Neither Odim nor Giddins provided written lists of issues to the committee. Odim said that he did express his concerns to committee members shortly after Wiseman's request. He testified that the issues he outlined were poor teamwork and communication, the need to consolidate the NICU and PICU and the need to reduce the number of anaesthetists. However, those attending that meeting did not recall Odim mentioning these concerns until much later in the summer and fall.

Giddins essentially said that he had no concerns that he felt he needed to bring to the committee. His view was that there was no reason to be concerned about what had occurred in the program to that point. He also was of the view that the anaesthetists' action was not appropriate. In response to questioning about what the Committee was asked to do and his view about the issues it was asked to address, Giddins said:

Yes, but I can't-I still, I am still unsure of many of what you are calling concerns. The concerns that you are remarking on, I feel are issues that are inherent in a pediatric cardiac surgical program. Concerns over outcomes, concerns over ensuring the highest possible quality of program, those issues are standard issues as far as I am concerned.

Q. Probably standard issues for any kind of surgery in any hospital anywhere; right?

A. Yes.

Q. You will agree, though, that having medical professionals withdraw services because of those concerns is a fairly unique experience?

A. Yes, but I can't speak for the people or the practitioners that chose to do that.

Q. I am not asking you to. I am just asking if for you this was something new?

A. Yes. (Evidence, page 3,387)

Giddins was the acting medical director of the VCHC and in charge of the PCS program. Considering the state of affairs that existed in the program to that time, the circumstances surrounding the deaths of Jessica Ulimaumi and Vinay Goyal and the concerns expressed by the nurses and the anaesthetists, Giddins's view could easily be seen as an alarming statement. It also helps to understand why other parties were of the view that approaching Giddins with their concerns was an exercise in futility.

Ullyot testified that, as far as she could tell, the lists presented to Wiseman were never collated or directly presented to the committee as agenda items, although a number of the issues were raised tangentially. Wiseman's testimony on this point is unclear, although it supports Ullyot's assertion that the issues on the list were, for the most part, only discussed as and when they might arise in the individual cases that were being reviewed (Evidence, page 40,482).