Third Deposition


Transcript of Witness G.

Date: May 27, 2012

Case: The Royal London Research Institute -v- European Court of Human Rights


















VIDEO SPECIALIST: The court reporter today is Brenda Huff. Would the reporter please swear in the witness.

WITNESS G. having been duly sworn, testified as follows:




Q: Good morning, G.

A: Good Morning.

Q: Due to the sensitive nature of the information you have, your identity has been changed a few times, hasn’t it?

A: Yes

Q: I imagine that has been quite troublesome.

A: That is an understatement.

Q: But on the scale of things you suffered while at the Institute’s facility, probably not the most painful.

A: I don’t have a scale. I live in a constant state of wretchedness.

Q: Of course. I apologise. For what it’s worth. I ask you to think back to point where you were rescued form the Facility. Or more, the point when you thought you had been rescued.

A: Which time?

Q: The first time.

A: Okay.

Q: You had been living in general population, at this point?

A: I was living on the cell block, yes.

Q: And what did your days consist of?

A: Psych tests, Memory exercises, torture.

Q: Torture?

A: What I considered torture, Yes.

Q: And can you clarify what that was?

A: I had arrived at the facility with my brother. I was told, if I participated in the exercises, we would both be allowed to ‘return home’. It was not my own desire to participate in those exercises. In fact, they hurt immensely. But they said I could see my brother again. They kept saying that, even though my brother had died 3 days after our capture.

Q: And what were these exercises?

A: The supervisors would bring people in and have me mine them for information until I was physically ill.

Q: And how often would this happen?

A: That I would be sick or that they would bring people in?

Q: Both.

A: So, if I mined 5 people a day, I would be sick by the 7th day.

Q: And what would happen when you got sick?

A: They would give me a break.

Q: For how long?

A: A couple of hours.

Q: Sorry?

A: A couple of hours.

Q: So, you’d still see people that same day?

A: Yes. Sometimes, we wouldn’t even get a break. They’d just mop us up and tell us to keep going.

Q: We?

  1. BERMAN: Objection, beyond the scope.
  2. ORFANEDES: Your honour, I am establishing the witness’s routine.
  3. BERMAN: You’re supposed to be asking about the escape.
  4. ORFANEDES: You mean the faux escape that your clients orchestrated.
  5. HOLMES: Enough. Ms. Orfanedes, continue with your questioning.


Q: G, who did you mean by we?

A: All the subjects with mental abilities. The had us work on the same corridor. If one of us was unsuccessful with a test, they’d pass the test to another. We would have lunch together. It’s how I met-

Q: G?

A: Sorry?

Q: It was how you met who?

A: It’s not important.

Q: We’ll decide if it’s important or not, G.

A: It’s how I met [Witness F].

Q: I see. Were the two of you friends?

A: When?

Q: While at the facility?

A: No. None of us were really allowed to talk to each other.

Q: But you ate lunch together-

A: Under supervision, yes.

Q: So, did you not talk because you didn’t want to or because you didn’t want to be seen?

A: Sort of both. Everything was being recorded.

  1. BERMAN: Objection, beyond the scope!
  2. ORFANEDES: How?
  3. BERMAN: The witness could not possibly know that.
  4. ORFANEDES: He was there.
  5. BERMAN: Your Honour, it has already been established that information from this period is unreliable. The subjects were purposely misinformed to keep the experiment unbiased-

WITNESS G: I know what I’m talking about.

  1. BERMAN: I’m sure you think you do.

WITNESS G: I know I do. I mined members of staff throughout my time at the facility. Seeing as the only other person with the ability to manipulate memories was murdered at the facility, I am confident that the memories I gathered were authentic.

  1. BERMAN: G, you have no way of knowing if your brother was murdered

WITNESS G: I saw it. I saw it in his supervisor’s memories.

  1. BERMAN: A witness whom you murdered before they could testify, so how can anyone really know.
  2. ORFANEDES: Your Honour, Mr. Berman is hijacking my examination of the witness.
  3. HOLMES: Mr. Berman, you will wait your turn, or you won’t have one. Have I made myself clear?
  4. BERMAN: Yes, Your Honour.
  5. ORFANEDES: May we continue, your Honour?
  6. HOLMES: Please.


Q: How did you know you were being recorded?

A: Because I knew, despite what we were being told, that we were the subjects of the experiment.

Q: And how did you know that?

A: how do you think I knew that?

MR HOLMES: G, please just answer the questions. We don’t need you to pose them.


Q: How did you come to know that you were the subjects of the experiment?

A: I had mined it from a Supervisor.

Q: And how often were you doing that?

A: At first, all the time, and then after we moved to cell block, only when I could get away with it.

Q: And when was that?

A: During breaks, meal times. The kitchen staff and orderlies were not…the brightest. Sometimes, I’d take memories from the others.

Q: The others?

A: The other-

Q: G, please answer.

A: The other people like me.

  1. GRAHAM: Your Honour, may I request a recess?
  2. HOLMES: Ms. Orfanedes? Mr. Berman?
  3. ORFANEDES: I’m fine with that.
  4. BERMAN: Yes, same.

VIDEO SPECIALIST: We are off the record at 12:35.

(A recess was taken.)

VIDEO SPECIALIST: We are back on the record at 13:40.


Q: Let’s jump forward a little. At the point, when you thought you were being rescued, how many people were left in the facilty?

A: I don’t know. I only know who was in my cell block.

Q: How many was that?

A: Seven.

Q: What had happened to the others?

A: What had we been told or what had actually happened to them?

Q: Both.

A: They told us they had been reassigned to another cell block. That’s what they had told me about my brother too.

Q: And what had actually happened?

A: (No verbal response.)

Q: G?

A: I heard 0504 die. She had been glitching all afternoon-

Q: Glictching?

A: It’s um- It’s a thing that happens to people with mental abilities. Sometimes it’s nose bleeds, blackouts. It’s the wear and tear we suffer for using our abilities, only it can become- I don’t really know how to describe it- It’s different for everyone. For me, I can get trapped in memories. For- For Witness F, She has episodes of dissociation. It’s basically like your ability takes over and you lose control of yourself.

Q: Hyper Disassociation.

A: Yeah, but we call it glitching. You know, from when we thought that we’d had these abilities implanted in our heads.

Q: I see.

A: Community slang.

Q: So you heard 0504 die and then?

A: And then in the morning, we were told she had been reassigned.

Q: And what did you do once you made the link?

A: Nothing.

Q: Nothing?

A: What could I do?

Q: Were you worried?

A: No. I am not afraid to die.

Q: Is that why you went along with the escape plan?

A: To a degree.

Q: What other reason was there?

A: If I was out I could find the Good Doctor and do to him what he had done to me.

Q: and by that you mean kill him?

A: By that I mean find him, bind him, torture him and kill him. Yes.

  1. GRAHAM: Can we have a sidebar?
  2. HOLMES: You’ve just had a recess. Either continue with your line of questioning or release the witness.
  3. GRAHAM: Okay.
  4. ORFANEDES: No further questions, your honour.

VIDEO SPECIALIST: We are off the record at 14:00.

(A recess was taken.)









You Asked Me Out – Cliff

Did you hear that?

What is the point of a pact like that?

‘If we’re still single at 25, or 30, we’ll marry each other.’ – if you wanted to marry me at all, why not marry me now? I’m never going to look better than I do now. I’m never going to be better than I am now. Either I’m good enough for you now or I’m not, end of. If I’m not, what do you think is going to happen in the space of five years?

I’ll tell you what’s going to happen: you’re going to get desperate. I’m going to get desperate. We’re going to lie awake at night in our respective beds, stressing about who we’ll take to so-and-so’s wedding, and when we last had sex, and maybe, just maybe, if we might be that one person who ends up with no one. We’re going to be cold. We’re going to be alone, and at that point, we’re just going to want something familiar. We’ll suppress the things we dislike about each other. We’ll force ourselves to take an interest in the other’s passions. We’ll even forgo our personal beliefs just so we have someone to go home to each night.

And ever so slightly, we’ll resent each other. And at the back of our minds, we’ll think, ‘What if you’re only with me because you’re scared of being alone?’ And we’ll let that fester. And every time we have an argument, it’ll come up. Passively, mind. We’ll never address it directly, for fear that we’ll have to acknowledge it properly. You know – part ways.

Then we’re back to square one. Cold. Alone. And even older.

So while I understand this is all ‘fun and games’, I don’t play games with matters of the heart, and I never ever make fun of it.

…Should we order?


She unlocks the car with a beep. The little boys tug at the door handles.

‘Max, stop shoving me!’

‘I’m not shoving you! It’s Nico!’

‘Mum! Jos hit me!’

‘If you’re going to fight,’ she says, clicking the key into the ignition, ‘you can walk to Aunt Livy’s.’

The fidgeting stops. The boys attach their seatbelts.

‘Are we going to Aunt Livy’s?’

‘Yes.’ She says, smiling at them through the rear view mirror.

Nico and Max cheer. Jos folds his arms.

‘I don’t want to go to Aunt Livy’s.’ He mumbles, ‘She doesn’t let me read by myself.’

‘But she makes the best ice cream sundaes!’ Max beams. He leans forward in his seat.

‘Mummy, have you had a ice cream sundae at Aunt Livy’s?’

‘I don’t want to go to Aunt Livy’s.’ Jos says, louder. He looks at his mum in the reflection of the mirror.

‘So I’ve heard.’She says, staring back at him. ‘What do you want me to do about it?’

Jos does not expect the cross examination and stumbles.

‘I don’t know.’ He shrugs. ‘Can’t we stay with you?’

She doesn’t even break a sweat.

‘Joseph, what day is it today?’

‘Thursday.’ He replies reluctantly.

‘Thursday. A week day. And what happens on a weekday?’

‘You have to go to work!’ Max pipes up.

‘I have to go to work. I don’t want to go to work on lovely summer days like this, but I have to, because I need to make money to support you. I’d rather be at the beach with all of you and Daddy, but beaches cost money. Boys cost money. Even Dads cost money sometimes. So I have to go to work. Daddy has to go to work. And you have to go to Aunt Livy’s.’

She turns around.

‘Sometimes you have to do things that you don’t want to. That is how life is balanced. On the one hand-‘

She raises her right hand.

‘Fun things. And on the other-‘

She raises her right.

‘Not so fun things. But that’s good. I know it’s hard to understand now, but it teaches you things. Endurance, how to enjoy the good things when you get them.’

She continues, her thoughts far away.

‘If you just do the things that you like all the time, the minute something you care about gets too difficult, like reading a new book, or drawing a picture, you’ll walk away instead of working through it. I want you to be brave and strong when you grow up. Not quitters. Not spineless, or weak willed like the men on my side of the family.’

She turns back and starts the car.

‘Things will be different with you. I’m not going to give you the chance to fail. So you can complain all you want, Joseph Finebeck, but you’re going to Aunt Livy’s and you’re going to learn something from it.

She backs out of the drive.