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TRIBUNAL OF INQUIRY
 
INTO PAYMENTS TO MESSRS CHARLES HAUGHEY AND MICHAEL LOWRY
 
APPOINTED BY INSTRUMENT OF THE TAOISEACH DATED 26 SEPTEMBER 1997 PURSUANT TO TRIBUNALS OF INQUIRY (EVIDENCE) ACTS, 1921 AND 1979 
OUTLINE WRITTEN SUBMISSIONS ON BEHALF OF DENIS O’BRIEN
 12 September 2005 WILLIAM FRYSolicitorsFitzwilton HouseWilton PlaceDublin 2 012350.0057.OOS/TPR 
 
TABLE OF CONTENTS 
EXECUTIVE SUMMARY..... 31. PRELIMINARY 62. MR. O’ BRIEN’S ENTITLEMENT TO DEFEND HIS GOOD NAME. 83. THE TRIBUNAL’S INQUIRY INTO THE EVALUATION PROCESS.... 104. THE TRIBUNAL’S INQUIRY AND ITS TERMS OF REFERENCE. 155. AMI REPORT....... 176. PROCURING THE EVIDENCE OF MICHAEL ANDERSEN.. 257. PROCURING THE EVIDENCE OF OTHER AMI WITNESSES 318. ATTENDANCE AT PUBLIC HEARINGS / CROSS-EXAMINATION 359. WHAT IS THE EFFECT ON THE TRIBUNAL? 3910. WHAT IS THE EFFECT ON MR O’BRIEN? 4111. THE DELAY OF THE TRIBUNAL... 4512. CONCLUSION 47
 
SCHEDULE 1....SCHEDULE II...
 
Executive Summary
The Tribunal’s public sittings into the second mobile phone licence have been proceeding for almost three years. During the course of this inquiry the Tribunal has called and heardevidence from 62 witnesses over 130 days’ of public hearing, including the evidence of Mr.O’Brien and the evidence of witnesses from the Department of Telecommunications, Energyand Communications (as it was then), the Department of Finance and the EuropeanCommission. Witnesses from the Irish Government Departments have answered, insofar asthey could, the questions that the Tribunal posed in respect of the evaluation methodology thatwas formulated and managed by Michael Andersen and other consultants from AndersenManagement International (“AMI”). None of the evidence given by any of these witnessesrevealed any wrongdoing in the evaluation process. Consequently, Mr. O’Brien submits thatat this stage the Tribunal is in a position where it has no evidence that there was anywrongdoing in respect of the competition for the second GSM phone licence.The second GSM licence was awarded to East Digifone Limited following an evaluation process that was devised and conducted by AMI who were retained to provide the necessaryexpert assistance to the Irish Government. As such, Michael Andersen and his AMI team areundoubtedly the central players in any investigation into this evaluation process.The Tribunal finds itself in a position where Michael Andersen is willing but unavailable togive evidence. The Tribunal has now permitted parties to make submissions premised on hisunavailability. A summary of Mr. O’Brien’s submissions are set out hereunder: i. Since no evidence of any wrongdoing in respect of the competition for the second GSM phone licence has been heard to date, the Tribunal should recognise and accept that itsinquiries have alleviated any public concern that may have existed about the award of the second mobile phone licence and should state publicly that it does not propose to proceed any further since it is satisfied that no wrongdoing existed. Such a decision bythe Tribunal would mean there would be no necessity to hear any evidence fromMichael Andersen or from any other individual;ii. Should the Tribunal believe that it is entitled to proceed with further inquiries into theGSM module (notwithstanding the absence of any evidence of wrongdoing) the
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