Lawyers acting for former Rehab boss Angela Kerins have demanded that the Public Accounts Committee (PAC) hand over all the material in their possession relating to her dealings with the spending watchdog.

She is suing chairman John McGuinness and the other 14 members of the committee for acting "illegally with intent to damage" her good name and reputation when she appeared before them in February.

PAC's legal advisers have been asked to produce all documentation including internal memos, voice recordings and phone data as part of Ms Kerins's High Court action for damages.

Ms Kerins was grilled for seven hours by PAC members who asked about salary, company car and bonuses, which she is claiming amounted to a deliberate witch hunt against her.

In July, her legal counsel, former Attorney General John Rogers, told the High Court that his client had suffered personal injury as a result and she had been hospitalised for 10 days.

Ms Kerins also lost her €240,000-a -year job and had her constitutional rights breached, it was claimed.

In a letter sent to the Office of the Parliamentary Legal Adviser on Tuesday, Ms Kerins's lawyers claimed "that the members of the PAC conducted themselves illegally with intent to damage" her personally. It is the former Rehab boss's case they were "motivated by bias" and "acting beyond their legal competence".

The lawyers are demanding discovery of all notes, records, memoranda, correspondence, reports and minutes in the possession of PAC members or their servants and agents, pertaining to Ms Kerins's committee appearance.

These also include voice recordings of discussions between PAC members held behind closed doors in a bid to establish what advice they had been given before Ms Kerins's appearance.

Included in the list of items are computer files and telephone records.

In an eight-page letter addressed to Ramona Quinn, a solicitor at the Office of the Parliamentary Legal Adviser, the former Rehab CEO's lawyers are seeking discovery of "records of any kind however maintained, whether electronically, in hard copy or in any other manner".

The demand for documents is broken into categories including:

How PAC set their terms of reference and the "precise subject" of examination when they decided to investigate payments to the Rehab Group and call its CEO to attend;

Recordings and minutes of meetings "whether in private or public session" when it made the decision to start enquiring about Rehab;

Documentation on the legal opinions sought and received by PAC before Ms Kerins's first appearance and the decision to recall her in April;

Minutes and recordings and correspondence relating to the PAC's application to the Dail Committee on Procedure and Privileges to compel Ms Kerins to attend before it.

Legal sources say that the parliamentary watchdog is likely to resist any attempt to obtain what legal advice it obtained on the grounds of client/ lawyer confidentiality.

It is expected that the case will be heard sometime next year.

Irish Independent