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Paragraph 1 of the Grounds of Claim is admitted.
As to paragraph 2 of the Grounds of Claim, it is denied that the Claimant’s colleagues were improperly altering test data and it is denied that the test data as amended gave a misleading impression of the testing the compound had undergone. The Claimant’s colleagues made standard adjustments to test data in accordance with industry guidelines. It is not admitted, if it is alleged, that the Claimant believed that the adjustments were improper or misleading and, if the Claimant did have such a belief, it is denied that it was reasonable. A chemist of the Claimant’s training and experience would have been well aware of the industry guidelines and therefore that the adjustments were standard and appropriate.
It is admitted that on [insert date], the Claimant told [insert name] that [insert names] had been inappropriately altering test data. It is admitted that [insert name] expressed concern and said that he would investigate the allegation.
[Insert name] made enquiries and in particular examined the test data and the working documents relating to the test data. He discovered that no inappropriate adjustments had been made to the test data.
It is denied that the Claimant heard nothing further about the matter; [insert name] met with the Claimant on [insert date] and explained the findings of his
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