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By Daniel O'Donoghue
BBC News
Nurse Lucy Letby has accused hospital bosses of a "conspiracy" against her to cover up shortcomings on the neo-natal ward where she is accused of murder.
The 33-year-old is charged with murdering seven babies and attempting to murder 10 others at the Countess of Chester Hospital between 2015 and 2016.
She told her trial a "gang of four" doctors apportioned "blame" on to her "to cover up failings at the hospital".
Ms Letby denies all charges against her.
Prosecutor Nick Johnson KC, in cross examination, asked Ms Letby how she felt towards her former colleagues.
Asked about Dr Stephen Brearey, a consultant who demanded the defendant was taken off the unit in June 2016, Ms Letby said she did not have a problem with him at the time she was working with him.
Mr Johnson then directed the jury towards a note, found at Ms Letby's home, which had a profanity written on it.
Ms Letby has previously told the court this was written after she was removed from the unit and was directed at Dr Brearey and Dr Ravi Jayaram as they had been "making comments I was responsible for the deaths of babies".
Mr Johnson went on to ask Ms Letby if she felt there was a "conspiracy" against her, she agreed.
"Who is in the conspiracy group?," Mr Johnson asked.
She named Ravi Jayaram, Stephen Brearey, John Gibbs and another doctor who cannot be named for legal reasons.
"So the gang of four?," Mr Johnson said.
Mr Johnson asked what the conspiracy between the four was, and she said they had "apportioned blame onto me".
"I believe to cover up things at the hospital," she added.
Ms Letby was later asked about the death of a baby boy, Child A.
She told the court that if the cause of death was established as air embolus, then it would have come from the person connecting the fluids, "which wasn't me".
Mr Johnson also asked Ms Letby about insulin discovered in the blood of two babies in this case.
Ms Letby was asked if Child E was poisoned with insulin.
"Yes I agree that he had insulin," she said.
Mr Johnson asked: "Do you believe that somebody gave it to him unlawfully?"
Ms Letby said she did not know "where the insulin came from" and denied causing the baby any harm.
She also agreed that Child L was poisoned with insulin but added: "I don't know how the insulin got there."
"I don't believe that any member of staff on the unit would make a mistake in giving insulin," she said.
Earlier the court heard that a total of 257 nursing shift handover sheets, containing some of the names of her alleged victims, were found during police searches of her home following her arrest in July 2018.
She agreed with Mr Johnson that taking such sheets out of the hospital was not "normal practice" and they should be discarded in confidential waste.
"What were you thinking as this pile of handover sheets accumulated almost to the size of a phonebook," Mr Johnson asked.
The defendant said she did not know she "had that many".
'Keepsake box'
Mr Johnson put it to her that she was keeping the notes for her "little collection".
Ms Letby responded: "No."
She added: "I keep a lot of paper, I have a difficulty throwing anything anyway."
The former nurse said she had kept many items over the years, including cards, letters, notes and did not keep the handover sheets "because of the content".
Mr Johnson responded: "Are you really asking the jury to accept that pieces of paper with sensitive information about dead children on them were insignificant?"
The defendant responded: "Yes."
Mr Johnson then asked Ms Letby about a blood gas record chart relating to one of the babies in this case, which was also found at her home.
Mr Johnson accuses her of "fishing it out of the confidential waste bin".
She responded: "I never fished anything out of the confidential waste bin."
He said: "It was for your little collection, wasn't it?"
Mr Johnson went on to speak about a keepsake box in her former home in Chester, and asked her if she knew what was in it when police raided her home.
Ms Letby said: "I can't recall."
Mr Johnson explained to the jury that a "pristine" handover sheet, dated 1 June 2010, was found in the box.
He said this was Ms Letby's first day as a student nurse on the Countess of Chester neonatal unit.
Mr Johnson said the defendant was "not prepared to tell the truth about these handover sheets" but she responded saying "the truth is what I have told you".
Ms Letby was then asked about a sympathy card she sent to the grieving parents of a baby girl, Child I, who she allegedly murdered.
Inside, the defendant wrote: "There are no words to make this time any easier. It was a real privilege to care for [Child I] and get to know you as a family - a family who always put [Child I] first and did everything possible for her.
"She will always be part of your lives and we will never forget her.
"Thinking of you today and always. Lots of love Lucy x."
An image of the card and its inside message was recovered by police from Ms Letby's phone and GPS data confirmed that the image was taken on the neonatal unit, the trial heard.
Mr Johnson asked: "Why did you write the card at home, and then bring it to work and take a photo of it in the place where the baby had died in dreadful circumstances?"
Ms Letby responded: "The place is insignificant, I take photos of the majority of cards that I send. This was taken to give to the staff who were going to the funeral."
Mr Johnson asked her if she took the picture to "give you a bit of a thrill, taking a picture in the place where the child died?".
"Absolutely not," Ms Letby said.
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