns from this account in 1991 or 1992. Joint account no. ******** currently holds £953.73. Four regular payments are made from the account as follows:

Amount

Payable to

Standing Order/ Direct Debit

£114.22

£12.50

£30.36

£13.69

Abbey National B.S.

Hickman and Bishop

Legal and General

Thames Water

Monthly Standing Order

Annual Payment

Monthly Direct Debit

The account is paid £160.00 by monthly transfer from the account of Michael John SMITH and £130.00 by monthly transfer from the account of Pamela Avril SMITH. These deposits, with the exception of two cheques, one for £5.41 and one for £2.93 on the 18th and 25th March respectively comprise the total input into the account in 1992. In 1991 these transfer payments were the only deposits into the account. The highest balance of the joint account in 1992 was £1,048.10 and in 1991 £826.78. The lowest balance in 1992 was £707.78 and in 1991 £329.11. Cheques are issued from the account fairly infrequently and mainly for small amounts. The highest value cheque in 1992 being £226.34 and in 1991 £180.32. The Abbey National Savings account no. X3997760 SMI currently holds £8406.54. It was opened on 22.03.91 with

Signed J Say Signature witnessed by

Witness Statement Page 150

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

£1566.26 which was the closing balance of a previous account number X2066509 SMI. Since account no. X3997760 was opened on 22.3.91 cheques to the amount of £6,142.56 have been paid into the account mostly transferring money from his National Westminster current account. Cash deposits have also been paid in. These cash deposits cannot be accounted for as withdrawals from his National Westminster Current or Joint account. Nor have they been withdrawn from his Access account. These payments are as follows:

19.02.91 £200.00

21.03.91 £300.00

18.05.91 £200.00

07.06.91 £200.00

08.06.91 £50.00

03.08.91 £100.00

17.08.91 £200.00

28.09.91 £300.00

26.10.91 £50.00

07.12.91 £100.00

18.12.91 £150.00

08.06.92 £75.00

TOTAL £1925.00

Signed J Say Signature witnessed by

Witness Statement Page 151

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

The previous account, number X2066509, was opened on 28.11.88 with £2050.68 (which is the closing balance of a previous account no. R5194231 SMI which had been in existence since at least 1985 with a balance of about £2000.00). Small credits of between £100 and £700 paid in by cheque took the balance to £3950.68 on 21.06.89. On 02.07.89 two tranches of Abbey National shares were purchased at a cost of £1007.50 each which took the balance to £1935.68. On 19.02.91 cash (£200) is deposited in the account for the first time. This was followed by a cash deposit of £300 on 21.03.91 which was just before that account was closed and reopened on the same day as X3997760. Michael SMITH has a National Westminster Bank Access Card no. 5224 0061 2943 4243. The credit limit is fixed at £1300. His average expenditure on the card for the first six months of 1992 was £131.00 and his balance owing varied from a high of £525.77 in February to a low of £40.00 in June. In 1991 his average monthly expenditure was £323.00 and his balance owing varied from a high of £1415 in February to a low of £32.32 in November. The vast majority of the transactions refer to the purchase of publications, with hi-fi and sundry purchases also recorded. All payments to Access for 1991 and 1992 have been made by cheque from his current account. The following shareholdings have been revealed in documents, Exhibits PMS/32, RH/33:

Signed J Say Signature witnessed by

Witness Statement Page 152

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

Company

Holding

Certificate No.

Registrar

British

Telecom PLC

Tarmac PLC

East Midlands

Elec

Scottish

Power PLC

Eastern

Electricity

Seeboard PLC

340 part paid

400

100 part paid

160 part paid

100 part paid

Z0175314

708807

Z0732607

10145681

0434375

Z0881301

Lloyds Bank Plc,

BN99 6DA

Nat West Bank,

BS99 7NH

Lloyds Bank Plc,

B30 3ER

Bank of Scotland

EH7 4AL

Nat West Bank,

BS99 7ZF

Lloyds Bank Plc,

BN12 6DA

Signed J Say Signature witnessed by

Witness Statement Page 153

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

London

Electricity

Southern

Electricity

Yorkshire

Electricity

Midlands

Electricity

Scottish

Hydro

Powergen

National

Power

100 part paid

90 part paid

114

186

Z0917554

Z0758734

3223045

2257041

105995

0419767

Z0633860

Lloyds Bank Plc,

B30 3ER

Lloyds Bank Plc,

B30 3ER

Nat West Bank,

BS99 7ZF

Nat West Bank,

BS99 7ZF

Royal Bank of Scotland

EH11 4BR

Nat West Bank,

BS99 7ZG

Lloyds Bank Plc,

B30 3ER

Signed J Say Signature witnessed by

Witness Statement Page 154

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

The following receipts have been recovered in Michael SMITH’s property. They cannot be accounted for by cash withdrawals from his National Westminster accounts nor by cheques from either account. They have not been paid for from the Access account, although a cash withdrawal of £900.00 was made from the Abbey National account on 3rd February 1990 which may relate to the first entry on the following list.

Date

Amount

Exhibit

Receipt for cash

(16 x £50)

Receipt for cash

Visionworld Ltd

Receipt for cash

Visionworld Ltd

Receipt for cash

balance, ABC Music

(main payment of

above not accounted

for elsewhere)

03.02.90

19.10.90

23.11.90

24.11.90

£770.00

£290.00

£385.00

£189.00

£720.00

SC3

Signed J Say Signature witnessed by

Witness Statement Page 155

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

Receipt for cash

London Guitar Studios

Receipt for cash

The Synthesizer Company

Receipt for cash

The Synthesizer Company

Receipt for cash

Project Music

Receipt for cash

Bentalls

Receipt for cash

John Lewis, Kingston

Receipt for cash

(2 x £50)

Soho Soundhouse

Receipt for cash

ABC Music

13.12.90

05.02.91

26.02.92

09.03.91

16.03.91

06.04.91

13.04.91

11.05.91

£1795.00

£4800.00

£138.00

£180.00

£199.00

£145.00

£79.00

£145.00

PMS32

RRl

SC3

PMS32

RH33

SC3

Signed J Say Signature witnessed by

Witness Statement Page 156

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

Receipt for cash

Callhaven

Receipt

SYCO

Receipt for cash

Project Music

Receipt for cash

Riverside Hi-Fi

Receipt for cash

Seeboard

Receipt

Unilet Products

Receipt

SYCO

Receipt

Wembley Commercial

Centre

Receipt

Project Music Store

03.07.91

19.07.91

27.07.91

05.10.91

30.11.91

06.02.92

18.02.92

07.04.92

11.04.92

£58.75

£351.33

£459.00

£210.00

£119.99

£93.00

£581.63

£240.00

£45.00

PMS32

SC3

PMS32

RH33

SC3

PMS32

RH33

Signed J Say Signature witnessed by

Witness Statement Page 157

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

Receipt

Wembley Commercial

Centre

27.07.92

£150.00

PMS32

RH33

TOTAL

£12,143.70

Michael SMITH has been the registered owner of a 1981 Datsun Cherry 3 door saloon registration mark KJH 249W since 14.05.83. The August 1992 Glass’s Car Price Guide does not go back as far as 1981, but shows a 1983 model with average mileage to be worth between £400.00 (trade price) and £1000.00 (in good condition). His wife has been the registered owner of a December 1986 Peugeot 305 5 door saloon registration mark D514 BLD since 09.08.89. The August 1992 Glass’s Car Price Guide shows this to be valued at between £1850.00 (trade price on a 1986 “C” plate) to £3275.00 (a good condition 1987 “D” plate). £2000.00 in £50.00 notes was found at SMITH’s home address (Exhibits PMS/24 and PMS/25). This money is not accounted for by cash withdrawals from any of the known bank accounts. Enquiries reveal that none of the notes in this collection were issued from the Bank of England prior to 06.06.90. The total of hidden income identified in this report is £16,018.70 composed as follows:

Signed J Say Signature witnessed by

Witness Statement Page 158

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Jonathan Peter SAY

Cash found and seized at SMITH’s address

Unaccounted for deposits at Abbey National

Unaccounted for cash receipts

£2,000.00

£1,875.00

£12,143.70

The lack of cash withdrawals after the middle of August 1991 coupled with the ceasing of cheques made payable to food retailers suggests access to other cash resources.

I produce a chart of SMITH’s financial transactions, Exhibit JPS/10, and a chart of the credits, debits and balances of SMITH’s bank accounts, and cash purchases, between 1st January 1990 and 11th August 1992, Exhibit JPS/11.

Signed J Say Signature witnessed by

Witness Statement Page 159

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Kevin John HALL

Age of Witness (date of birth) Over 21

Occupation of Witness Retail Branch Manager

Dated 6 October 1992

I am employed as the Branch Manager for W.H. Smith Ltd at Unit 14, St. Anns shopping centre, Harrow, Middx and have been employed as such since November 1989. On checking my stock record for an American magazine called ‘Keyboard’ for the month of August, 1992, during week ending 11th July 1992, we had fourteen copies delivered. On the 22nd August 1992, we had four copies of this magazine remaining unsold. This would show that it is highly probable that there were copies of ‘Keyboard’ on display at this store on the 6th August 1992. Normally with this quantity they would all be placed on display, however occasionally if the shelves are crowded a limited quantity would be placed in the stockroom. If this is the case the magazines are regularly replenished by the sales staff. It is normal practice if a customer requests a magazine that is not on display. Staff will check the stockroom for reserve stock. This stock record which I referred to earlier in my statement I have handed to DS Hudson and produce it as exhibit KJH/1.

Signed Kevin J. Hall Signature witnessed by Roseline M. Hudson D/S

No. 991A

Witness Statement Page 160

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Arthur Stephen TRIMBEE

Age of Witness (date of birth) 28 January 1936

Occupation of Witness Assistant Director MOD Security/5

Dated 25 August 1992

I have been the assistant Director of Ministry of Defence Security, with responsibility for security in industry for nearly two years. This involves direct liaison with British companies involved with Defence contracts including those which concern classified material. I am responsible for ensuring that companies which handle classified material apply appropriate safeguards to protect it. Today I met with Detective Chief Inspector GRAY and Detective Inspector MORRISSEY who told me they were conducting an Official Secrets Act investigation, which involves GEC/HIRST RESEARCH CENTRE, East Lane, Wembley, Middlesex. I can say that the GEC/HIRST RESEARCH CENTRE at East Lane, Wembley, Middlesex is a ‘prohibited place’ under the provisions of Section 3(b) Official Secrets Act 1911, as amended by the Official Secrets Act 1920, and has been designated as such since before 1977. It is so designated because it receives and holds classified material for the purpose of fulfilling Ministry of Defence contracts. These contracts cover a range of military equipment including the Rapier Missile System.

Signed A. S. Trimbee Signature witnessed by M Morrissey DI

No. 991A

Witness Statement Page 161

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF John Michael CAMP

Age of Witness (date of birth) 9 December 1931

Occupation of Witness Security Executive, Thorn EMI

Address and Telephone Number Blyth Road, Hayes, Middlesex UB3 1DL

081 573 3888

Dated 20 August 1992

On Thursday 20th August 1992, at THORN EMI premises in Blyth Road, Hayes, I handed to Det. Sgt. P Smith an original Official Secrets Acts declaration signed M J Smith on 28th July 1976. The further declaration was signed by M J Smith on 28th April 1978. This document was removed from security files held in my office under my direct control. I exhibit this document as Exhibit JC1.

Signed J. M. Camp Signature witnessed by P. Smith DS

No. 991A

Witness Statement Page 162

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Ernest George Stephen LEY

Age of Witness (date of birth) 28 January 1936

Occupation of Witness Group Security Manager, TEE

Dated 6 August 1992

I am the group security manager for THORN EMI Electronics. I am responsible for maintaining a database of employees, past and present. From the information held on this database I can confirm that Mr Michael John SMITH, born in London on 22.9.48, payroll number M97422 commenced employment on 26.7.76. He ceased employment with the company on 30.9.85. I can also say that on 28.7.76 he signed the certificate under the Official Secrets Act acknowledging that he was briefed and bound under the terms of that Act. From this record I can also say that on 2.6.76 the company received approval to allow him access to Government classified information up to “SECRET”.

Signed E. G. S. Ley Signature witnessed by M Morrissey DI

No. 991A

Witness Statement Page 163

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF John Stewart McMICHAEL

Age of Witness (date of birth) Over 21

Occupation of Witness Retired

Dated 21 October 1992

Between October 1966 and February 1989, I was employed at EMI Electronics, latterly Thorn EMI, at Hayes, as Manager, Defence Security Department for the whole of the company. I was responsible for all aspects of defence security in relation to the company. I have been shown Exhibit JMC/2, which is described as one (1) company security document in the name of Michael SMITH. I recognise it as a Security Department Personnel file of the type kept personally by me. It relates to Michael John SMITH, born 22/948. I have studied the file and can say that the items of correspondence held in it are those that were held by me. The file includes correspondence between myself and the Ministry of Defence (MOD), Security Service and EMI Feltham. I recall Michael John SMITH, because there was a problem with his security vetting which was withdrawn by the MOD. At EMI Feltham SMITH was a Quality Assurance Engineer, engaged on project XN715. Contained in the file is a transcript of an interview of Michael SMITH with myself, which took place in my office on Monday, 12th November, 1979. I taped the interview covertly because I expected it to be a lengthy interview and I can say that the transcript, contained in Exhibit JMC/2, is a true and accurate record of that interview. The cassette tape was later destroyed. The Interview was carried out at the request of the MOD (SY5) as his security clearance had been withdrawn and he

Signed John McMichael Signature witnessed by Christine Robson DC

No. 991A

Witness Statement Page 164

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

CONTINUATION OF STATEMENT OF John Stewart McMICHAEL

had been seeking an interview with the head of security. In summary, my impression of SMITH is that he was being evasive, not answering questions directly and was unable to remember surnames of certain persons. I remember that when I informed him that if he went to the MOD for an interview he would be asked questions of a similar nature as if he were being positively vetted. His reaction indicated to me that he was concerned at having to face those sort of questions in an official capacity. He went quiet and went physically pale. He contacted me several times after this interview trying to find out what was happening re his security status. He also tried to ingratiate himself with the MOD by reporting a lack of security at Feltham. He was certainly very persistent. I would be willing to attend court and give evidence if necessary. I have read through this statement and would like to add that the idea to tape record SMITH’s interview was entirely my own, it was not normal practise.

Signed John McMichael Signature witnessed by Christine Robson DC

No. 991C

Witness Statement Page 165

Form MG 11(T)

STATEMENT OF Frank TAYLOR

Age if under 21 Over 21

Dated 23 November 1992

I was employed as a Deputy Director Security Ministry of Defence, Procurement Executive, from 14th January 1975 until my retirement on 18th September 1981. I was responsible for vetting of personnel whose cases were referred to M.O.D. (PE) as contracting department. I have today been shown exhibit MR/20, a quantity of correspondence. I note in particular on M.O.D. (PE) headed letter to M J SMITH esq, dated 25th January 1980. I identify the signature on that letter as being my own. The letter refers to a request for an interview and an enclosed Security Questionnaire. I also note that the quantity of correspondence contains a Security Questionnaire, form E93A, in the name of Michael John SMITH and dated 6th February 1980. I vaguely recall the last page of handwritten notes. I see at section 11 of the form, at subsection (a) in reply to the question, “Have you ever been a member of or in sympathy with any Communist, Trotskyist or Fascist organisation in the United Kingdom or elsewhere?” the reply is “No”. I also see that in subsection (b), in reply to the question, “Have you ever had any connection with any group or movement associated, or in sympathy, with a Communist, Trotskyist, or Fascist organisation?”, the answer is “No”. I note that the quantity of correspondence also includes a letter from myself to Mr M J SMITH, dated 30th May 1980. I identify the signature as being my own. The letter refers to arrangements for an interview at Fleetbank House at 10.15 am on Tuesday, 10th June, 1980, where Mr Maloney will be the interviewing officer. From my experience it was unusual to receive a request from an employee of M.O.D. contractors for interview about security clearances. I have some recollection of the circumstances surrounding the case. I vaguely recall setting up

Signed F. Taylor Signature witnessed by S. Beels DS

Witness Statement Page 166

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Frank TAYLOR

the interview between Mr MALONEY and SMITH but was not myself present at it.

I would be willing to attend court and give evidence if required.

Signed F. Taylor Signature witnessed by S. Beels DS

Witness Statement Page 167

Form MG 11(T)

STATEMENT OF Mr ‘D’

Age if under 21 Over 21

Dated 9 December 1992

Between April 1962 and January 1985 I was employed as a member of the Security Service. In 1980 I was working in a section of the Service specifically concerned with individuals who had come to notice in a security context whilst employed with commercial companies undertaking classified government contracts. On 10th June 1980 I interviewed Michael John SMITH at Fleetbank House, 2-6 Salisbury Square, London, EC4, resulting from his request to have his security clearance for his employment at EMI reinstated. I introduced myself as Mr Maloney and the interview lasted for approximately an hour. At the outset of the interview I presented SMITH with a Form E93A that he had completed. This is a security questionnaire. SMITH confirmed that he had both completed and signed it. Today, Detective Sergeant Beels opened a sealed bag marked MR/20 in my presence and showed me a copy of a completed E93A security questionnaire. This appeared to be a copy of the one that was completed by SMITH prior to the interview. During the course of the interview SMITH initially claimed that he had never been a member of the Communist Party of Great Britain or Young Communist League and had never knowingly attended any meetings of these groups or knowingly associated with any members of these groups. He further claimed that he had a general lack of interest in politics apart from “a normal day to day interest in current affairs”. I then put to him that in fact I knew him to have been actively involved in Communist Party activities for a number of years. Thereafter Mr SMITH admitted his involvement with the Communist Party

Signed Mr ‘D’ Signature witnessed by S. Beels DS

Witness Statement Page 168

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mr ‘D’

and Young Communist League since about 1971. He claimed that he had resigned from these groups in late 1975 or 1976 and that his resignation was not prompted by his Joining EMI but rather because of growing disillusionment with the Communist Party and the YCL in general. I made a report of this interview on 17 June 1980. This was prepared from a recording of the interview that I had made at the time without SMITH’s knowledge. I do not recall what happened to this recording. Normal procedure at that time would have been to destroy the tape after a report had been made, but I cannot recall whether in fact this was done. I now produce a copy of the report made by me on that date as Exhibit D/1. My name has been removed from this report.

Signed Mr ‘D’ Signature witnessed by S. Beels DS

Witness Statement Page 169

Form MG 11(T)

STATEMENT OF Edgar George HILL

Age if under 21 Over 21

Dated 18 November 1992

I was employed with the Ministry of Defence between 1947 and July 1987. I was Director of Security for the MOD Procurement Executive between September 1977 and September 1982. As Director of Security (PE) I was responsible for security within the Procurement Executive, certain Defence Research establishments and list x firms.

I have been shown Exhibit MR/20, which consists of a quantity of correspondence. I note in particular a letter dated 30th June 1980 from myself to Mr M.J. Smith Esq. I identify the signature as being my own. I recall certain aspects of this case, in particular Mr Smith being interviewed at Fleetbank House (which was unusual), and the decision to withdraw his security clearance. I note, especially in paragraph two, that I have written “we note in particular your admission that you had in fact been a member of the Young Communists League between 1971 and 1976, and that you had denied such membership both in your answers to the security questionnaire and also in the early part of your interview.”

I would be willing to attend court and give evidence if necessary.

Signed E. G. Hill Signature witnessed by Christine Robson DC

Witness Statement Page 170

Form MG 11(T)

STATEMENT OF Jeffrey SINGLETON

Age if under 21 Over 21

Dated 2 December 1992

I am exhibits officer in. the case of R v Smith and have been employed in this role since 8th August 1992. I have been asked to explain why only part of the contents of exhibit SR4, a quantity of correspondence and components, were split to exhibit J.S.14 to J.S.38 inclusive and examined by people judged competent to explain their significance while the remaining part of SR4 was left unexamined. On 9th August 1992 I received exhibit SR4 at Paddington Green Police Station along with a large number of other exhibits. All these exhibits had to be booked in and then initially examined to assess their worth to the investigation. Exhibit SR4 was opened during the evening of 9th August at Paddington Green Police Station by myself and the contents systematically copied and resealed and given other exhibit numbers viz J.S.14 to 38 inclusive. Whilst this process was being carried out copies of the documents above were examined and other investigating officers judged that they may be significant to the investigation although they were not competent or qualified to assess their true worth. With expedience of the investigation an issue people judged competent to explain the documents already examined were contacted and an appointment made to show such documents to them. By the time it became necessary for Detective Chief Inspector GRAY and Detective Inspector NICOLSON to leave for this appointment only documents, exhibits J.S.14 to J.S.38 inclusive had been examined and these were handed to Detective Inspector NICOLSON for initial assessment by competent examiners. The remaining documents were resealed, left unexamined as SR4 for assessment at a later date.

Signed J. Singleton Signature witnessed by

Witness Statement Page 171

Form MG 11(T)

STATEMENT OF Martin MORRISSEY

Age if under 21 Over 21

Dated 1 December 1992

On Thursday 17th September 1992 I visited the area of Harrow-on-the-Hill, Middlesex. Whilst there I directed Detective Sergeant Phillip ATKINSON to photograph those places that Michael John SMITH had indicated, in interviews with Detective Chief Superintendent Malcolm MACLEOD, that he had visited on Thursday 6th August 1992. Certain of these photographs are exhibited under reference PA/1 by Detective Sergeant ATKINSON. The remainder are exhibited under reference PA/5 by Detective Sergeant ATKINSON. It is by reference to these photographs and my own observations of Harrow-on-the-Hill that this statement is made. Photographs 3, 4, 5, 6, 7, 8, 10, 11, 12 and 13 are views along PETERBOROUGH ROAD, from KENTON ROAD, up the hill towards the HIGH STREET, Harrow-on-the-Hill. Photographs numbered 14, 15 and 16 are views in the opposite direction, down PETERBOROUGH ROAD towards Harrow. Photographs numbered 17 and 19 show the view towards CHURCH HILL and photographs 20, 21 and 22 show the Junction of PETERBOROUGH ROAD, CHURCH HILL and HIGH STREET. Photograph number 24 is a water hydrant which is in PETERBOROUGH ROAD on the west footway some three feet from the junction with CHURCH HILL. Photograph number 26 is a view down CHURCH HILL from the entrance to St Mary’s church which sits on the top of Harrow-on-the-Hill. Photographs number 28 and 29 are of the lych gate at the entrance to St Mary’s Church. Photographs 30 and 31 show the church’s main door. The photograph numbered 32 shows the two benches which are situated on a viewing platform which is at the far side of the church if one entered by the lych gate (photographs 28 and 29). Photograph 33 shows one of the two paths on that side of the church. This one leads to

Signed M. Morrissey DI Signature witnessed by

Witness Statement Page 172

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Martin MORRISSEY

ROXBOROUGH PARK to the north west of Harrow-on-the-Hill. Photograph number 34 shows a third bench which is to the left of those in photograph 32 as one views the photograph. Finally photograph 35 shows the second path down to the west of the church, this leads to BESSBOROUGH ROAD.

Signed M. Morrissey DI Signature witnessed by

Witness Statement Page 173

Form MG 11(T)

STATEMENT OF Martin MORRISSEY

Age if under 21 Over 21

Dated 8 January 1993

Further to my last statement of 1st. December 1992, I have read the notes which were recovered from Michael John SMITH’s house and exhibited under references JS/4l, JS/42, JS/43 and JS/44. As far as I am able to discern the content of these notes, I have transcribed them into a typewritten form. I produce these four typewritten copies of the originals as exhibits MSM/2, a transcription of JS/4l, MSM/3 a transcription of JS/42, MSM/4 a transcription of JS/43 and MSM/5 a transcription of JS/44.

Signed M. Morrissey DI Signature witnessed by

Witness Statement Page 174

Form MG 11(T)

STATEMENT OF Philip ATKINSON

Age if under 21 Over 21

Dated 26 November 1992

On Thursday 17th September 1992 in company with Detective Inspector MORRISSEY, I visited the vicinity of Harrow-on-the-Hill, Middlesex. In my statement of 6th November I produced a number of photographs which I took on this day as exhibit PA/l. I now produce the remainder of the photographs which I took of this area on the 17 September 1992 as exhibit PA/5. The unretouched negatives are retained in my possession.

Signed P. Atkinson DS Signature witnessed by

Witness Statement Page 174A

Form MG 11(T)

STATEMENT OF Philip ATKINSON (Det Sgt. 158766)

Age if under 21 Over 21

Dated 6 November 1992

On Thursday 22nd September 1992, together with Security Officer Mrs ‘C’ I travelled to Oporto in Northern Portugal. There, in the vicinity of a camp site and in various parts of that town, I took a quantity of photographs, PA/2 refers.

Signed P. Atkinson DS Signature witnessed by

Witness Statement Page 175

Form MG 11(T)

STATEMENT OF Oleg GORDIEVSKY

Age if under 21 Over 21

Dated 10 December 1992

From 1962 until 1985 I was an officer in the KGB, The Committee of State Security for the USSR. This is a security and intelligence organisation, since December 1991 renamed the SVR, the Service of External Intelligence and MB, the Ministry of Security. For the first nine years, until 1972, I was a member of Directorate ‘S’ of the First Chief Directorate which was responsible for the training and organisation of KGB officers who operated abroad under false foreign identities, these people are known as “illegals”. As a result I became thoroughly familiar with, and indeed was involved in the development of, tradecraft and secret communications including the use of clandestine meetings, visual signals and dead letter boxes. I finished my KGB career in 1985 as head of KGB operations in London. From 1976 I had been working secretly for the British Intelligence Services. In 1985 my role was discovered by the KGB but I managed to escape from Moscow to Britain. Since 1985 I have maintained my expertise in intelligence matters, studied large quantities of material from the former Soviet Union relating to intelligence matters and been the co-author of three books on intelligence matters. I would say that I have good current knowledge of the SVR and MB organisations because I keep myself well informed through the information which is now leaking from the former Soviet Union, and since the individuals in the two organisations are very much the same as in the KGB and use the same tradecraft techniques. Today Detective Inspector MORRISSEY has shown me some photocopies of an envelope and five pieces of paper.

First, I have looked at the envelope RH/22 and it immediately strikes me that this was written by a Russian. The unsteadiness of the writing is a familiar sign

Signed O. Gordievsky Signature witnessed by Martin Morrissey DI

Witness Statement Page 176

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Oleg Gordievsky

when they acquire the ability to write in Latin script usually in their late twenties. Also I notice that the letters ‘n’ and ‘r’, but particularly ‘n’ are written in capital letters where the rest is in small letters this results from the method they are taught where they copy the letters from examples in different books and so on, coupled with the difficulty in changing from Cyrillic to Latin script. They often get confused between capital and small letters.

Now to the letter marked JS/40. This type of letter is familiar to me. It is typical of a summons to an agent for a clandestine meeting, usually after an accidental break in communications with an agent. It is deprived of any specific details like a date, time and place of the meeting because the agent and KGB officer know from previous agreement what they are. Secondly, tradecraft doesn’t permit one to reveal vital details in case the note was intercepted or lost. Also the writing and the wording reminds me very much of the way Russian officers would do it.

The note JS/41. I find this very interesting and striking. It looks very much like a note made by an agent listening to the instructions of his case officer. On the fourth line down he makes a note about the signalisation, as it is called in the KGB, to be used in the course of clandestine meetings. A vertical line is a signal of danger, which means the agent must take special measures because either he or the officer may be under hostile observation. The horizontal line with the words “come next day” means that today’s clandestine meeting for some reason cannot take place and for some reason is being postponed to the next day, usually the same time and the same place. Those two visual signals are the most usual ones used by the KGB in the communication both with the agents and the above mentioned “illegals”. Practically speaking today only the SVR and the GRU (Russian Military Intelligence Service) would use these signals in intelligence operations. These signals are put by chalk or marker pen on a lamp post or gate post or telephone wiring box or something like that, so that they can easily be seen by the agent, even while driving in a car past the site. The last two lines are very typical for the KGB clandestine communication agreements. For me, the first words mean the date and place of the next meeting and the following words mean if it will not be possible to carry out the meeting, then to carry it out at the same place and time the next week.

Signed O. Gordievsky Signature witnessed by Martin Morrissey DI

Witness Statement Page 177

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Oleg Gordievsky

I have never visited Horsenden Hill, but I know where it is and it is a typically suitable place for KGB clandestine meetings. It is within the 25 mile limit and also not in the centre of London. There are no police stations or similar that would make for a difficult climate for such a meeting. The last line on this note is a very important one, it is a typically traditional KGB arrangement where if the contact between the agent and the case officer is broken, the agent will have to turn up at a previously appointed time and place until contact is re-established. In this case, according to the note, every second and third Wednesday of each month.

The note JS/42 is full of messages for me as a former KGB officer. It looks for me like a note made by a well disciplined agent, listening carefully to the instructions of his case officer, in order not to miss or forget anything. By disciplined, I mean an agent who uncritically receives the instructions of the officer and follows them precisely. From the point of view of the KGB only it’s best agents are disciplined. The first half of the note is the officer explaining the best route to the meeting place. The agent has underlined the word “suggest”" twice which means that the officer emphasised these words so that in effect they are orders and that is why the agent underlines them. The officer gives these orders with an objective in mind and this is usually to control the route taken to the meeting by the agent so that counter-surveillance can be used by the officer and his colleagues from the Russian residency to see if the agent is being followed by the British security authorities. A second reason for arranging a route to the meeting for the agent in advance is so visual signals can be left for him. On the next lines is the ritual reminder of what to do if contact is broken as I have previously explained on the note JS/41. At each meeting the case officer discusses the agent’s professional future with him because the KGB is interested in continuing to enjoy the agent’s access or, better, to improve it or expand it. So, the last two lines may be about the future of the agent, or about the work that the agent has access to, and what will happen to that in the future.

With regard to note marked JS/43 there is a difference between this note and the others, JS/41, JS/42 and JS/44. The signalisation is different, in that colours are indicated

Signed O. Gordievsky Signature witnessed by Martin Morrissey DI

Witness Statement Page 178

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Oleg Gordievsky

and the use of a magazine or newspaper probably as an indicator or a sign of identity. While I feel that the note indicates communication in the intelligence field, qualitatively the difference indicates that this note refers to a different stage in the case officer/agent relationship either before or after the period represented by the other notes.

The note JS/44 I regard as the most interesting, because it looks like a memo where the agent has recorded the most important elements of his conversation with the case officer. On the left side it states “1. get Karl’s Address and telephone number” which is an instruction from the case officer. The KGB uses its agents for “talent spotting”, that is in order to recruit more agents, they ask for people’s details to be obtained by the established agent so that they may be approached by KGB officers. After this at number 2, the agent is trying to draw the object where the case officer is telling him that the signals will be put but it is not clear what the object is. The signals are the same as on JS/41 which are typical elements of KGB signalisation. On the next line is the location Abbotsbury Road/Melbury Road and a coke can at bollard. Since the 1970’s the KGB slowly introduced disposable items, such as empty cigarette boxes, empty cans, orange and banana skins, as signals. They would be left in places where they would be unlikely to be removed too soon. The system of graphic signals and disposable items are often used together. The location Abbotsbury Road/Melbury Road like the rest of the area between Holland Park and Holland Road has been used regularly by the KGB for signal sites, because it was conveniently on the route of KGB officers living in the block of flats in Edith Road on the way to their Embassy in Kensington Palace Gardens. I myself was responsible for reading signals from different “illegals” which they left in this area in the 1980’s. The last two lines are instructions to follow a route and as I have explained before this allows for example counter-surveillance by the case officer, and for signals to be left on the route. On the right hand side is the tasks to be done for the next meeting. I recognise the words biosensors, micron valve and HTSC which I have been told by D.I. MORRISSEY represents high temperature super conductivity, as frequently on the requirements

Signed O. Gordievsky Signature witnessed by Martin Morrissey DI

Witness Statement Page 179

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Oleg Gordievsky

lists of the line-X of the KGB work. Line-X is concerned with illicit acquisition of high technological industrial and scientific secrets, usually important or relevant to the military production. About a third of all KGB officers belong to this line-X branch and their job is the acquisition, usually through agents, of that information. On note JS/44 under the requirements list I see the discussion of the delivery of something substantial, like a bundle of documents or a bulky item. Finally a reminder of the standing arrangements if contact is lost.

I have been asked why an agent would keep such notes, well according to the tradecraft an agent is not supposed to keep incriminating notes but the case officer’s interest is that the agent complies with the instructions he is given and turns up at the meetings and remembers what to do before the next meeting. This interest overrides the consideration of the agent’s security. The case officer is interested in short term success for his own career, allowing the agent to make notes thus jeopardising the long term future of the agent. Throughout this statement “case officer” refers to an officer of the KGB or SVR, which are effectively the same thing, who is responsible for all aspects of the control of the agent which would include meeting him and receiving information from him. The GRU is very similar to the line-X KGB and uses similar tradecraft.

From my experience of 23 years in the KGB I can confidently state that these notes JS/41 to JS/44, were made in response to the instructions of a KGB case officer, or possibly GRU. It was impossible for the person making the notes not to realise he was dealing with an intelligence service, because of the numerous elements of the paraphernalia of espionage which are the signalisation, the directions to follow a specific route, the contact and fall back arrangements, the sophisticated requirements list and the possible evidence of talent spotting.

Signed O. Gordievsky Signature witnessed by Martin Morrissey DI

Witness Statement Page 180

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF D. G. BARLOW

Age of Witness (date of birth) 44 (3 March 1948)

Occupation of Witness Quality Manager

Address and Telephone Number Hirst Research Centre

East Lane, Wembley, Middx. HA9 7PP

Dated 20 August 1992

I have been employed at HRC for eight years. For the last seven years I have headed the QA Department. From Dec. 1985 Michael John SMITH was employed in my department. Throughout this period he usually arrived by car between 8.45 and 9.15 am, and left after 5.15 pm. His normal lunch break was one hour at any time between 12.00 and 2.00 pm. He was not a regular user of the canteen at lunch times and quite often listened to music in his car. If he left the site, by car or on foot, he was obliged to sign an attendance record although there was no check on it. This applied to any absence during the working day.

Signed D. G. Barlow Signature witnessed by A. Walsh DS

No. 991A

Witness Statement Page 181

Form MG 11(T)

STATEMENT OF Mrs C (Stella Rimington)

Age if under 21 Over 21

Dated 9 December 1992

Further to my statement dated the 9th day of November 1992. I have examined JS/45, a street map of Oporto, Portugal with four crosses marked thereon, two of the crosses with adjacent arrows, and read the relevant part of the Defendant’s statement. I visited Oporto in September 1992 and identified the four places marked. Three of the crosses are very specific, that is at a particular point on a particular side of the road. At each of these sites there are bus stops and telephone boxes but nothing of obvious tourist interest. The fourth cross marks a square, Largo de San Joao Novo, where there is a church, a museum, a restaurant and a pub. These locations were photographed and are shown in Exhibit PA2. Having visited these sites it is my opinion that the marked map is typical of the sort of instructions given by Soviet/Russian Intelligence officers to their agents to follow a specific route; in this case passing either telephone boxes where further instructions could be received or bus stops where anti-surveillance measures could be used and ending in a busy tourist place where a meeting or contact could take place which would be difficult for any surveillance to monitor. Instructing agents to follow a particular route is an established tradecraft practice of Soviet/Russian Intelligence officers as stated in my previous statement. It is also established tradecraft practice for Soviet/Russian intelligence officers to arrange meeting with agents in particularly sensitive or important cases, in third countries. For cover reasons this is often combined with a holiday or other reason for travel. Both PRIME and GERHARDT had meetings with their case officers in third countries. Also third countries are sometimes used for training agents in communication or anti-surveillance techniques. I have examined

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 182

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mrs C (Stella Rimington)

JS/66, a street map of Honfleur, France, marked with three crosses, two joined by a line. I visited Honfleur in November 1992 and identified the places marked. Two are hotels and the third a restaurant. The two marking hotels are joined by a line. I was assisted by a member of the Direction de la Surveillance du Territoire (DST) who took photographs. Whilst it is possible that these markings indicate a specific route and meeting places, I do not consider I have sufficient information to draw a firm conclusion that they have an intelligence significance.

Signed Mrs “C” Signature witnessed by Martin Morrissey DI

Witness Statement Page 183

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Philip Raymond BEAUCHAMP

Age of Witness (date of birth) 10 May 1931

Occupation of Witness Retired Quality Manager

Dated 2 September 1992

From 1951 until 1991 I worked at Thorn EMI, Feltham, in the Quality Assurance field, mainly on the weapons projects carried out at the establishment. At about the beginning of the 1970’s I became Chief Quality Engineer. In 1976 I recall Mike SMITH joining the company; I put him onto the XN715 Fuze project as a Test Engineer with expectation that he would become a Quality Engineer. His job involved getting to understand the XN715 system; assisting the engineers in testing the development product; assessing the testability of the product; processing fault data associated with the product. To achieve these requirements he needed full access to XN715 data, comprising drawings, specifications (requirements and test) and physical hardware. He worked on the project for two years until I was asked to arrange his removal from the project on to other work. Today Detective Sergeant SMITH has shown me a number of documents in marked bags: RH/26, RH/17, PMS/23. In respect of these, there is nothing relating to the XN715 project or any other classified weapons related work at EMI Feltham to my knowledge. However, I have been shown a sheet of paper RH/13; I am unable to determine any significance to it.

Signed P. R. Beauchamp Signature witnessed by Paul Smith D/S

No. 991A

Witness Statement Page 184

Statement of Witness (C.J Act, 1967, S.9; M.C. Act, 1980, S.102; M.C. Rules, 1981, r.70)

STATEMENT OF Alan RENNIE

Age of Witness (date of birth) 28 September 1938

Occupation of Witness Senior Scientific Officer, Ministry of Defence

Dated 6 August 1992

I am a senior scientific officer in the Ministry of Defence, and have worked for this Ministry and its predecessors since 1960. I am aware that in about 1975 and 1976 EMI Electronics Limited, now known as THORN EMI Electronics Limited, were commissioned by the Ministry of Defence to develop a production model of a radar fuse for use in the British free fall nuclear bomb WE177. The THORN EMI development code for this fuse is XN715. The production of this fuse ceased in about 1988 but THORN EMIE continue to refurbish the fuses which are still in operational use. This fuse was manufactured solely in the United Kingdom for the exclusive use of British armed forces. The project was and still is, classified “SECRET”, I judge this to be the correct classification. “SECRET” means ‘information and material the unauthorised disclosure of which would cause serious injury to the interests of the nation’. The communication of information regarding this fuse to a foreign agent would be useful to an enemy, could enable them to take counter measures and the interests of the United Kingdom would be prejudiced.

Signed A. Rennie Signature witnessed by M. Morrissey DI

No. 991A

Witness Statement Page 185

Form MG 11(T)

STATEMENT OF Jeffrey SINGLTON

Age of Witness (date of birth) Over 21

Dated 7 May 1993

I am exhibits officer in the case of Regina v Smith and have been employed in such position since 8th August 1992. On 11th August 1992 I opened exhibit RH5 and split part of the contents, maps and an itinerary relating to Oporto, Portugal to become exhibits JS45, JS46 and JS47. These were sealed and labelled as such. The remaining documents were replaced and resealed as exhibit RH5. The exhibit RH5 was split so that those maps which had markings upon them and the itinerary, which may have been pertinent to the timing of any visit by Mr SMITH to Portugal could be examined more easily, and if required be examined by more than one person in different locations. On 24th September 1992 I split exhibit SR13 and removed a map of Honfleur, France which was sealed as exhibit JS66 and labelled as such. The remaining part of the exhibit was replaced and resealed as exhibit SR13- The reason for this split is that the map was required as part of the investigation while the remainder of SR13 was not deemed pertinent to a particular avenue of enquiry and the split allowed for ease and clarity of investigation.

Signed J. Singleton DS Signature witnessed by

Witness Statement Page 186

Form MG 11(T)

STATEMENT OF Mrs C (Stella Rimington)

Age if under 21 Over 21

Dated 10 May 1993

I refer to my previous statements dated 9 November and 9 December 1992. I have been asked to expand on my expertise. I joined the Security Service in October 1969 and for the following five years was a member of the section studying the operational methods and techniques of intelligence services of countries hostile to the U.K. My work involved the study of information gained from defectors and from Security Service investigations and observations of such intelligence officers in the U.K. and worldwide. During this period I took part personally in the debriefing of a number of Soviet defectors. Between 1976 and 1987 I was involved in the research and preparation of a number of Official Secrets Acts prosecutions. From 1987-1990 I was head of Security Service training department and as such involved in the training of Security Service officers in methods to counter the operational techniques of hostile intelligence services. From 1990-1993 I was head of the section of which I was a member when I first joined the Security Service. During this period I was involved in the study and assessment of the effects of the changes in the Soviet Union and the break-up of the Warsaw Pact on the intelligence services of those countries. I have also been asked to expand on the assertion in my statement of 9 November 1992 that the intelligence services of the Russian Federation (RFIS) have inherited most of the resources and assets of the Soviet Intelligence Services following the break-up of the Soviet Union in 1991. Despite the lessening of tension between Russia and the West the RFIS have continued to be active against Western, including British, interests. RFIS officers en poste in the UK and worldwide continue to gather information by clandestine means.

Signed Mrs “C” Signature witnessed by M. Gray DCI

Witness Statement Page 187

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Mrs C (Stella Rimington)

Intelligence gathering is like completing a jigsaw, every piece, while not necessarily of high value in itself, can be of great value in building up the whole picture. This is particularly true in the Science and Technology (S&T) field, where classification of individual pieces of information is not necessarily a true reflection of their worth to an enemy. Sometimes a small, seemingly innocuous piece of information, can be of value in adding to information already received or ongoing research. RFIS remain active also in Europe and North America and information gained in these countries as well as the UK, could be valuable in adding to knowledge of joint UK/US/European research. In these circumstances information of a low classification or even unclassified could prove extremely valuable to those receiving it. I have been asked about the circumstances in which Viktor OSCHENKO arrived in the UK last summer. On 20 July 1992 Viktor OSCHENKO, a colonel in the SVR (formerly KGB), sought asylum at the British Embassy in Paris. He was given leave to enter the UK, which he did on 25 July 1992, when he was granted indefinite leave to remain. Previously OSCHENKO had served in the UK as Third then Second Secretary at the Soviet Embassy from 29 August 1972 to 22 September 1979. During this period Security Service investigations identified OSCHENKO as a member of the KGB.

Signed Mrs “C” Signature witnessed by M. Gray DCI

Witness Statement Page 188

Form MG 11(T)

STATEMENT OF Oleg Gordievsky

Age if under 21 Over 21

Dated 5 May 1993

Further to my statement of the 10th December 1992 I have been asked by Detective Inspector Morrissey to provide some documentary evidence of my previous employment in the KGB, the Committee of State Security of the USSR. I produce my KGB identity card, which is the main and the only document identifying me as a member of the KGB and as a member of the Soviet Union’s armed forces. It was issued to me in the year 1978 in Moscow after my return from my assignment in Denmark. It was issued because in my time in Denmark I had been promoted from the rank of Major to the rank of Lieutenant-Colonel, thus needing a new identity card. Because the officers of the KGB wear plain clothes I had to visit the photo studio of the KGB in Moscow to be photographed in the uniform of a Lieutenant-Colonel for the card. In February 1985 I was promoted to the rank of Colonel but because I was posted at that time in London I was not in a position to get a new identity card before I finished my KGB career in May 1985. The photograph is not on this identity card because when my book “KGB: The Inside Story” was to be published, the publisher wanted to use my identity card as an illustration in the book, and in fact it appears on the dust jacket. At that time, 1990, for reasons of personal security I did not allow my photograph to be seen in public and so the photograph of me in my Lieutenant-Colonel’s uniform was removed from the card. On the inside left hand of the identity card it says: on the ink stamp is the national emblem and the words “Committee of State Security of the USSR”, on the printed KGB emblem the words “KGB of USSR”. In ink my personal number as member of the armed forces: D-895525. In the upper right

Signed O. Gordievsky Signature witnessed by M. Morrissey DI

Witness Statement Page 189

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Oleg Gordievsky

corner the series of the identity card NK-4. A line on the right hand side says “valid until 31st December 1985”. On the right hand side of the card the text says “Committee of State Security of USSR. Identity card NK No. 3406 Lieutenant-Colonel GORDIEVSKY Oleg Antonovich. Holding the office of Senior Assistant of Department Head. The owner of this card is permitted to store and to carry arms. Deputy Chairman of State Security” (signed). On the right hand side is the same emblem as on the left of the card. I produce this card as exhibit OG/1. When I was escaping from Russia in July 1985 I had it with me as a precaution in case I was arrested in the border area. I have also been shown exhibits marked JS/45, JS/46, JS/47 and a series of photographs exhibit PA/2. In the light of my previous statement I have been asked for my opinion on these maps. The marks on the map of Oporto marked JS/45 look to me as if they could have an intelligence purpose. They could have been marks of dead letter boxes, signal sites or agent meeting places. Most likely these places, three of which have a well protected and transparent bus shelter, are perfect meeting places or visual contact places, while the fourth place looks like a cosy and convenient meeting place. Another possibility is that the crosses on the map are marks of the route which a KGB contact is supposed to follow probably stopping for a short period of time at bus-stops before his meeting with a case officer in order to be checked as to whether he is being followed by hostile surveillance. It is the bus-stops that are marked in this small area that lead me to this conclusion. Having said this, that the marks could have an intelligence purpose, I have not sufficient information to be certain that they are.

Signed O. Gordievsky Signature witnessed by M. Morrissey DI

Witness Statement Page 190

Form MG 11(T)

STATEMENT OF Michael Anthony BYRNES

Age if under 21 Over 21

Dated 26 April 1993

On April 23rd 1993 the financial controller of the company which employs me, Jacqueline Beck, asked me, in my capacity of credit controller, to gather all the available paperwork and computer held records on the financial transactions between The Synthesizer Company Limited and Mr Mike Smith of 48A Burton Road, Kingston-Upon-Thames, Surrey. This was, she said, in response to a request from police to obtain a statement from a representative of the company in regard to monies received from Smith and products purchased by him. On Monday, 26th April 1993 DC Richards of New Scotland Yard attended my office and showed me two exhibits marked JS/39 and RR/3, and asked me to explain the difference in prices quoted on JS/39, a preliminary quotation, and RR/3 a handwritten receipt. He also asked me to list all items purchased by Smith from The Synthesizer Company. Exhibit JS/39, described as two pieces of paper, ignoring that headed ‘SYCO Invoice’, is in essence a preliminary quotation prior to the making of a contract, the prices found thereon are all approximate and open to negotiation. All the items listed on the quotation, except that described as ‘CNI RMCD, 44MBHD and CD ROM’ were purchased by Smith under Order number S7253. RR/3, a handwritten receipt, is a document in confirmation of Smith’s payment of £10,062.50 for these and other goods under Order number S7253. The discrepancies between prices quoted and those paid by Smith are a result of haggling between Smith and the representative with whom he dealt. A list of items purchased by Smith on this occasion is held on invoices, copies of which I gave to DC Richards on the 26th April 1993 and which I submit as

Signed M. Byrnes Signature witnessed by R. Richards DC

Witness Statement Page 191

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Michael Anthony BYRNES

exhibit MAB/1. These all relate to Order No. S7253 but two bear different Order numbers being S16847 and S7488. This can be accounted for by our warehouse being out of stock of the products listed at the time of ordering and their having to be recorded under another reference. The invoice total for the goods is £10,062.49, a difference of £0.01 which is a rounding up of the VAT charged on the deal. I was also shown by DC Richards an exhibit marked RR/1, a statement of the account of Mr Mike Smith. This is a true record of his account as relates to Order S7253 but is not a full record of all Smith’s transactions. I produce a full account of Smith’s dealings with The Synthesizer Company as exhibit MAB/2 and include in this exhibit invoices relating to the balance of his dealings with my company outside those dealt with in exhibit MAB/1. I am willing to attend Court as a witness if necessary.

Signed M. Byrnes Signature witnessed by R. Richards DC

Witness Statement Page 192

Form MG 11(T)

STATEMENT OF Michael Anthony BYRNES

Age if under 21 Over 21

Dated 27 April 1993

Further to my statement dated 26th April 1993, DC Richards re-attended my office on 27th April 1993 at 10.30. DC Richards packaged and sealed exhibits MAB/1 and MAB/2 in my presence and I signed the labels affixed to both. MAB/1 I describe as five (5) sheets of invoice paper relating to purchases by Mike Smith. MAB/2 I describe as the history of transactions of Mike Smith plus four (4) sheets of invoice paper. Both exhibits were as I had handed them to DC Richards on 26th April 1993.

Signed M. Byrnes Signature witnessed by R. Richards DC

Witness Statement Page 193

Form MG 11(T)

STATEMENT OF Ronald GILBERTSON

Age of Witness (date of birth) Over 21

Dated 7 May 1993

On Thursday, 7th May 1993 I attended an annex of the Metropolitan Police Forensic Laboratory at Denmark Hill, London. By making reference to exhibit MAB/1, an invoice from The Synthesizer Company addressed to Mr Mike Smith, 48A Burton Road, Kingston Upon Thames, Surrey, I found that exhibit PMS/2 - a Macintosh computer monitor, exhibit PMS/4 - a Diki Devices hard disk and cartridge unit, exhibit PMS/5 - a Macintosh computer keyboard, exhibit PMS/6 - a Macintosh computer, and exhibit PMS/8 - a Toshiba compact disk drive, are the same makes and types of those items described on exhibit MAB/1. Exhibits PMS/2, PMS/4, PMS/5, PMS/6 and PMS/8 have been in police possession since 8th August 1992.

Signed R. Gilbertson DS Signature witnessed by

Witness Statement Page 194

Form MG 11(T)

STATEMENT OF Marcia Anita ASHWOOD-LUCK

Age if under 21 Over 21

Dated 22 April 1993

I am the owner of two florist shops in the Kingston-upon-Thames area. Ashwood Florists at 83 Surbiton Road, Kingston-upon-Thames and Tudor Florists at 172 Tudor Drive, Kingston-upon-Thames, which I have owned for roughly four years. I employ 2 full time staff, both women, who each work at one or other shop, and two part-time staff, again both women, who fill in at whichever shop I need them to. I have been asked who would have been working at Tudor Florists on the morning of Saturday August 8th 1992 and if there would have been any men on the premises. That would have been one of my full time staff, Katherine GOULD, who would have been there from 8.30am to 5.30pm. I don’t actually employ any male staff, however, there are three men who help out delivering flowers on an ad-hoc basis, Colin BUTLER, Frederick WHEELER and his son David WHEELER. Of these three, it would most likely have been David WHEELER who would have been at Tudor Florists that day. David’s wife Susan is one of my part-time staff, and he helps her out as and when he is needed. Obviously, delivering flowers means he would have been in and out of the shop, and my shop at Surbiton Road, most of the day. I understand that I may

Signed M. A. Ashwood-Luck Signature witnessed by C Robson DC

Witness Statement Page 195

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Marcia Anita ASHWOOD-LUCK

have to attend court and give evidence if required. I would like to add that whoever is delivering flowers would usually take a full load of flowers and only come back to either shop once or twice during the day.

Signed M. A. Ashwood-Luck Signature witnessed by C Robson DC

Witness Statement Page 196

Form MG 11(T)

STATEMENT OF Colin BUTLER

Age if under 21 Over 21

Dated 20 April 1993

I have assisted selling flowers, generally helping out, in Tudor Florists at 172 Tudor Drive, Kingston-upon-Thames, Surrey, for about the last four years. I also help out at Ashwood Florists, which is also owned by Mrs N. Ashwood-Luck, the owner of Tudor Florists. I have, today, been approached by DC Robson, from New Scotland Yard, who is investigating offences against the Official Secrets Act committed by a Michael John SMITH. She has asked me if I can remember whether or not I was working at the Tudor Drive Florists on the morning of Saturday 8th August 1992 and if a man wearing a purple T-shirt, blue jeans and blue canvas shoes asked me for directions to Cardinal Drive. I cannot remember specifically if I did help out in the shop that day, but I can say that I have never been asked for directions to Cardinal Drive. I understand that I may have to go to court and give evidence regarding this matter.

Signed C. Butler Signature witnessed by C Robson DC

Witness Statement Page 197

Form MG 11(T)

STATEMENT OF David WHEELER

Age if under 21 Over 21

Dated 20 April 1993

I am employed as a storeman for Albright Engineering, Red Lion Road, Surbiton, however, on most Saturdays for the last four years I have helped my wife out in her Saturday job at Tudor Florists, 172 Tudor Drive, Kingston Upon Thames, Surrey. Today, I have met with DC Robson from New Scotland Yard, who is investigating offences committed under the official Secrets Act by Michael John SMITH. I have been asked if I was helping out in the shop on the morning of Saturday, 8th August 1992, and if a man, Michael SMITH, dressed in a purple T shirt, blue jeans and blue canvas shoes came in and asked directions to Cardinal Drive, Kingston. I think I most probably was in the shop that morning, but I do not remember anyone asking for directions to Cardinal Drive. I’m sure I would remember-if anyone asked for that road, because it doesn’t exist in that area. I understood that I may have to attend court and give evidence.

Signed D. Wheeler Signature witnessed by Christine Robson DC

Witness Statement Page 198

Form MG 11(T)

STATEMENT OF Frederick Albert WHEELER

Age if under 21 Over 21

Dated 22 April 1993

I have been retired for just over four years, however, to help my daughter-in-law, Susan WHEELER, I help to deliver flowers for Ashwood and Tudor Florists on an ad-hoc basis. Both shops are owned by Mrs Marcia ASHWOOD-LUCK. The Tudor Florists shop is at 172 Tudor Drive, Kingston-upon-Thames, however, I tend to deliver from the Ashwood Florist’s shop more often than not. I have met DC Robson from New Scotland Yard who is investigating offences committed against the Official Secrets Act by Michael John SMITH. I have been asked if I would have been working at the Tudor Florists on the morning of Saturday, 8th August 1992 and if I can remember a man dressed in a purple t-shirt, blue jeans and blue canvas shoes asking directions to Cardinal Drive. It is very unlikely that I would have been at Tudor Florists that morning as my son, David WHEELER, tends to help Susan on Saturday’s. To my recollection no-one has ever asked me for directions to Cardinal Drive. I do not know Michael John SMITH. I understand that I may have to attend court and give evidence.

Signed F. A. Wheeler Signature witnessed by C Robson DC

Witness Statement Page 199

Form MG 11(T)

STATEMENT OF Stephen John BEELS

Age if under 21 Over 21

Dated 4 May 1993

I have examined exhibits RH/21, PMS/14 and RH/20, British passports issued to Michael John SMITH, born 22nd September 1948, in particular the entry and exit stamps, and visas, entered on the various passport pages. Exhibit RH/21, passport No. P498414 issued at Peterborough passport office on 6th July 1970 which expired on 6th July 1980, contains the following entry and exit stamps, and visas, which are discernible to me and which I have listed chronologically:

DATE

STAMP

LOCATION

20(?)-07-70

14-08-70

17-08-70

20-08-70

09-09-70

12-07-71

20-07-71

05-08-71

19-10-72

02-11-72

Entry

Exit

Visa

Entry

Exit

Entry

Exit

Entry

Exit

Entry

Exit

Ostend, Belgium

Bulgaria

Turkey

Greece

Italy

Calais, France

Andorra

Madrid, Spain

Alicante, Spain

Signed S. Beels DS Signature witnessed by

Witness Statement Page 200

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Stephen BEELS

DATE

STAMP

LOCATION

27-07-73

01-09-73

15-09-73

16-08-74

21-06-76

19-08-76

26-08-76

Entry

Exit

Entry

Visa

Entry

Ostend, Belgium

Athens, Greece

Pula, Yugoslavia

U.S.A. visa issued London

Chicago, U.S.A.

Windsor, Canada

Exhibit PMS/14, passport No. 611898B issued at London passport office on 22nd July 1977 which expired on 22nd July 1987, contains the following entry and exit stamps which are discernible to me and which I have listed chronologically:

DATE

STAMP

LOCATION

11-08-77

13-08-77

20-09-78

21-09-78

21-07-79

08-06-80

24-06-80

07-09-86

Exit

Entry

Exit

Entry

Exit

Entry

Exit

Entry

Spain

Portugal

Caia, Portugal

Ibiza

Crete, Greece

Malaga, Spain

Exhibit RH/20, passport No. 516314L issued at Newport passport office on 2nd June 1988 which expires on 2nd June 1998, contains the following entry and exit stamps which are discernible to me and which I have listed chronologically:

DATE

STAMP

LOCATION

10-09-88

24-09-88

Entry

Exit

Sevilla, Spain

Signed S. Beels DS Signature witnessed by

Witness Statement Page 201

Form MG 11(T)

STATEMENT OF Judith Elizabeth RUSHTON

Age if under 21 Over 21

Dated 29 April 1993

I am a personnel assistant for Eli Lilly and Company, a pharmaceutical manufacturers with whom I have worked for two years. I have today met with Detective Constable Christine Robson regarding Michael John SMITH who, I have been informed, has been charged with offences under the Official Secrets Act. SMITH was due to begin employment with our company on the 10th August 1992, as a Temporary Procedures Writer, the anticipated duration of his employment was to November 1992, although this could have been extended. SMITH’s C.V. was faxed to us on the 17th June 1992 by Lab Staff Ltd, an employment agency, I now refer to this fax as JER/1. I am also in possession of a letter of confirmation of employment from Lab Staff Ltd dated 24th July 1992, setting out SMITH’s contract with us, I now refer to this as JER/2. I have been asked to retain both originals of these exhibits pending court proceedings. I understand that I may have to attend court and give evidence.

Signed Judy E. Rushton Signature witnessed by C Robson DC

Witness Statement Page 202

Form MG 11(T)

STATEMENT OF James Edward SYKES

Age if under 21 47

Dated 21 April 1993

I have today spoken with Detective Sergeant BEELS from New Scotland Yard regarding a Michael John SMITH who I have been informed has been charged with offences under the Official Secrets Act. I am Advisor of Pharmaceutical Training for Lilly Industries. I have examined my records and can confirm that a Michael J. SMITH attended two introductory G.M.P. (Good Management Practice) programmes on Thursday 6th August 1992. The two courses are entitled ‘GMP For New Employees’ and ‘You’ll Soon Feel Better’. These courses are held at our training rooms at Lilly Industries, Kingsclere Road, Basingstoke, Hants. The courses on that day commenced at 9am and ended at 12 noon. I can confirm that Michael J. SMITH was to be employed as a Procedures Writer and would have been working for Mr Robbie BOOTH. Each employee would be required to enter his name before each course on a GMP attendance form. I am in possession of two GMP attendance forms for the two above-mentioned courses and can confirm that the name Michael J. SMITH is entered on them. I refer to ‘GMP Attendance Form (GMP For New Employees) dated 5th August 1992’ as exhibit JES/1. I refer to ‘GMP Attendance Form

Signed J. E. Sykes Signature witnessed by S. Beels D/S

Witness Statement Page 203

Form MG 11A(T)

CONTINUATION OF STATEMENT OF James Edward SYKES

(You’ll Soon Feel Better)’ as exhibit JES/2. This second form was also dated 5th August 1992. Although both forms are dated 5.8.92 I have examined my business diary and can confirm that the relevant courses in fact took place on 6th August, 1992, a Thursday. I have photocopied the relevant page (6.8.92) from my diary and now refer to this as exhibit JES/3. JES/1 and JES/2 are also photocopies and were photocopied by myself. I have been requested to retain the originals of all three exhibits pending future court proceedings. I can recall hearing of Michael SMITH being arrested over the following weekend probably on the radio or television. It was on the following Tuesday that I was informed that it was the same gentleman who was meant to commence employment with us.

Signed J. E. Sykes Signature witnessed by S. Beels D/S

Witness Statement Page 204

Form MG 11(T)

STATEMENT OF Raymond WRIGHT

Age if under 21 Over 21

Dated 29 April 1993

I am Security Manager for Eli Lilly and Company, pharmaceutical manufacturers with whom I have worked for almost 30 years. I have met with Detective Constable Robson from New Scotland Yard regarding Michael John SMITH who, I have been informed, has been charged with offences under the Official Secrets Act. I can confirm that at no time did Eli Lilly & Co. place SMITH or his address at 48A Burton Road, Kingston-upon-Thames, under any form of surveillance prior to the 8th August 1992.

Signed R. Wright Signature witnessed by C Robson DC

Witness Statement Page 205

Form MG 11(T)

STATEMENT OF Martin Charles GRAY

Age if under 21 Over 21

Dated 21 April 1993

I am a Detective Chief Inspector attached to Metropolitan Police Special Branch at New Scotland Yard. Special Branch did not place Michael John SMITH or his home address at 48A Burton Road, Kingston-Upon-Thames, Surrey, under surveillance prior to his arrest on 8th August 1992.

Signed M. Gray Signature witnessed by

Witness Statement Page 206

Form MG 11(T)

STATEMENT OF Stephen John BEELS (Detective Sergeant)

Age if under 21 Over 21

Dated 4 May 1993

I have examined exhibit MN/13, a GEC Hirst Research Centre Audit Schedule, and identified from the initials MJS appearing under the heading Auditors those audit areas in which Michael John SMITH was the auditor, alone or with another. I produce this chronological list for the period 24th April 1986 to 23rd July 1992 as exhibit SJB/44.

Signed S. Beels DS Signature witnessed by

Witness Statement Page 207

Form MG 11(T)

STATEMENT OF Dr. Steven Langford CUNDY

Age if under 21 Over 21

Dated 26 April 1993

This statement, (consisting of 14 pages each signed by me) is true to the best of my knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable to prosecution if I have wilfully stated in it anything which I know to be false or do not believe to be true.

I have been asked to provide evidence that GEC Hirst Research Centre is a prohibited place within the meaning of the Official Secrets Act. I am not aware that the Ministry of Defence or Her Majesty’s Government issue certificates to confirm such a status. However, my belief that HRC is a prohibited place, and has been for many years, is based on the following facts: (a) A reading of the OSA Section 3(b). HRC has sketches, models, plans and documents relating to the repair, manufacture and development of munitions of war where the ultimate customer, through chains of subcontractors, is MoD. (b) HRC has direct contacts with various establishments of the Defence Research Agency who may be managing MoD’s extra-mural research procurement or who may be procuring components, subsystems or information directly for their own work on behalf of the MoD. (c) HRC has a Security Adviser appointed by MoD to oversee the implementation of security related procedures in its work, (d) HRC has had, almost certainly at any point in time, at least one contract from the MoD which was classified in accordance with security procedures. Such classification identifies material which the MoD regards as sensitive and which, by definition, confirms that some contracts relate to munitions of war. I have been asked to comment about the classification of documents held at HRC and to discuss the fact that not all documents, rightly regarded as sketches, plans, or information relating to munitions of war, bear the security classification appropriate to the final munition of war. The Rapier air defence missile system almost certainly is a classified system, yet Cossor delivered blueprints to HRC for the manufacture of a component of the Rapier

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 208

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

system that were not classified and HRC created related documentation, to enable that manufacture, which was not classified. Such occurrences are normal and are encouraged by MoD. They form an essential demonstration of the ‘need to know’ principle by minimising the number of people who have complete knowledge about a system. ‘Freeing up’ the manufacturing chain, so that relatively lowly tasks are not encumbered by draconian security precautions, ensures secrecy of ultimate use by requiring people in the chain to recognise (or be told) what is sensitive and structure the next lower level tasks in a way which does not reveal the sensitive information. If every task bore the classification of the ultimate objective then the manufacture of certain nuts and bolts would be ‘top secret’. The objective is to stop that reductio ad absurdum and reduce the number of people who have access to classified information to an absolute minimum. Note that even I cannot assert that the Rapier system is classified; I can only surmise that is the case. I have been asked to comment on the suggestion that the Rapier documentation found in Smith’s possession might have been the result of some hasty clearing by him of his place of work. This is an unbelievable assertion. The sheer bulk of the documentation including folded blueprints, which do not sit easily in a pile of A4 size paper, makes it beyond belief that the removal of documentation was a ghastly error. Moreover, the documentation was removed from a filing cabinet to which Mr Smith did not have or need regular access although the filing cabinet was in the shared office that Mr Smith ended up occupying alone. Associated with the above suggestion I have been asked to comment whether Mr Smith left HRC in haste. This is certainly not the case. As is our normal practice in cases of redundancy, Mr Smith had consultation with his immediate superior and the Personnel Manager prior to the issue of a formal letter declaring the redundancy and was permitted to work out his statutory notice period of at least 4 weeks before the redundancy took effect. He was paid for work for the month of July and redundancy payment by cheque was sent on 31st July to his home address. Detective Sergeant Beels has shown me Smith’s personnel file at HRC, marked MN/9, which contains a copy of a letter dated May 29 1992 from the HRC

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 209

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Personnel Manager to Mr Smith formally confirming his position as Quality Audit Manager redundant and his last working day at HRC as 31st July 1992. There was certainly enough time between the declaration of a leaving date and that date for a collection for a leaving present to be organised and a departmental party to be arranged. This was not a hasty departure. Detective Sergeant Beels has shown me completed time-sheets, marked SLC/1, for Quality Assurance Unit personnel at HRC, including Mr Smith, covering the period 1st April 1990 to 31st July 1992. The time-sheet for 30th July 1992 shows that Mr Smith signed in at 9.20am and out at 12.28pm and the one for 31st July 1992 shows he signed in at 9.27am although no leaving time is entered. Detective Sergeant Beels has shown me an Audit Schedule list at 30th July 1992, marked MN/13. He has asked me to examine a chronological sequence of reports issued by the Q.A. department (marked SJB/44), drawn up by Special Branch from MN/13, relating to audits undertaken by M.J. Smith either alone or with another auditor. I have identified each report by its report number and commented on the military sensitivities in the relevant areas. My commenting system consists of: Y (Yes) - Known military contracts in the area. Contracts visible. P (Part) -Known military subcontract work in the area, often surrounded by similar work not of military significance, but contract chain well disguised. N (No) - No known military contract subcontract work in the area.

Report

number

Date

Audit Area

Sensitivity

636.01

633.01

631.01

635.01

628.01

628.02

628.03

629.01

627.01

23.7.92

18.6.92

11.6.92

9.6.92

21.5.92

19.5.92

14.5.92

Optical Spectroscopy

Photonics Division Blue Book Review

Micro Machining

Biosensors

Vacuum Micro Electronics Test Area

Analytical Chemistry

Millimetre Wave

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 210

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

9203.01

9203.02

626.01

625.01

621.01

621.02

621.03

619.01

618.01

620.01

620.02

617.01

616.01

615.01

614.01

614.02

613.01

612.02

612.01

609.01

608.01

607.01

607.02

9201.01

606.01

605.01

604.01

603.01

8.5.92

7.5.92

30.4.92

15.4.92

14.4.92

9.4.92

2.4.92

26.3.92

20.2.92

13.2.92

31.1.92

23.1.92

17. 1.92

17.1.92

13.1.92

Display & Optical Research Lab (SC)

Quality Support Environ Montrng

Systems Theory

Safety

Goods Inwards Despatch

Stores

Personnel & Training

Polymer Technology

Vacuum Micro Electronics

Electronics (Liquid Cryst)

Calibration System

Metallurgical Services

Deviation Report System

Crystallography

Thick Film Unit

Lighting

Quality Assurance Unit

Crystal Growth

Photonics Division Blue Book Review

Purchasing

Metallurgical Technology

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 211

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

602.01

602.02

9112.01

600.01

9111.01

599.01

598.01

597.01

596.01

596.02

595.01

594.01

593.01

590.01

590.02

588.01

586.01

9110.01

9110.02

584.01

582.01

583.01

583.02

581.01

580.01

580.02

580.03

9108.01

9.1.92

19.12.91

18.12.91

11.12.91

10.12.91

5.12.91

22.11.91

21.11.91

12.11.91

7.11.91

6.11.91

29.10.91

11.10.91

9.10.91

7.10.91

4.10.91

24.9.91

IC Assembly

Device Applications Lab

Applications Group

LAN Analyser

Design Office Operating System

Special Projects

BAW Delay Lines

Metallurgical Services Meniscograph

TACAN repairs

Electrochemistry Group

Software Control QDA DC 158

LCD Supermarket Displays

Olfactory Research Project

Device Failure Analysis

Chemistry & Materials FAB LAB (MB)

Laser Testing

Holography and Backplanes

RP004 236

Quality Doc Operating Procedure

Information Services Division

Long Range Research Lab (LR)

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 212

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

573.01

573.02

573.03

572.01

571.00

574.01

569.01

569.02

569.03

569.04

568.01

567.01

566.01

9105.01

565.01

564.01

563.01

562.01

561.01

561.02

561.03

561.04

560.01

560.02

560.03

559.01

9103.01

558.01

553.01

29.8.91

28.8.91

20.8.91

19.8.91

15.8.91

14.8.91

13.8.91

12.8.91

6.8.91

31.7.91

26.7.91

25.7.91

24.7.91

16.7.91

26.6.91

Gamma Calibrators

Active Matrix Group

Picker Hammersmith Group

Image Processing Group

Chemical Services Gases & Chems

Applied Chemistry

Superlattices

Silicon Group

Telecomms Local Systems Lab (TL)

Speech Processing Group

Computer Vision & Perception

Accounts

Engineering Workshop

Applied Chemistry Battery Test

Product Safety

Optical Spectroscopy

Telecomms Systems Integration Dept (TS)

Oscilloscope Maintenance

ESD Precautions

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 213

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

553.02

552.00

9101.01

550.01

550.02

550.03

550.04

550.05

550.06

550.07

549.01

547.01

547.02

545.01

545.02

539.01

539.02

539.03

538.01

538.02

537.01

537.02

536.01

535.01

533.01

533.02

533.03

26.6.91

11.6.91

7.6.91

17.5.91

16.5.91

15.5.91

18.4.91

9.4.91

19.3.91

14.3.91

13.3.91

ESD Precautions

Test & Inspection

Signal Processing Systems Lab (IP)

Central Computing Unit

High Temp Superconducting Devices Div

CPNS

Polymer Technology

Large Area Micro Electronics Division

Top Management Quality System

Liquid Crystal Devices Division

Evaluation of CFC Alternatives

Image Intensifiers H002056323

Biosensors

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 214

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

532-01

531.01

531.02

531.03

531.04

531.05

529.01

530.01

528.01

528.02

528.03

527.01

526.01

525.01

522.01

522.02

522.03

522.04

520.01

519.01

519.02

524.01

524.02

524.03

518.01

517.01

516.01

516.02

12.3.91

8.3.91

7.3.91

6.3.91

5.3.91

4.3.91

20.2.91

8.2.91

29.1.91

24.1.91

23.1.91

22.1.91

18.1.91

17.1.91

Micro Machining

SBE & AM Assembly Group

Goods Inward Despatch

Vacuum Micro Electronics Test Area

Deviation Report System

Metallurgical Services

Safety

Crystallography

Calibration System

Laboratory General System (DAL)

Site Engineer

Vacuum Micro Electronics Processing

Personnel & Training

Stores

Crystal Growth

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 215

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

516.03

513.01

513.02

513.03

513.04

513.05

513.06

509.01

511.01

512.01

510.01

508.01

506.01

506.02

504.01

504.02

503.01

507.01

505.01

505.02

505.03

501.01

501.02

501.03

501.04

501.05

500.01

499.01

17.1.91

3.1.91

18.12.90

13.12.90

3.12.90

29.11.90

28.11.90

27.11.90

13.11.90

8.11.90

Crystal Growth

Systems Theory

IC Assembly

AMSYS

Vacuum Micro Electronics

GPT Proposal 90108

Lighting

Quality Support Inspection Procs

Materials Processing Dept

Materials Processing Dept (DAL)

Trident X Ray Orientation

Purchasing

Electro Chemistry Group

BAW Delay Lines

Software Control QDA DC 158 (DAL)

Design Office Operating System

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 216

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

499.02

499.03

498.01

496.01

496.02

497.01

495.01

494.01

494.02

494.03

494.04

486.01

486.02

486.03

484.01

481.01

480.01

480.02

480.03

482.01

482.02

482.03

482.04

482.05

479.01

479.02

479.03

479.04

8.11.90

1.11.90

19.10.90

15.10.90

9.10.90

29.8.90

10.8.90

8.8.90

7.8.90

3.8.90

25.7.90

Design Office Operating System

Metallurgical Technology

TACAN Repairs

Management System (EEV)

AB Dick Contract CB46015

Device Failure Analysis

GPT Proposal 90301

Photography

Applications Group

Laser Systems

Quality Doc Operating Procedure

Chemical Services Gases & Chems

Signed S. L. Cundy Signature witnessed by S. Beels D/S

Witness Statement Page 217

Form MG 11A(T)

CONTINUATION OF STATEMENT OF Dr. Steven Langford CUNDY

Report

number

Date

Audit Area

Sensitivity

478.01

474.01

474.02

474.03

474.04

474.05

474.06

473.01

472.01

470.01

470.02

470.03

470.04

470.05

468.02

468.01

467.01

467.02

467.03

466.01

465.01

465.02

464.01

463.01

463.02

463.03

463.04

463.05

25.7.90

3.7.90

2.7.90

22.6.90

21.6.90

31.5.90

24.5.90

21.5.90

9.5.90

Engineering Workshop

Metallurgical Services Meniscograph

Digital Optical Systems

Speech Processing Group

Glass Fabrication

Image Processing Group

Thick Film Unit

Optical Spectroscopy

Applied Chemistry

EBMF Facility General System

Picker Hammersmith Group