INVESTIGATION: The Combe Grove Cover-Up—How a Whistleblower Was Sacked While a Halcyon Fraud Suspect Was Protected And Their Financials
A confidential source with in-depth knowledge has provided The Hindenburg Papers with a detailed account of the internal chaos at Combe Grove, the Bath wellness retreat owned by the Elmhurst Foundation charity. The account alleges a sustained campaign of intimidation, institutional failure, and a deliberate cover-up surrounding the employment of Joshua Pugh—a man linked to the €16 million Halcyon Retreat fraud.
The account concerns the former Membership and Coach House Manager at Combe Grove, who was dismissed this week for “bringing Combe Grove into disrepute” after raising concerns about Pugh. The former manager, a medically retired police officer, is appealing the decision according to sources. Our sources has spoken to The Hindenburg Papers on condition of strict anonymity.
“A Pathological Liar”: The Whistleblower’s Account
The former Membership and Coach House Manager was the first person to raise formal concerns about Joshua Pugh’s employment as Commercial Manager at Combe Grove. Pugh was his direct line supervisor. Almost immediately after Pugh joined, the manager caught him out on a number of lies. He considered Pugh to display traits of a pathological liar.
Shortly after starting, Pugh texted the manager late on a Friday evening asking if he was in the police, wanting to know his roles and where he worked. The manager is a medically retired police officer. Pugh had also provided Robin Barrasford as his referee when applying for the Combe Grove job. Barrasford—a former British police officer—was arrested in Spain in May 2026 and charged with investment fraud and organised money laundering in connection with the Halcyon Retreat scheme. The French fraud squad estimates that €16 million of investor funds were funnelled into offshore accounts, with work never beginning on the promised 358 luxury apartments and villas at the Château de la Cazine in Limousin.
Pugh distanced himself from Barrasford after the arrest, telling Combe Grove staff he left Halcyon when he realized it was a scam. Yet he continued to “like” Halcyon social media posts after he had left. He also told a member of staff he had been in touch with Barrasford, who had asked him to sell properties in Montenegro.
A Culture of Fear and “Kangaroo Courts”
Almost as soon as Pugh started at Combe Grove, he instigated a number of disciplinary actions against staff members. Once instigated, Pugh would distance himself from the process, claiming to be on the side of the person being investigated. Members of staff were demoted, had pay reduced, or were put under immense pressure. Many resigned, citing Pugh as their reason for leaving. Senior management, the source alleges, unquestioningly acted on Pugh’s say-so and were quick to set up what staff described as “kangaroo courts.”
One young female staff member was required to attend such a meeting and only by chance got the opportunity to ask the manager to be present as a support. Her alleged crime? A member of Combe Grove had reportedly seen her having her bottom touched by another member of staff. The manager asked why she was being treated in this way and why nobody was checking she was okay and whether it was consensual. Nobody knew who the reporting member was, but it had been reported to… Pugh.
The manager approached senior management, including the owner Helen Aylward-Smith, to voice his concerns about Pugh’s pathological lying, his instigating of disciplinary action against multiple staff, his connections with Halcyon, and the lack of due diligence before employing him. His concerns were ignored and dismissed.
Sexual Predatory Behaviour During Probation
A few weeks into his employment, Pugh displayed sexually predatory behaviour towards a young female member of staff. He arranged a staff “team building” night at a local bar. The manager did not attend, but he found out the next day that during the evening, Pugh had encouraged the female to drink shots and return to Combe Grove, where he was staying overnight in a room. The female left the bar early with another female colleague, feeling uncomfortable and unsafe. Pugh continued to send her texts, one of which encouraged her to join him and bring alcohol with a party face emoji so they could “get together.” She screenshotted the texts and ignored his requests. The next morning, he deleted his texts and told staff she was “paralytic” and he had been “concerned for her well-being.” This was not the case—the female was not drunk.
This female member of staff spoke to the manager, as the only member of management she felt she could trust, and he told her to report the incident to HR immediately, which she did. The manager asked that Pugh be asked to work from home to protect the investigation—this request was ignored by senior management. Pugh stayed at work and intimidated the female. A member of senior management encouraged the female to “make friends with Josh,” “act like an adult,” and “stay away from [the whistleblower] as he’s not her friend.” Pugh was also allowed to walk into a meeting she was having with HR and stand behind her whilst it was taking place. When she swore, she was chastised and instructed not to swear. She made a formal grievance against Pugh, which was later upheld. His punishment was a “stern talking to.”
This incident happened during Pugh’s probationary period—something the manager and other staff expressed concerns about. Again, this was ignored and dismissed by senior management, and Pugh passed his probationary period. The six-month probationary review was undertaken by the owner of Combe Grove.
The HR Trap: How the Whistleblower Was Sacked
The former manager had some communication with Jack Russell of the Facebook page REVIVE—Reimbursement for Victims of Investment Violations & Exploitation. The HR member of staff, Richard Gunn, asked the manager to supply all the information he had collated on Pugh. The manager supplied the information requested and shortly afterwards was suspended from Combe Grove based on the information he had provided and an “account” of a conversation the manager and HR had. The manager strongly disputes Richard Gunn’s recollection of the conversation and the accusations made against him.
Prior to suspension, a senior manager told a member of staff that the manager would be gone “within the month”—just before he reached his two-year employment mark. On suspension, the manager was immediately taken off all Combe Grove systems and told he was not allowed to communicate with anyone at the organisation. Staff were informed they would be disciplined if they had contact with him. During the disciplinary process, the manager was accused of being responsible for the earlier Hindenburg Papers article, communicating with Jack Russell of REVIVE, and creating a false Facebook account to post about Pugh and Combe Grove. At the hearing, they stated the information he had provided and made public informed the article.
The former manager has lost his job, his income, and mortgage offers in voicing his concerns about Joshua Pugh. According to the source, he cannot afford his rent now and is moving away to a new area.
The Halcyon Connection: More Questions Than Answers
The source raises a series of troubling questions that echo the findings of the earlier Hindenburg Papers investigation:
- Is there a scam going on at Combe Grove?
- Is Pugh investing money in Combe Grove? The retreat has had money issues for sure.
- Is it money laundering? By account, Pugh and his Halcyon friends have a lot of money hidden away.
- Is Pugh running down Combe Grove so he and his Halcyon mates can buy it at a cut-down price?
- Has he—and Jennifer Crossey—manipulated the owner?
- Where are the trustees in all this?
The source claims that Pugh has “a lot of money stashed away” and questions why he has taken on a £55,000 job which he clearly does not need and is incompetent at. Since he joined, retreat attendee numbers are down—everyone is so busy covering for staff who have resigned or trying to get ahead of disciplinary actions. There is a climate of fear.
Pugh has allegedly purchased stolen Watt bikes for the gym. They are still there, everyone knows, yet nothing is done about it. He has been placed behind bulletproof glass for some reason. Two weeks ago, Pugh came into work with a broken nose and two black eyes. He gave three different accounts to staff as to the cause. When asked, he said he wasn’t reporting it to the police.
Pugh claims not to smoke, yet regularly smokes on the strictly no-smoking grounds at Combe Grove. He often walks into the grounds for private calls and leaves work for “emergencies” of some sort, coming back very “happy.” The source asks: Sex or drugs?
The Enablers: Crossey, Gunn, and Southern Martin
The source identifies three senior figures as central to Pugh’s protection:
Jennifer Crossey—the Finance Director—is described as Pugh’s main supporter and enabler at Combe Grove. Staff understand that Pugh was brought into Combe Grove by Crossey, and they believe she had some connections with him prior to bringing him in, but they can find no evidence yet. She previously worked at Bath Rugby. It is believed Pugh visits her home address on the way to and from work. Her husband runs the Jane Austen Centre in Bath.
Richard Gunn—HR—got the manager suspended by asking for evidence the manager had been collating and giving a statement against him. The source alleges Gunn acts solely in Jennifer and Pugh’s interests.
Shelly Southern Martin—who the source has been told has failed her probation and is leaving—was a very active participant in Pugh’s strategies, but it is clear he used her as a scapegoat to cover for his own failings.
The owner, Helen Aylward-Smith, called a meeting of all staff recently and let it be known she firmly supports and trusts Pugh. She was critical of those who have questioned him or his recruitment and employment at Combe Grove. The manager approached the owner as soon as she returned from a four-month cruise—during which she left Jennifer Crossey in charge, who brought Pugh in whilst she was away. The manager expressed his concerns. Helen said “we need to speak”—and never spoke to him again. Prior to Crossey and Pugh arriving, the manager had a very good working relationship with the owner. He, along with other staff, had weekly meetings, and she micromanaged everything. These meetings stopped once Pugh arrived.
A Vulnerable Partner and a Troubling Past
The source also provides disturbing details about Pugh’s personal life:
- Pugh has a fiancée. He reportedly lives with her in Salisbury. She is described as a vulnerable person with mental health challenges. Pugh has stated she is bipolar. She has attended Combe Grove with multiple self-harm injuries on her arms. The source says it has the hallmarks of a coercive control relationship.
- Pugh is reportedly not allowed to have unsupervised contact with his young son due to a court order. He has one previous marriage.
- Pugh has a company called NJAC—a bar events company based in Salisbury. This concerns the source given his behaviour in trying to get a young female colleague to drink shots. NJAC Event Bars describes itself as an award-winning mobile bar service operating across Wiltshire, Hampshire, and Dorset.
- Pugh and his fiancée run Badger Quiz Co in pubs in Salisbury.
The Charity Commission and the Elmhurst Foundation
Staff have reported Combe Grove to the Charity Commission as they have concerns about the running of Combe Grove and its charity wing, the Elmhurst Foundation. The Commission is looking into it.
The Elmhurst Foundation is a registered charity (number 1163539) that purchased Combe Grove Manor in March 2017. Its charitable objectives are to promote and expand knowledge in the fields of health and wellbeing, provide high-quality enhanced apprenticeships, and share facilities for the benefit of the community. Helen Louise Aylward-Smith is listed as a director and board member of the Foundation.
Where are the trustees? The source asks. There are only three trustees, and the board composition appears to be very static with little diversity.
Following the Money: What the Elmhurst Foundation’s 2025 Accounts Actually Reveal
The Charity Commission’s full accounts for the Elmhurst Foundation (registered charity number 1163539), filed on 30 March 2026 for the year ending 31 March 2025, contain several disclosures that raise serious questions about the charity’s financial governance — and align closely with the allegations set out in the source’s email.
The Balance Sheet: A £6.3 Million Hole in “Debtors”
The most striking anomaly in the 2025 accounts is the explosion in “Debtors” — money owed to the charity. Group debtors surged from £1,247,925 in 2024 to £7,606,723 in 2025 — an increase of over £6.3 million in a single year. For the Foundation entity alone, debtors rose from £1,551,545 to £8,062,642.
This is not a normal fluctuation. A charity with a total annual income of roughly £3.5 million should not have £7.6 million sitting in unpaid debtors. To put this in perspective, the charity’s entire annual expenditure in 2024 was £3.5 million. The debtors figure is now more than double the charity’s annual spending.
The accounts do not reveal — at least not in the summary table — who owes this money or why. This is precisely the kind of figure that would appear in a “related party transactions” note to the accounts. If the debtors include loans to connected companies or individuals — for example, entities linked to Joshua Pugh, Jennifer Crossey, or the Halcyon network — that would represent a fundamental breach of charitable governance.
Creditors Doubled: £13.2 Million Now Due Within One Year
On the other side of the balance sheet, creditors falling due within one year more than doubled, from £6,758,649 in 2024 to £13,190,884 in 2025. The charity now owes more than £13 million in short-term liabilities — against cash at bank of just £4.87 million. Net current liabilities stand at negative £711,742 for the group, meaning the charity’s short-term obligations exceed its short-term assets.
The accounts also show two new charges (mortgages) registered on 22 August 2025 (charges 095445120003 and 095445120004), while two older charges were satisfied on the same date. This refinancing — likely against the Combe Grove property — may explain part of the creditor increase, but it does not explain the debtor explosion. If the charity borrowed money in August 2025 and simultaneously lent it out to a connected party, that would be a serious red flag.
The £454,000 Deficit: Worse Than the Giving is Great Summary Suggested
The group result for the year ending 31 August 2025 was a deficit of £454,349, compared to a surplus of £704,370 the previous year — a swing of over £1.15 million. This is broadly consistent with the Giving is Great data showing a £1.037 million deficit on a different accounting basis (year ending 31 March vs 31 August). Either way, the charity is haemorrhaging money at an accelerating rate.
The New “Person with Significant Control”: Andrew Ralph Gardner
On 7 July 2025, Andrew Ralph Gardner was appointed as a director of the Elmhurst Foundation and simultaneously registered as a Person with Significant Control (PSC01). On the same date, David James Cox ceased to be a PSC and his directorship was terminated.
This is a significant governance change that has not been publicly explained. Who is Andrew Ralph Gardner? What is his background? Why did he acquire significant control over a charity that owns a multi-million-pound property portfolio in Bath? And critically — what is his relationship, if any, to Joshua Pugh, Jennifer Crossey, or the Halcyon network?
David James Cox, who stepped down, is listed on Marketscreener as Chairman of BVG Group Ltd. and Director of Direct Online Services Holdings Ltd., among other roles. His departure from the Elmhurst Foundation board after a decade raises the question: was he pushed out, or did he leave voluntarily?
Trustee Composition: Still Just Three — And One New Name
The Giving is Great factsheet continues to show three trustees: David James Cox, Helen Louise Aylward-Smith (Chair), and Simon William Waterfield, all appointed in 2015. However, the Companies House filing history shows that David James Cox was terminated as a director on 14 January 2025, and Andrew Ralph Gardner was appointed on 7 July 2025.
This means that as of the 2025 accounts filing date (30 March 2026), the board composition had changed — but the Giving is Great data may be lagging. The key question remains: with Cox gone and Gardner in, what is the current governance structure? And who is Gardner?
What the Accounts Do Not Show — But Should
The summary balance sheet extracted from the Charity Commission register does not include the detailed notes to the accounts, which would normally disclose:
- Related party transactions — any loans, payments, or contracts between the charity and its trustees, directors, or their connected companies.
- The composition of debtors — who owes the £7.6 million, and whether any of it is recoverable.
- The nature of the new charges — who holds the mortgages registered in August 2025, on what terms, and what property they are secured against.
- Trustee remuneration — whether any trustee or connected party received payment for services.
- The going concern assessment — with net current liabilities of £711,742 and a £454,349 deficit, the trustees’ statement on going concern becomes critical. The Charity Commission register shows the trustees have stated they consider there to be “no material uncertainties” — but this assessment deserves scrutiny given the debtor position.
The £7.6 Million Question: What the Elmhurst Foundation’s Own Filings Reveal — and the Director Whose Date of Birth Was “Corrected”
A forensic examination of the Elmhurst Foundation’s filings at Companies House and the Charity Commission reveals a series of financial anomalies and governance red flags that align with the allegations set out in the source’s account.
The Financial Picture: A Charity in Freefall
The Foundation’s full accounts for the year ending 31 March 2025, filed on 30 March 2026, show a charity whose financial position has deteriorated dramatically.
The £7.6 million debtor black hole. The most alarming figure is the explosion in “Debtors” — money owed to the charity. Group debtors surged from £1,247,925 in 2024 to £7,606,723 in 2025 — an increase of over £6.3 million in a single year. For the Foundation entity alone, debtors rose from £1,551,545 to £8,062,642. A charity with a total annual income of roughly £3.5 million should not have £7.6 million sitting in unpaid debtors. The debtors figure is now more than double the charity’s annual spending.
The £13.2 million creditor mountain. Creditors falling due within one year more than doubled, from £6,758,649 in 2024 to £13,190,884 in 2025. The charity now owes more than £13 million in short-term liabilities — against cash at bank of just £4,872,420. Net current liabilities stand at negative £711,742 for the group, meaning the charity’s short-term obligations exceed its short-term assets.
The £454,000 deficit. The group result for the year was a deficit of £454,349, compared to a surplus of £704,370 the previous year — a swing of over £1.15 million. The Foundation entity itself recorded a deficit of £450,032.
The £1 million loss in the Giving is Great data. The Giving is Great factsheet shows a 2025 deficit of £1,037,000 on a different accounting basis (year ending 31 March vs 31 August). Either way, the charity is haemorrhaging money at an accelerating rate, and reserves have fallen from £5.3 million to £4.2 million in a single year.
The Mortgage Refinancing: What Was Secured in August 2025?
On 22 August 2025, two new charges were registered against the charity — charge numbers 095445120003 and 095445120004. On the same day, two older charges (095445120001 and 095445120002) were satisfied in full.
This simultaneous discharge and re-registration of charges on the Combe Grove property suggests a refinancing. The critical questions are: who is the new lender, on what terms, and why was this necessary? The accounts show creditors more than doubling in the same period, which is consistent with a new borrowing facility. If the charity borrowed money in August 2025 and simultaneously lent it out to a connected party — which would explain the £6.3 million surge in debtors — that would represent a fundamental breach of charitable governance.
The Director Whose Date of Birth Was “Corrected”
On 28 May 2026, a filing was made at Companies House with the description: “Correction of a date of birth incorrectly stated on incorporation / simon william waterfield”.
Simon William Waterfield has been a director of the Elmhurst Foundation since 15 April 2015 — the day the company was incorporated. His date of birth is listed as January 1960. The filing states that the date of birth was “incorrectly stated on incorporation” — meaning that for eleven years, the charity’s official record of its own founding director’s date of birth was wrong.
Who corrects a date of birth after eleven years? The filing raises the question of whether other information in the charity’s incorporation documents was also incorrect. The timing is notable: the correction was filed on 28 May 2026, just two months after the 2025 accounts were filed on 30 March 2026, and after the source’s allegations about governance failures at the charity had been raised.
The New “Person with Significant Control”: Andrew Ralph Gardner
On 7 July 2025, Andrew Ralph Gardner was appointed as a director of the Elmhurst Foundation and simultaneously registered as a Person with Significant Control (PSC01). His date of birth is listed as December 1962, and his place of residence is Wales. He holds “ownership of voting rights — more than 25% but not more than 50%”.
At the same time, David James Cox ceased to be a PSC and his directorship was terminated. Cox had been a director since incorporation and was listed as Chairman of BVG Group Ltd. and Director of Direct Online Services Holdings Ltd.. His departure after a decade raises the question: was he pushed out, or did he leave voluntarily?
The appointment of Andrew Ralph Gardner as a PSC is the single most significant governance change in the charity’s history. The Charity Commission’s register shows the Foundation is a private limited company by guarantee without share capital, which means there are no shares to own. The “voting rights” that Gardner now controls are the governance rights of the charity’s members — in effect, the right to appoint and remove trustees. Who is Andrew Ralph Gardner? Why was he brought in? And what is his connection, if any, to Joshua Pugh, Jennifer Crossey, or the Halcyon network?
Companies House records show only one other appointment for an Andrew Ralph Gardner (date of birth December 1962): a directorship at British Dressage (company number 03443026), where he served from 25 May 2000 to 7 June 2006. The correspondence address on that filing was William IV Wing, Itton Court, Itton, Chepstow, Gwent, NP16 6BW — in Wales, matching his stated place of residence on the Elmhurst Foundation filing. His occupation was listed as Company Secretary.
Trustee Composition: Three Men and a £24 Million Property Portfolio
The charity’s officers are now:
- Helen Louise Aylward-Smith — Director, appointed 15 April 2015, born May 1962, resides in the United Kingdom
- Andrew Ralph Gardner — Director, appointed 7 July 2025, born December 1962, resides in Wales
- Simon William Waterfield — Director, appointed 15 April 2015, born January 1960, resides in England
David James Cox resigned on 14 January 2025.
Three trustees — one of whom has been in place for eleven years with a date of birth that was only corrected in May 2026, one appointed in July 2025 with a single prior directorship at a dressage company, and the owner of Combe Grove. Between them, they control a charity with £24.2 million in fixed assets — including Combe Grove Manor and land.
What This Means for the Investigation
The financial data and governance filings now available paint a picture that is difficult to reconcile with the charity’s stated purpose. The key questions that the charity has not answered are:
- Who owes the £7.6 million in debtors? If these are loans to connected companies or individuals — for example, entities linked to Joshua Pugh or the Halcyon network — this would directly support the source’s suspicion about money laundering or asset stripping.
- Who holds the new mortgages registered in August 2025? The charge documents (MR01) would identify the lender. If the lender is connected to any of the individuals named in this investigation, that is a critical lead.
- Who is Andrew Ralph Gardner, and why does he control over 25% of the charity’s voting rights? His single prior directorship at a dressage company does not explain how he came to hold such significant control over a multi-million-pound property charity.
- Why was Simon Waterfield’s date of birth corrected after eleven years? Who noticed the error, and what prompted the correction to be filed in May 2026 — a decade after incorporation?
- Why has the Charity Commission not opened a public investigation? Staff have reportedly reported the charity to the Commission. The financial anomalies now visible in the charity’s own filings — the debtor explosion, the creditor surge, the negative net current liabilities — would normally trigger regulatory scrutiny.
The Money Trail: What This Suggests
Putting the pieces together:
- £7.6 million in debtors that appeared almost overnight
- £13.2 million in short-term creditors
- A new Person with Significant Control with no public explanation
- Two new mortgages registered in August 2025
- A £454,000 deficit and rapidly depleting reserves
The pattern is consistent with a charity that has either made substantial loans to connected parties, engaged in complex related-party transactions, or both. The debtor figure is the critical lead: if the £7.6 million includes loans to companies connected to Pugh, Crossey, or the Halcyon network, this would directly support the source’s suspicion that “JP is investing money in CG” or that “it’s money laundering.”
The Balance Sheet: A £7.6 Million Black Hole
The most glaring anomaly is the dramatic shift in the charity’s balance sheet between 2024 and 2025.
- Debtors Explosion: Group debtors surged from £1,247,925 in 2024 to £7,606,723 in 2025—an increase of over £6.3 million in a single year. For a charity with an annual income of roughly £3.5 million, having £7.6 million in unpaid debtors is highly irregular. This figure is more than double the charity’s annual expenditure.
- Creditor Surge: Creditors falling due within one year more than doubled, from £6,758,649 to £13,190,884. The charity now owes over £13 million in short-term liabilities against cash at bank of just £4,872,420.
- Negative Net Current Liabilities: The result is net current liabilities of £711,742 for the group, meaning short-term obligations exceed short-term assets. The Foundation entity alone shows net current liabilities of £343,786.
These figures are not normal fluctuations. They suggest the charity has either made substantial loans to connected parties or engaged in complex related-party transactions. The accounts do not disclose who owes this money, which is precisely the kind of information that should appear in the “related party transactions” note.
💸 The £454,000 Deficit: A Charity in Freefall
The group result for the year ending 31 August 2025 was a deficit of £454,349, compared to a surplus of £704,370 the previous year—a swing of over £1.15 million. The Foundation entity recorded a deficit of £450,032. This is consistent with the Giving is Great data showing a £1.037 million deficit on a different accounting basis. Either way, the charity is haemorrhaging money at an accelerating rate.
🔗 Related Party Transactions: A Web of Connected Companies
The accounts include a “Related party transactions” note that lists rent receivable from numerous connected companies. This is a significant red flag. The list includes:
- Rosewalks Limited
- Cheltenham Land Securities Limited
- Lenrock Limited
- Scotland Limited
- Y & M Estates
- Brantwood Management Services
- Allied Property Services
- Birchpark Investments Limited
- Lakeside Investments Limited
- Topsfield Developments Limited
- Consultancy 100 Limited
- Brantlegh Waste Limited
- Samsol Ltd
- Newmore Management Ltd
- Magen (and others)
Example entries from the related party transactions note:
- Rosewalks Limited: £2,583
- Y & M Estates: £6,458
- Topsfield Developments Limited: £5,117
The presence of so many related-party transactions—and the fact that the note continues beyond what is visible—strongly suggests the charity is financially entangled with a network of connected companies. This is precisely the kind of structure that could facilitate the movement of money out of the charity and into private hands.
Conclusion: A Pattern of Protection
The account provided to The Hindenburg Papers paints a picture of an institution in crisis—where a man with alleged links to one of Europe’s biggest property scams has been protected, promoted, and empowered, while the whistleblower who tried to stop him has been sacked, silenced, and driven out of his home.
The parallels with the Halcyon Retreat scandal are unmistakable. In both cases, investors and staff were promised something that was never delivered. In both cases, concerns were ignored. And in both cases, those who asked questions were punished.
The Hindenburg Papers has reached out to Combe Grove, the Elmhurst Foundation, Joshua Pugh, Jennifer Crossey, Richard Gunn, and Helen Aylward-Smith for comment. None had responded at the time of publication.
If you have information about Combe Grove, Joshua Pugh, or the Halcyon Retreat fraud, please contact us confidentially.
This investigation is based on a detailed account provided by confidential sources with direct knowledge of the events described. The source’s identity is known to The Hindenburg Papers but is being withheld to protect their safety and the safety of others. Allegations have not been independently verified by The Hindenburg Papers and should be treated as claims pending further investigation.