Hard to tell what Jackson is focusing on really as his submission is spread across various heresay & anecdotal evidence, perhaps not even evidence at all of the charge reading it at face value. He appears to use Professor Gruden's observation/opinion of a riders testosterone level (I assume he looked at the teams quarterly testosterone results submitted to UCI) being 'elevated' at the same time period Freeman ordered Testogel, but ends the same submission saying the alleged rider is not possible to identify for reasons too deeply buried. So is that the rider with elevated levels? If so, what is buried, you have the rider, you have the steroidal module of his biological passport to refer at WADA to prove it easily, what's too deeply buried to prove? That suggests to me that neither the level was elevated enough to be a doping violation or high-enough to be medical malpractice. It's clearly not enough to worry the biological passport, WADA or UCI anyway!
Jackson also uses various other anecdotes such as Freeman was an ambitious Dr who lied to protect his status in the medical team, threatened by others ethics and didn't object to Nicole Cooks coach doing IV recovery. My understanding is Fabio was brought in precisely because the older riders complained the team didn't do IV recovery, so why Freeman would object to something coming down from we assume Steve Peters & Brailsford is all a bit subject to what is actually there to object to from both a medical and ethical view by Freeman? This was February 2011 yet Jackson implies all related to an order in May 2011. All we know is Fabio described the IV protocol as a black box with normal stuff. Who knows, as doping goes what that might be, it's all appearing very far removed from anything tangible when there's also plenty of opposing anecdotal evidence Freeman was protecting himself from Peters & Sutton too with the fabricated email etc.