The first is that Dr Ardrey [that is, the appellant], well knowing that a level of science not possessed by the company [that is, Phoenix] was necessary to achieve an effective licensing package, represented to the company that he could, with the employment of consultants, produce such a package within varying but short time frames.
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The second is that Dr Ardrey, throughout his employment by the company, continued to reassure the company that they were on track to have a licensing package when he well knew that an effective licensing package could not be produced and that the work his consultants were producing and being paid for was not suitable for incorporation into such a package.
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The third is that the work claimed for in respect of each of the invoices had not been done. That's simple enough. The work had simply not been done. And you'll remember that both Mr O'Sullivan [that is, the prosecutor] and Mr Massey [that is, defence counsel] went through that in quite some detail. The State's case is that the work had not been done.
The fourth is that Dr Ardrey ... having achieved the budget allocations of $165,000 and later $500,000 from the company, proceeded to cause the company to make the payments particularised in each one of the separate counts on the indictment for material which could never have fulfilled the process for which he had been granted access to the budgeted money, namely the production of a licensing package, thereby deceiving the company into acting to its detriment. The State says that what was produced was unsuitable for incorporation into the promised licensing package.
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The fifth thing is that Dr Ardrey represented the invoices to the company; that's Phoenix Eagle, and sought payment of them well knowing that the payees; that is, Franklin Chen and Associates or Franklin Chen, Silicon Valley Pharmaceuticals and so forth - so the payees did not exist as he had represented them to be because in relation to Silicon Valley that the consultants did not exist, or were not appropriately qualified, or did not actually do the work, and in relation to the Franklin Chen invoices, leaving aside Franklin Chen, that the consultants did not exist; that is, the consultancy Franklin Chen and Associates didn't exist, or any other person supposed to be associated with it didn't exist, although - and this is a matter for you, it's a matter of comments - it seems that the State doesn't dispute that there was a person called Franklin Chen. But the State disputes that Franklin Chen was appropriately qualified or that, in fact, Franklin Chen or Franklin Chen and Associates had done the work. So I'll say that again.
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The sixth is that Dr Ardrey set up a system whereby he procured payment of the invoices by Phoenix Eagle to the consultants in circumstances where he was ultimately the beneficiary of the moneys, namely knowingly and wilfully disguising the true nature of his relationship with the consultants; and in the case of Franklin Chen by failing to disclose his proper qualifications and the family relationship, and in the case of Silicon Valley the fact that the moneys were being paid to his parents-in-law and not to Silicon Valley. For short summary you could refer to that generally as being the system of payment that the State says that Dr Ardrey set up (ts 3183 - 3185).