‘Yes.’

‘And Mast Twenty, owned by EE – that’s this mast right here, correct?’

Michael pointed to the map. To a second mast, perhaps an inch further away from the murder site. White checked his own papers.

‘Yes, Mr Devlin. That’s correct.’

‘How far is that mast from the site of the murder?’

‘Judging by the key, it looks to be just over half a mile.’

‘Can you tell me, is Mast Twenty closer to the site of the murders than Mast Twenty-two?’

‘No. It is not.’

‘What’s the difference in distance?’

‘Around half a mile again. Mast Twenty-two is less than two hundred yards from the scene of the murders.’

‘OK. In that case is Mast Twenty at least the second closest mast to the site of the murders?’

White took a few moments to look at his map. Michael could see White counting under his breath. He had anticipated the question that would follow his answer.

‘No, Mr Devlin. It is not the second closest mast.’

‘That’s interesting. I wonder, do you have any idea how many masts are in fact closer?’

‘Five, Mr Devlin. Mast Twenty is the sixth closest cell mast to the murder scene.’

Michael nodded his head as he glanced towards the jury. Most had started to look confused by the exchange. He needed to make sure that they were grasping the point.

All still a bit technical so far, he thought. So let’s make it crystal clear.

‘How can it be correct, Mr White, that Simon Kash’s phone use places him at the scene of the murder, when his telephone was ignored by the five cell masts closest to that location?’

‘As I explained very clearly to Mr Epstein, it is perfectly possible that Mast Twenty-two was at capacity. In those circumstances Mr Kash’s telephone would seek out the closest available cell site. The important word there is available. It is perfectly possible that Mast Twenty was the only one of the next five masts that was not at capacity.’

‘But you said earlier, Mr White, that each mast had three cell zones, and that it was very, very unlikely that a telephone signal would travel up to a mile before finding an available cell. Isn’t that right?’

‘It is, Mr Devlin, yes. But this wasn’t a mile, was it? It was half a mile. Plus you have to consider the number of masts. Look at the map in your hand. For some reason the Bromley area has far fewer masts than the average and so the phone’s signal has far fewer options. Plus each mast has to take on far more signals. All of this suggests that masts in this area are much more likely to reach capacity. Now I accept, of course, that Mast Twenty is not the ideal mast. But its use in no way suggests that Mr Kash’s phone was somewhere other than the murder site.’

Michael took a few moments, keeping his eyes on White, before responding. The expert witness clearly thought he had batted back the best point. Which was exactly what Michael wanted him to think.