It's fair to say, isn't it, that there's been a bit of a joint effort on the part of both of you since you first went to see the solicitors back in 07?---Well, we've been together for 26 years, yes.
To the extent that you both swore the same affidavit; do you recall that?---Yes, yes, we did.
Then you both signed the one witness statement. That was after the affidavit?---Yes, I think we did. I think we did. There's been a lot of toing and froing, but I think, yes, we did sign the one witness statement, yes.
When you say toing and froing, were you both present together when the affidavit was being prepared, the joint affidavit?---Yes.
You were both together when the joint witness statement was being prepared?---When you say present when it was being prepared, were we in the - do you mean being in the office in Mandurah or
I apologise. Let me clarify. Your solicitors were Clement and Co of Mandurah. Yes?---That's correct.
So you went to see them for advice?---Yes.
They met with you to prepare firstly the affidavit?---Yes.
The course of that preparation involved a solicitor sitting down with both you and Dana at the same time and asking you both questions at the same time?---Yes. I also prepared a long written statement that I gave them that some of the affidavit material came from as well.
After that joint affidavit, there was the joint witness statement, you told us earlier?---Yes.
That was prepared in the same fashion, you and Dana together with the solicitor?---Yes.
At all times, both of you together with the solicitor?
---Yes.
In fact, it's a fair summary to say that for these proceedings this week, you and Dana have separate witness statements, but they are pretty much in the same terms, aren't they?---Yes.
And you've read over her witness statement a number of times?---I've read it over. I've read Dana's once and skimmed through it a couple of times.
So you know then it's almost identical to yours, don't you?---Yes.
And similarly she has read your witness statement?---No, Dana hasn't read mine, not comprehensively. She's had a look at bits.
To your knowledge?---Yes, to my knowledge.
But she was present with you at all times when it was being prepared?---She knows the substance of it, yes.
But she was present with you and the solicitor when her witness statement was being prepared. Yes?---Yes.
You spent a lot of time with your solicitors back from 07, I think, when the caveat was lodged. Am I right in that?
---Yes, 07.
07, so we're now in 011 so it's four years, isn't it?
---Yes.
Or nearly?---It's been over four years since all of this started, but yes.
Your solicitors no doubt explained to you that it's a very serious business to lodge a caveat, didn't they?---Yes.
And that in fact you had to be careful to make sure that what you said in any affidavit was accurate. Yes?---They said to tell the truth and nothing but.
And no doubt they said the same thing about the witness statements?---They said, 'Whatever you do, just tell the truth and nothing but,' and when I've been seeing my witnesses, the people we've got as witnesses, I've stressed that to them as well.
Tell me about that a bit more. Who have you been seeing and when and what have you said to them?---I saw Russell and I got him to - I told him what the situation was.
When you say you told him what the situation was, what do you mean?---That Adaria had reneged on her original agreement, and I said, 'Look, we'll be needing you as a witness.' I said, 'Can you write down your story?' I said, 'But when you write down your story take your time, make sure that whatever you say you can stand by because you'll be called up in court to be questioned on it.'
Did he discuss his recollections with you?---On several occasions; on other occasions, no, he just wrote down what he thought. I found it to be imperative not to influence because I don't want people to end up sitting where I am here not feeling a hundred per cent sure of what they're saying.