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Sloppyness or dishonesty.
What Phil Jones meant, which would have been obvious if you didn't go with pre-digested quotes from someone who has an axe to grind, was that 15 years is slightly below the threshold of statistical significance.
It has indeed warmed significantly since 1995; but what does that warming mean if you're constrained to looking at only the 1995-2010 period? Nothing.
It's always possible to fit a linear regression to some short-term noise, but it's meaningless: http://woodfortrees.org/plot/hadcrut3vgl/from:2001/to:2009/trend/plot/hadcrut3vgl/from:1950/to:2010/plot/hadcrut3vgl/from:1989/to:1995/trend/plot/hadcrut3vgl/from:1973/to:1978/trend/plot/hadcrut3vgl/from:1981/to:1987/trend
(Very long link, hopefully it will parse correctly).