01/07/2020, a FoIA request was made to Highways England:

I ask to be provided for the below 15 claims:

1. The Cost Breakdown Document (CBD)

The CBD will be in their original spreadsheet (Excel) format, with no alteration /amendments of the content and the cells will contain their references to associated/linked workbooks. These ‘workbooks’ have recently been referred to by your General Counsel, Tim Reardon as a schedule of rates.

2. The associated workbooks/worksheets referenced in each of the CBD’s.

3. If the workbooks/sheets are unavailable:
a. Why they cannot be produced i.e. why they were deleted/discarded
b. Why they cannot be located
c. When they were used, the date:
i. From and
ii. To

The 15 claim references are below, in the following format:
Loss Date
Kier Ref
Invoice number

25/03/2016
GC\024207
13255

11/02/2016
GC\023679
13740

31/05/2016
GC\025066
14349

28/11/2016
GC\027673
14882

27/04/2016
GC\028937
16128

06/10/2016
GC\026762
16621

24/10/2016
GC\027071
14671

24/08/2017
GC\031860
16750

25/05/2017
GC\030405
16930

24/03/2017
GC\029485
16938

28/02/2017
GC\029056
17193

07/05/2017
GC\034184
17246

13/04/2018
GC\045830
17543

01/01/2018
GC\033747
18700

02/01/2018
GC\033761
18170

Yours faithfully,

Mr P Swift