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Archived Transcript for 3 December 2001: Pages
1 to 50
1
1 Monday, 3rd December 2001
2 (10.00 am)
3 THE CHAIRMAN: Mr Garnham.
4 MR GARNHAM: Good morning, sir. Sir, two procedural matters
5 before we resume evidence this morning.
6 The first is you will recall on Friday that you
7 accepted my invitation to issue a summons against
8 Miss Anne Bristow requiring her to produce all relevant
9 documents in the possession of Haringey. Over the
10 weekend Haringey have produced a substantial bundle of
11 new material which runs on my count to an additional 263
12 relevant documents.
13 Sir, we are grateful to Miss Bristow for her efforts
14 over the weekend to provide that material.
15 Nevertheless, sir, we have the very greatest concern
16 about Haringey's failure to produce this documentation
17 earlier. There seem to us, sir, with the greatest of
18 respect only two possible reasons: either incompetence
19 on the part of Haringey Council or a deliberate attempt
20 to avoid their responsibilities to this Inquiry. These
21 new documentations, sir, particularly because of their
22 volume, pose a major challenge for this Inquiry. It
23 will take us some time to read, digest and analyse this
24 new material.
25 Sir, for our part we would decline to allow this
2
1 Inquiry to be derailed by the submission of this vast
2 quantity of new material so late in the day.
3 Accordingly, sir, with your leave we would propose to
4 continue with our current timetable for calling
5 witnesses, making what use of this new documentation as
6 we can and as we are able but reserving the right to
7 recall every one of the Haringey witnesses we see fit to
8 deal with the matters arising out of the new material.
9 A good illustration of the difficulty that
10 Haringey's actions have put this Inquiry in is
11 demonstrated by the evidence of Ms Kozinos and the
12 Ben Brown report produced on Friday. Ms Kozinos's
13 counsel has made representations to me this morning that
14 late disclosure of this document and the complete
15 failure until this weekend to disclose the material
16 referred to in that report puts her in an entirely
17 unfair position. Her professional reputation is on the
18 line and she is being allowed or invited because of
19 Haringey's actions to deal with that criticism in a way
20 that prevents her from preparing for that properly.
21 That seems to us, sir, a point of real substance.
22 We propose, therefore, consistent with the approach
23 I have just outlined, not to ask Ms Kozinos about the
24 Brown report at all this morning, but to invite her to
25 give us a supplementary statement dealing with the
3
1 matters raised in that report. We will then consider
2 how best to use both Brown's report and Kozinos's
3 response.
4 Sir, that is the first procedural matter I wanted to
5 raise. The second concerns one of the witnesses who we
6 had listed to call this morning, Miss Carole Baptiste.
7 Sir, you will appreciate that she is a witness of some
8 importance to the matters to be addressed by this
9 Inquiry. Sir, the Inquiry was informed on 6th June that
10 Miss Baptiste had instructed solicitors. Those
11 solicitors asked for an extension of time for service of
12 their client's statement until 13th June and you, sir,
13 granted that extension. On 8th June a further extension
14 was sought, and granted until 3rd July. On 17th July we
15 were told that Miss Baptiste was too ill to participate.
16 We were not prepared to accept that bald assertion by
17 Miss Baptiste and asked for a report from her own
18 psychiatrist. Sir, that report or the information we
19 received in relation to that report revealed that
20 Miss Baptiste was in fact fit to attend and give
21 evidence.
22 Accordingly, sir, on 28th August a summons requiring
23 Miss Baptiste's attendance to this Inquiry was served on
24 her solicitors. Her solicitors informed us by telephone
25 that they did not have instructions to accept service of
4
1 a summons and required, perfectly properly in those
2 circumstances, to serve the summons direct on their
3 client.
4 Sir, that proved a difficult task, a difficult task
5 indeed. But in fact it was achieved on 27th November
6 when the process server found Miss Baptiste and served
7 the summons on her personally by hand.
8 Sir, because we regard Miss Baptiste's evidence as
9 important we thought it right to contact her solicitors
10 again once that service had been effected, with a view
11 even at this late stage, to obtaining her cooperation.
12 We suggested that if she were to indicate cooperation
13 and to provide us with a statement and agree to attend
14 then you might look kindly on an application even that
15 late for a recommendation to the Secretary of State,
16 that the Secretary of State meet her legal costs.
17 We also mooted with Miss Baptiste's solicitors the
18 possibility of us giving her a yet further extension of
19 time to prepare her case by moving the listing for her
20 being called to give evidence from this morning to next
21 Monday, giving her a further week and a chance for her
22 solicitor and counsel to prepare.
23 In the end, that suggestion did not meet with
24 Miss Baptiste's approval, as a result of which we
25 informed her and her solicitors in writing that the
5
1 summons would stand and that she would be required to
2 attend this morning. She has failed to attend, sir.
3 She is therefore in breach of the summons and in my
4 submission the proper course for you to adopt now is to
5 give instructions to the Solicitor to the Inquiry to lay
6 any information before the magistrates alleging
7 a failure by her in breach of her obligations, and we
8 would then allow the criminal proceedings to take their
9 course against Miss Baptiste.
10 One final consequence of that would be that in my
11 submission it would be open to you, sir, to draw every
12 proper inference contrary to Miss Baptiste as you see
13 fit in the light of her failure to attend and her
14 failure to take advantage of any of the numerous
15 opportunities you have given her to co-operate with this
16 Inquiry.
17 THE CHAIRMAN: Thank you. Thank you very much indeed,
18 Mr Garnham. I will comment on both of those matters in
19 turn.
20 Firstly, I am of course glad that Haringey has now
21 produced this great volume of 263 documents, even at
22 this very late hour. I regard that as an indication of
23 something that I believe to be totally unacceptable, in
24 that this Inquiry was announced in the early part of
25 this year, letters were sent to all the interested
6
1 parties, and it was clear that Haringey was a very key
2 interested party in May and June, and here we are almost
3 at the end of the year, and when we have key witnesses
4 before us, receiving this volume of late material.
5 This is not only unfair to the other interested
6 parties, and indeed unfair to the witnesses; it is
7 detrimental to the work of the Inquiry. Whilst I have
8 had chance to look at a very long letter from Mr Lloyd,
9 the Solicitor to the Inquiry, and he indicates that
10 criticisms can fairly be made at Haringey, I have to say
11 that I have seen no reason, no acceptable reason as to
12 why these documents were not produced a great deal
13 earlier.
14 I am content, Mr Garnham, to follow the course of
15 action that you intend.
16 With regard to Miss Baptiste, I would like to make
17 it plain that this Inquiry has been punctilious in the
18 way that we have handled Miss Baptiste. I am satisfied
19 that we have taken every action that is available to us
20 to help her to get to this Inquiry to give her evidence.
21 She is a very important witness. Her behaviour is, to
22 put it mildly, entirely unacceptable. She has exhausted
23 my patience and I suspect that of others and without
24 reservation of any kind I instruct that the solicitor
25 now lay information before a magistrate's court so that
7
1 criminal proceedings can be taken and I hope that these
2 proceedings will be pursued as vigorously as possible.
3 Mr Garnham.
4 MR GARNHAM: Thank you sir. May I ask Ms Kozinos to return
5 to the witness chair, please.
6 MS ROSEMARIE KOZINOS (continued)
7 MR GARNHAM: Good morning Ms Kozinos. When the Inquiry was
8 adjourned on Friday you will recall we were dealing with
9 the events of 5th November.
10 MS KOZINOS: Yes.
11 MR GARNHAM: Before returning to them there are just one or
12 two additional questions I want to ask you about the
13 events of 2nd November. Do you recall that?
14 MS KOZINOS: Yes.
15 MR GARNHAM: That is the occasion when Kouao and Victoria
16 returned to your offices to withdraw the allegations of
17 sexual abuse.
18 MS KOZINOS: Yes.
19 MR GARNHAM: First, this arises out of paragraph 21 of your
20 statement which I think you have in front of you.
21 MS KOZINOS: Which paragraph?
22 MR GARNHAM: 21. It is a lengthy paragraph and you will
23 want page 14 of the statement. About six lines down do
24 you see where you tell us:
25 "She told me that Victoria had told her when they
8
1 returned home that she had lied and did not want Carl
2 (Manning) arrested."
3 Do you see that, six lines down on page 14?
4 MS KOZINOS: Yes.
5 MR GARNHAM: Do you see that?
6 MS KOZINOS: Yes.
7 MR GARNHAM: Presumably the first "she" in that sentence,
8 "She told me ...", is Kouao?
9 MS KOZINOS: Yes.
10 MR GARNHAM: The second "she", "... when they returned home
11 that she had lied ..." is presumably Victoria?
12 MS KOZINOS: Yes.
13 MR GARNHAM: It reads as if the words "and did not want Carl
14 (Manning) arrested" are attributed to Victoria. Is that
15 what you intended or are they attributed to Kouao?
16 MS KOZINOS: Kouao blames -- that she did not want him
17 arrested, Victoria did not want him arrested.
18 MR GARNHAM: So Kouao was saying that Victoria said that
19 she, Victoria, did not want Manning arrested?
20 MS KOZINOS: Yes.
21 MR GARNHAM: Thank you very much. Second, about eleven
22 lines further down on page 14, halfway down the page do
23 you see the words:
24 "The social worker had told me she was concerned
25 that Ms Kouao was using her child to gain housing and
9
1 had made allegations of sexual abuse to support the
2 application."
3 MS KOZINOS: Which bit?
4 MR GARNHAM: It begins, "The social worker ..." It is about
5 midway between the two bullet holes on my page.
6 MS KOZINOS: I have it.
7 MR GARNHAM: Who is the social worker, is that
8 Lisa Arthurworrey?
9 MS KOZINOS: That is right.
10 MR GARNHAM: When did she tell you that?
11 MS KOZINOS: It was on the day before.
12 MR GARNHAM: So on 1st November?
13 MS KOZINOS: That is right.
14 MR GARNHAM: Did you record that anywhere in the notes?
15 MS KOZINOS: On the day before?
16 MR GARNHAM: Anywhere in the notes?
17 MS KOZINOS: No -- well on here, apart from this note.
18 MR GARNHAM: Apart from the -- why do you not recall that?
19 Might it not have been an important addition to the
20 record, the fact that the social worker involved thought
21 that the woman was attempting to use the child?
22 MS KOZINOS: I am not sure if I got this information from
23 Lisa or if it was via Carole Baptiste when we discussed
24 the strategy --
25 MR GARNHAM: That is why I asked you who the social worker
10
1 was.
2 MS KOZINOS: Lisa.
3 MR GARNHAM: Are you now saying that it was she who told you
4 that?
5 MS KOZINOS: I am not -- from recollection, and I am a bit
6 vague whether it was Lisa or whether it was Carole when
7 we discussed it when she asked me to reiterate the Child
8 Protection Procedures to Ms Kouao the previous day but
9 it was said.
10 MR GARNHAM: It was certainly at that stage before the
11 strategy meeting?
12 MS KOZINOS: Yes.
13 MR GARNHAM: In that case can I ask you to look at
14 paragraph 26 of your statement, please. About five or
15 six lines down in paragraph 26, I think when you are
16 talking about the strategy meeting on the 5th, you say:
17 "I remember at that stage Lisa Arthurworrey told me
18 that she thought Ms Kouao's complaints were an attempt
19 to get rehoused."
20 MS KOZINOS: Yes.
21 MR GARNHAM: Does that mean you are told that twice?
22 MS KOZINOS: Yes but I am not sure if the first time was
23 from Carole when we discussed -- when she asked me to go
24 out to speak to Ms Kouao about the Child Protection
25 Procedures.
11
1 MR GARNHAM: In any event, what you were told by
2 Lisa Arthurworrey during the course of the strategy
3 meeting did not come as news to you because you knew
4 that was her view from this meetings --
5 MS KOZINOS: Yes, it was a concern she raised, a suspicion.
6 MR GARNHAM: The same page, about four lines from the
7 bottom, you say -- this is four lines from the bottom of
8 page 14. Four lines from the bottom you are describing
9 what you said to Kouao during your meeting with her and
10 you say:
11 "I said that the allocated social worker would
12 complete a full family assessment and the case would go
13 to case conference."
14 That is what you told Kouao, is it?
15 MS KOZINOS: Yes.
16 MR GARNHAM: So at that point you regarded a case conference
17 in this case as inevitable?
18 MS KOZINOS: Yes, because of her explanation and the
19 concerns raised by them.
20 MR GARNHAM: Thank you very much. The fourth of these
21 preliminary points, Ms Kozinos, is this: you say in the
22 sentence that follows what we have just looked at that
23 during that interview with Kouao on 2nd November you
24 asked her to find alternative accommodation and Kouao
25 told you that she would be going straight to the
12
1 Kimbidimas' house.
2 MS KOZINOS: Yes, back to the Kimbidima house.
3 MR GARNHAM: Back to the Kimbidima house.
4 MS KOZINOS: Because that is where she was from the previous
5 day.
6 MR GARNHAM: I see, thank you. You do not actually say that
7 in that part of your text here, the word "back" is
8 a word you have added now.
9 "I asked Ms Kouao to find alternative accommodation
10 whilst we investigated as it was inappropriate for her
11 to continue to live with Manning. Ms Kouao insisted she
12 could protect Victoria and said she was going straight
13 to her friends' house to stay. The friends were Julian
14 and Chantelle whose address was on file."
15 That reads to me, but correct me if I am wrong, as
16 if you are telling us that was the first occasion on
17 which she had gone to live with ...
18 MS KOZINOS: Yes, sorry it is the way I have written it. I
19 knew that because I funded the cab the previous day.
20 MR GARNHAM: It is poor expression there. You do
21 acknowledge you knew from the previous occasion that
22 Victoria and Kouao were going?
23 MS KOZINOS: And I was just confirming that is where she had
24 to stay while we investigated.
25 MR GARNHAM: Thank you very much. Does that mean that you
13
1 repeated to Kouao on this occasion the same advice,
2 namely that she could not continue living with Manning?
3 MS KOZINOS: Absolutely.
4 MR GARNHAM: And that she needed to find alternative
5 accommodation to live in in order to protect Victoria?
6 MS KOZINOS: Yes, that she could not have any contact
7 with -- Victoria could not have any contact with him
8 while we investigated.
9 MR GARNHAM: Thank you very much. Go on to paragraph 23,
10 please. The third sentence of paragraph 23, third
11 sentence:
12 "After the interview, later on that same day,
13 I fully updated the Team Manager Carole Baptiste.
14 Carole Baptiste told me that Lisa Arthurworrey felt the
15 child's answers were totally rehearsed."
16 Then there is a description of that conversation.
17 Then you say:
18 "I wrote up the brief interview on a summary sheet
19 known as SS5 which updated Carole Baptiste and was
20 placed on the file."
21 Do you see that?
22 MS KOZINOS: Yes.
23 MR GARNHAM: Just turn back, will you, to paragraph 21.
24 That is where you start your description of events on
25 2nd November.
14
1 MS KOZINOS: Yes.
2 MR GARNHAM: You tell us about the conversation you had with
3 Kouao when she retracted the allegations of sexual
4 abuse.
5 MS KOZINOS: Yes.
6 MR GARNHAM: Then you say about four lines from the bottom
7 of that page:
8 "I made a full note of that visit immediately
9 afterwards."
10 Is that a reference to the same note, namely the one
11 you made on the SS5 sheet?
12 MS KOZINOS: Yes, I would write it up in note form, in
13 rough, then put it neatly on an SS5, because I take
14 notes on a notebook.
15 MR GARNHAM: The reason I ask, and perhaps you have just
16 given us some indication of the explanation, is that
17 when you first described making those notes you describe
18 them as happening immediately after your conversation
19 with Kouao. The second time you mention making that
20 note you say you did it after the conversation with
21 Kouao and after updating Baptiste. I wanted to know
22 which is accurate.
23 MS KOZINOS: What we normally do is take notebooks with us
24 in interviews and we make notes, and when we finish the
25 interview we make notes. We do not write it out neat
15
1 with the service user. Then I wrote it up neater on the
2 SS5.
3 MR GARNHAM: After the meeting with Baptiste?
4 MS KOZINOS: I think actually it was before. I have not got
5 a clear recollection but the notes were written up that
6 day.
7 MR GARNHAM: So should we read paragraph 23 amended so that
8 we understand your evidence to be that you made the SS5
9 note after the conversation with Kouao but before the
10 meeting with Baptiste?
11 MS KOZINOS: And that is my normal practice, particularly if
12 it is a case that is not mine, because then I have to go
13 on duty and deal with other matters.
14 MR GARNHAM: Yes. You nodded in answer to my question and
15 that means we do not record it but you are saying yes to
16 my assertion?
17 MS KOZINOS: Yes. It would have been given to Carole.
18 MR GARNHAM: Thank you very much. Can we then turn to
19 events of 5th November which is where we had got to.
20 MS KOZINOS: Yes.
21 MR GARNHAM: You told us on Friday, when we began discussing
22 the events of that day, that you were asked to chair the
23 strategy meeting as a favour to Carole Baptiste. You
24 say in paragraph 24 of your statement, if you want to
25 look at it:
16
1 "By this stage it was not unusual for
2 Carole Baptiste to ask me to take on jobs for her."
3 We began discussing this on Friday but let me ask
4 you again: how often, at this stage, November 1999, were
5 you being asked to do favours for Carole Baptiste?
6 MS KOZINOS: It varied then increased and sometimes I would
7 not do them and sometimes I did.
8 MR GARNHAM: Is it once every month or once a day that you
9 were doing her job?
10 MS KOZINOS: Once every other day.
11 MR GARNHAM: Thank you. What did that tell you about
12 Carole Baptiste's competence as a manager that she was
13 needing to ask you every other day to do one of her jobs
14 for her?
15 MS KOZINOS: It was more about her availability and
16 commitment.
17 MR GARNHAM: What did it tell you about her availability and
18 commitment then?
19 MS KOZINOS: That it was poor, as I said previously on
20 Friday, because it had an impact on me.
21 MR GARNHAM: Yes. It had an impact on you because there you
22 were as a senior practitioner being asked on a regular
23 basis to do the jobs of a team manager because the team
24 manager was not available.
25 MS KOZINOS: Yes, it could be put like that.
17
1 MR GARNHAM: You tell us, in paragraph 25 of your statement,
2 that:
3 "... it was decided that a memorandum interview
4 would not be pursued at that stage."
5 MS KOZINOS: Yes.
6 MR GARNHAM: Why not?
7 MS KOZINOS: Because for several reasons. First of all,
8 there was a reluctance for police involvement.
9 MR GARNHAM: There was a reluctance for police involvement.
10 What do you mean?
11 MS KOZINOS: Ms Kouao had stated earlier that she did not
12 want the police involved or that Victoria had also
13 expressed that she did not want Carl Manning arrested.
14 MR GARNHAM: Why is that relevant?
15 MS KOZINOS: Because it is about the wishes and feelings of
16 the child and what we normally do with memorandums and
17 it is not uncommon to run strategy meetings not at this
18 stage, it is not saying it rules out the possibility at
19 all --
20 MR GARNHAM: I am a little concerned about that. Let me ask
21 about that. If you have a mother attending with her
22 child reporting sexual abuse by the mother's partner and
23 the mother says, "Oh, the child does not want to pursue
24 this", you regard that, do you, as a reason for not
25 involving the police?
18
1 MS KOZINOS: No, not at all, because although it was
2 Ms Kouao who had retracted the allegations, Victoria had
3 not.
4 MR GARNHAM: No, quite.
5 MS KOZINOS: So what we decided, if you look at one of my
6 decisions, is actually to talk to Victoria, and why
7 I say it is not uncommon to talk to a child first before
8 we pursue with the memorandum interview and that so they
9 fully understand it, so they are aware of the process,
10 and if it is something they want to do.
11 MR GARNHAM: But surely Ms Kozinos there was already, by
12 that stage, ample grounds for requiring a memorandum
13 interview.
14 MS KOZINOS: I am not saying it did not require a memorandum
15 interview, I am saying at that stage, which was
16 a strategy meeting for immediate action, it was to first
17 talk to Victoria and it is one of my recommendations: we
18 needed to go round and talk and ascertain what she
19 wanted to explain to her, because nothing was explained
20 to her the previous day from my understanding from the
21 strategy meeting.
22 MR GARNHAM: Yes. But when did you have in mind the
23 memorandum interview taking place then?
24 MS KOZINOS: The decision would have been made after our
25 risk assessment on the day.
19
1 MR GARNHAM: I am still not sure that I understand why you
2 were not involving the police then and there.
3 MS KOZINOS: What you do you mean I was not -- the police
4 were involved, they were part of the joint
5 decision-making, it was a joint investigation.
6 MR GARNHAM: But I think you were saying to us that the
7 reason you thought better of holding a memorandum
8 interview straight away was because of reservations
9 about reporting the matter to the police.
10 MS KOZINOS: No, it was a decision we both made that we
11 needed to speak to Victoria to explain and decide she
12 was fully aware of what a memorandum interview was,
13 because they can be quite horrific in themselves.
14 MR GARNHAM: So you had in mind then that the memorandum
15 interview would happen very shortly thereafter?
16 MS KOZINOS: After speaking to Victoria and the memorandum
17 depending what the child said would also determine the
18 medical.
19 MR GARNHAM: But for either of those reasons the memorandum
20 interview would have to take place fairly promptly after
21 the strategy meeting even if you are allowing time for
22 Victoria to be seen first?
23 MS KOZINOS: Yes.
24 MR GARNHAM: Because on any view there were serious concerns
25 either way, either the allegation was true or else
20
1 Victoria was being used?
2 MS KOZINOS: Of course.
3 MR GARNHAM: Victoria had been spoken to about the
4 allegation, had she not, on 1st November?
5 MS KOZINOS: She had.
6 MR GARNHAM: So what more needed to be done before this
7 memorandum interview could go ahead?
8 MS KOZINOS: My understanding from the strategy meeting is
9 that it was a brief discussion and they had cut her off
10 and that the worker at the time felt it was very
11 rehearsed.
12 MR GARNHAM: Yes, that was Lisa Arthurworrey.
13 MS KOZINOS: That is right. But nothing was explained to
14 Victoria at all, apart from "We will get back to you at
15 a later stage".
16 MR GARNHAM: But as I understand the position,
17 Lisa Arthurworrey did not want to go ahead with
18 a detailed conversation with Victoria on 1st November,
19 because she thought what was required was a memorandum
20 interview. Is that not right, that the reason she was
21 cut off was because the social worker did not want, by
22 that means, to damage any evidence that came out of the
23 revelations?
24 MS KOZINOS: I am not too sure about that.
25 MR GARNHAM: I am not quite sure why you need a second
21
1 conversation with Victoria before you proceed to
2 memorandum interview.
3 MS KOZINOS: Because the impression I got from the worker is
4 she felt it was rehearsed and that there was not much
5 exploration or that it was seen that it was rehearsed in
6 an attempt to gain housing, and not much more thought
7 had been put into that.
8 MR GARNHAM: Was that not enough to trigger a decision to
9 hold a memorandum interview? Did you need to do any
10 more?
11 MS KOZINOS: Yes, we needed to go back and speak to the
12 child. She was not given the opportunity or explained
13 anything of the process in terms of a memorandum or what
14 an investigation would need. Good practice dictates we
15 do talk to children. We do not do things without
16 discussing and making them aware of the investigation.
17 MR GARNHAM: I see. So you were certainly of the view that
18 what ought to happen promptly after the strategy meeting
19 was Victoria should be seen for this second brief
20 conversation and then a memorandum interview should
21 promptly follow that?
22 MS KOZINOS: Yes, and explain the procedures and the
23 possible medical, depending what she said.
24 MR GARNHAM: You recommended in the strategy meeting
25 decisions that Jones and Arthurworrey talk to Victoria
22
1 alone about the allegations as part of their Section 47
2 investigation, is that right?
3 MS KOZINOS: They needed to talk to the child alone, yes, it
4 would have been part of that risk assessment, that
5 investigation.
6 MR GARNHAM: Then a decision as to whether or not
7 a memorandum interview should follow would be made?
8 MS KOZINOS: Depending on how Victoria felt, yes it was
9 dependent a lot on that risk assessment.
10 MR GARNHAM: Will you have volume 6, please, page 87. That
11 is the list of decisions of that strategy meeting.
12 MS KOZINOS: That is right.
13 MR GARNHAM: Do we see anywhere there a reference to the
14 talk at paragraph 8 being the means of deciding whether
15 or not to hold a memorandum interview?
16 MS KOZINOS: Well, it is in relation to number 8, "Talk to
17 the child".
18 MR GARNHAM: But it does not say, does it, "And use that
19 discussion to decide whether or not to proceed with
20 a memorandum interview"?
21 MS KOZINOS: No, but this is not a verbatim account of the
22 strategy meeting. There was full discussions. These
23 are just some of the decisions made from it. It was
24 fully discussed.
25 MR GARNHAM: Why is there no record of your reasons for not
23
1 directing a memorandum interview then and for suggesting
2 that it be reconsidered after the conversation with
3 Victoria? Why is there no record of that?
4 MS KOZINOS: Because like I said it is not a verbatim
5 account. I accept, no, there is not anywhere that says
6 it and at the time I put "not at this stage" which
7 I felt was sufficient. But no, I did not record the
8 reasons.
9 MR GARNHAM: Should you have done?
10 MS KOZINOS: We did not normally do, no.
11 MR GARNHAM: So that somebody looking at the file afterwards
12 could understand the reasons that you have now explained
13 to us as to why the decision to hold a memorandum
14 interview should await this conversation with the child?
15 MS KOZINOS: But the people working from the file are the
16 same two people who are also at the strategy meeting
17 that have taken part in this discussion and the joint
18 decisions.
19 MR GARNHAM: I see, but it is possible, is it not, that
20 things may change and someone else may have to pick up
21 this file and know what is going on?
22 MS KOZINOS: That is possible.
23 MR GARNHAM: And it is possible for example that the
24 supervising manager may change and need to pick up this
25 file and find out what is going on?
24
1 MS KOZINOS: But at the time the team manager and the social
2 worker and the police officer were present and as far as
3 I understood they were the ones that were carrying out
4 the work.
5 MR GARNHAM: But it is possible, as I say, is it not, that
6 any of those may change so that if you do not record
7 this they may not know about it?
8 MS KOZINOS: One of them would know about it. It is not
9 likely that all three would change.
10 MR GARNHAM: I see. But do you not see that nonetheless it
11 is good practice to record that sort of decision on your
12 records?
13 MS KOZINOS: No, I accept that and in hindsight it would
14 have been a lot clearer now if it had been recorded.
15 MR GARNHAM: Yes. You regard it as appropriate for social
16 workers to talk to children prior to the memorandum
17 interview, you told us, and you say that in fact was
18 standard practice?
19 MS KOZINOS: Yes it was.
20 MR GARNHAM: Was there any concern in your team that such
21 a conversation might damage the evidence from the child
22 later on? The reason I ask is because that has been
23 suggested by the police as a reason why they would not
24 talk to a child.
25 MS KOZINOS: It was not so much going into the evidence but
25
1 it was more about trying to ascertain in terms of the
2 child whether it was a good way to go forward, whether
3 they wanted to. A lot of children -- a lot of decisions
4 are made about memorandum but it does not necessarily
5 mean that the child is fully aware. They need to know
6 that there is also possibility if it does go to court
7 that it can be used as evidence and cross-examined and
8 it is only fair I feel and good practice to always
9 inform a child as well as the non-abusing parent.
10 MR GARNHAM: But in order to gain the information from
11 Victoria would you need to decide whether or not this
12 case should go forward to a memorandum interview? Would
13 you not need to ask her about the allegation she had
14 made?
15 MS KOZINOS: You need to make some form of an assessment.
16 MR GARNHAM: And that would involve asking her about the
17 allegations?
18 MS KOZINOS: Not too much about the allegations, you would
19 not ask her to keep repeating the allegations.
20 MR GARNHAM: But you would ask her about it once, would you?
21 MS KOZINOS: You would get an indication, yes? We already
22 know this child has already disclosed whatever --
23 whether the social worker felt it was rehearsed or not,
24 you had a child that had said an allegation, so we have
25 established that fact, yes? It is whether -- it is to
26
1 make an assessment.
2 MR GARNHAM: Of?
3 MS KOZINOS: Of Victoria and also whether she wanted to go
4 ahead for the memorandum interview. It is not to
5 re-examine or re-examine her allegations.
6 MR GARNHAM: Right. So tell me how you would do it. What
7 would you say to Victoria?
8 MS KOZINOS: You would explain to her from what she had said
9 the previous day, you would explain to her the process.
10 MR GARNHAM: Yes.
11 MS KOZINOS: And ascertain her wishes and feelings about it.
12 MR GARNHAM: So you would say, "What would you like to do
13 about it"?
14 MS KOZINOS: You would reassure her she would be safe.
15 MR GARNHAM: And you would say, "What would you like to do
16 about it, Victoria?", would you?
17 MS KOZINOS: You would tell her the options.
18 MR GARNHAM: They would be?
19 MS KOZINOS: That she can speak to the social worker, she
20 can do a memorandum.
21 MR GARNHAM: She would not know what a memorandum was, would
22 she, so what would you say to her?
23 MS KOZINOS: You would explain the whole process of
24 memorandum, it is about giving evidence and about how it
25 is done, where it is done, who does it, something about
27
1 the environment, who has access to that information.
2 MR GARNHAM: And the purpose for which it is gathered?
3 MS KOZINOS: And the purpose and what the possible outcomes
4 could be.
5 MR GARNHAM: Then what would you say to her? "Do you want
6 to do that?"
7 MS KOZINOS: Yes, you would ascertain whether she could or
8 wanted to, and there are things you would need to take
9 into consideration like language. In this case
10 Victoria's first language was not English, it was
11 French, so we would have to do the memorandum in French.
12 MR GARNHAM: Was there any reason why any of that could not
13 have been done when Victoria was in the office on
14 1st November or 2nd November?
15 MS KOZINOS: But it had not been done.
16 MR GARNHAM: But there is no reason why it could not have
17 been done?
18 MS KOZINOS: It could have been done, that is right.
19 MR GARNHAM: You say that you felt Victoria was being
20 bullied.
21 MS KOZINOS: Yes.
22 MR GARNHAM: Did you report that to the meeting?
23 MS KOZINOS: Yes.
24 MR GARNHAM: Lisa Arthurworrey says in her statement and has
25 said to us in evidence that you did not do so but she is
28
1 wrong about that, is she?
2 MS KOZINOS: Yes.
3 MR GARNHAM: Did you tell the strategy meeting it was
4 obvious that Kouao was trying to get housing and that
5 the ploy had backfired?
6 MS KOZINOS: No.
7 MR GARNHAM: Again Lisa Arthurworrey says that you did.
8 MS KOZINOS: No, I strongly dispute that.
9 MR GARNHAM: Because that would be a dangerous allegation to
10 make, would it not?
11 MS KOZINOS: What we said was an allegation had been made,
12 right? Regardless of whether it did happen or did not,
13 we had a duty to investigate and that is why Section 47,
14 which was agreed by everybody in that meeting, was
15 instigated.
16 MR GARNHAM: You have told us that the SS5 document was
17 written up by you on 2nd November. So it would have
18 been available for the strategy meeting on 5th November.
19 MS KOZINOS: It should have been on the file, yes.
20 MR GARNHAM: You do not appear to have discussed it.
21 MS KOZINOS: We did discuss it.
22 MR GARNHAM: Did you make reference to the SS5 during the
23 course of the strategy meeting?
24 MS KOZINOS: Yes, we talked fully about what had taken place
25 on the visit on the 1st, the 2nd, and also our planning
29
1 in terms of the investigation.
2 MR GARNHAM: Yes, I understand that, but did you refer the
3 others at the strategy meeting to the notes you say you
4 had compiled on the 2nd?
5 MS KOZINOS: I spoke about the note or the assessment.
6 MR GARNHAM: Did you refer to the fact that you had made
7 a note or were you merely describing its contents?
8 MS KOZINOS: I was describing its contents but Lisa knew
9 about the note from the discussion we had before the
10 strategy meeting.
11 MR GARNHAM: If what you say is right, would it not have
12 been sensible to have copied and distributed the SS5 to
13 those who were attending the meeting?
14 MS KOZINOS: No, because I had a clear recollection at the
15 time of what had happened.
16 MR GARNHAM: You had taken the trouble, you say, to record
17 those matters on the SS5 form and you did so at some
18 length. That was a record you had made immediately
19 after or shortly after that meeting. If that was indeed
20 available, would it not have been the sensible thing to
21 do to let everybody have sight of it?
22 MS KOZINOS: But the social worker would have had sight of
23 it before and the reason it was so detailed was because
24 at that time it was not meant to be me chairing the
25 strategy meeting so it was crucial that they did have
30
1 all that information so the team manager could make
2 decisions in relation to that information that I had got
3 at that day. But, as it was me who ended up chairing
4 the strategy meeting I did verbally feed back and had
5 a recollection of the visit which had taken place that
6 week.
7 MR GARNHAM: What you have put in that SS5 form would be of
8 particular relevance, would it not, to the police?
9 MS KOZINOS: Yes but it was discussed.
10 MR GARNHAM: Why did you not provide a copy to the police,
11 to PC Jones, if it existed?
12 MS KOZINOS: They never requested one.
13 MR GARNHAM: They probably did not know it existed, did
14 they?
15 MS KOZINOS: They knew it existed because it was myself who
16 saw Kouao and Victoria.
17 MR GARNHAM: But they did not know you had written a three,
18 four-page note.
19 MS KOZINOS: They knew I had written the contents of that
20 meeting.
21 MR GARNHAM: Are you saying or not saying that during the
22 course of the strategy meeting on 5th November you told
23 the assembled group you had recorded the events of
24 2nd November on a piece of paper?
25 MS KOZINOS: I do not recall that but it is standard
31
1 practice we do record any contact and the police would
2 be aware of that.
3 MR GARNHAM: If you had indeed recorded it as you say you
4 did, would it not have been a document highly useful to
5 the police officer who was present?
6 MS KOZINOS: If they wanted it.
7 MR GARNHAM: Why did you not simply produce it and give it
8 to them if it existed?
9 MS KOZINOS: I did not think at the time and we do not
10 normally give things from our file anyway without
11 permission.
12 MR GARNHAM: You see, one possibility is that you had not
13 written up that note on 2nd November and therefore were
14 not in a position to give it to anybody.
15 MS KOZINOS: No, I dispute that, I am sorry.
16 MR GARNHAM: Where did you believe that Victoria was on
17 5th November?
18 MS KOZINOS: She was at the Wood Green address with
19 Chantelle and Julian.
20 MR GARNHAM: How did you know she was still there?
21 MS KOZINOS: By what the social worker had said the previous
22 day about what Ms Kouao had reassured me that is where
23 she would be staying.
24 MR GARNHAM: Well, you had been told that that is where
25 Kouao and Victoria were going to go. What evidence did
32
1 you have as to how long they were going to stay?
2 MS KOZINOS: That is discussion I had with Ms Kouao in the
3 office visit and she reassured me that is where she
4 would be staying throughout the investigation.
5 MR GARNHAM: How long did you tell her the investigation was
6 going to last?
7 MS KOZINOS: I did not. What I told her is that we would
8 need to fully investigate the matter and that is when
9 I mentioned the case conference with her, that we would
10 have to hold a case conference.
11 MR GARNHAM: So Kouao would have gone away from that
12 conversation with you believing she needed to stay with
13 the Kimbidimas until the case conference?
14 MS KOZINOS: That is correct.
15 MR GARNHAM: There never was a case conference in this case.
16 MS KOZINOS: No, unfortunately.
17 MR GARNHAM: So you would have assumed she remained with the
18 Kimbidimas throughout the period with which we are
19 concerned?
20 MS KOZINOS: That is right.
21 MR GARNHAM: But you were reaching that conclusion based on
22 what Kouao had told you?
23 MS KOZINOS: On what the social worker had told me.
24 MR GARNHAM: Although she was only reporting what Kouao had
25 told her?
33
1 MS KOZINOS: No, my belief is that they followed that
2 through the previous day with the team manager on that
3 first visit of the 1st.
4 MR GARNHAM: The only source of information about how long
5 Victoria and Kouao were going to stay with the
6 Kimbidimas came from Kouao.
7 MS KOZINOS: How long?
8 MR GARNHAM: Yes.
9 MS KOZINOS: They were told -- she was told clearly to stay
10 there until the investigation had been completed.
11 MR GARNHAM: I appreciate that you say that but that does
12 not mean Kouao is going to do as she was told, does it?
13 MS KOZINOS: No, but at the time I did feel she would have.
14 MR GARNHAM: On what possible basis?
15 MS KOZINOS: Her reassurance from the social worker who
16 I would have assumed would have checked it out the day
17 before -- I went through it with her and she was quite
18 adamant that is where she needed to stay and at the time
19 when I had contact with her I did accept that
20 explanation.
21 MR GARNHAM: You were considering two possible reasons why
22 the allegations of sexual abuse had been made and then
23 withdrawn. One of them was that Victoria had indeed
24 been abused. The other was that she had not but that
25 Kouao was using her to get housing. Given that the
34
1 second of those possibilities existed, how could you
2 possibly rely on what Kouao told you about where she
3 would be keeping Victoria?
4 MS KOZINOS: Which is why a risk assessment needed to take
5 place and why a Section 47 was instigated so you would
6 have known that on that day.
7 MR GARNHAM: You would have known that once that risk
8 assessment was completed?
9 MS KOZINOS: Exactly.
10 MR GARNHAM: But in the interim you had no way of knowing
11 whether Kouao had left Victoria with the Kimbidimas or
12 brought her back to Manning, did you?
13 MS KOZINOS: Not for certain, no.
14 MR GARNHAM: So you were working on an assumption that one
15 of the two possible abusers would do as you asked and
16 not bring her back to the other?
17 MS KOZINOS: I accepted the explanation at the time, yes.
18 MR GARNHAM: That was an extremely dangerous assumption to
19 make on your part, was it not?
20 MS KOZINOS: No, because that is with the knowledge of
21 hindsight that we have now. I felt reassured from the
22 social worker and the team manager the previous day that
23 she had accepted that she was staying there and also
24 from my visit --
25 MR GARNHAM: But you were -- sorry, please finish.
35
1 MS KOZINOS: It is okay.
2 MR GARNHAM: But you were accepting an explanation that
3 originated with Kouao?
4 MS KOZINOS: True.
5 MR GARNHAM: And Kouao might have been one of the abusers?
6 MS KOZINOS: Absolutely.
7 MR GARNHAM: So that for you to accept that explanation was
8 plainly dangerous, was it not?
9 MS KOZINOS: Not plainly dangerous because it was based on
10 assessment I carried out with her at that time. And
11 also I instigated a Section 47 after, and with
12 discussions regarding if she was to return what steps we
13 needed to take.
14 MR GARNHAM: Did you enquire during the course of the
15 strategy meeting whether Victoria and Kouao had indeed
16 remained up to that date with the Kimbidimas?
17 MS KOZINOS: The social worker informed me that is where
18 they were.
19 MR GARNHAM: Is it not the case that the social worker
20 informed that you that is where she had gone and that
21 you made no enquiry as to where they were on
22 5th November?
23 MS KOZINOS: No. The information I got at the time from the
24 social worker was that is where they were.
25 MR GARNHAM: I see. So you tell us that Lisa Arthurworrey
36
1 told you that today, "They are with the Kimbidimas".
2 MS KOZINOS: Yes, that is what I believe.
3 MR GARNHAM: Did you ask her how she knew that?
4 MS KOZINOS: I do not recall.
5 MR GARNHAM: Did you ask her whether she had phoned the
6 Kimbidimas to check whether they were still there?
7 MS KOZINOS: I do not recall. I do not.
8 MR GARNHAM: That would have been the sensible thing to do,
9 would it not, because otherwise nobody had any way of
10 knowing whether they had stayed at the Kimbidimas or
11 gone back to Manning?
12 MS KOZINOS: Absolutely, and I do not know, I cannot say if
13 I did or did not.
14 MR GARNHAM: You say in paragraph 26 that no Emergency
15 Protection Order was sought because mother and child
16 were not apparently living or having contact with the
17 alleged abuser. How could you possibly know that?
18 MS KOZINOS: Because a risk assessment was taking place that
19 day and we did discuss that if any time she was to
20 return to Manning we would consider an emergency
21 protection order, and there was a reference to
22 directions to speak to Legal.
23 MR GARNHAM: What did this risk assessment consist of?
24 MS KOZINOS: It would have been mother's ability to protect.
25 MR GARNHAM: What were the mechanics going to be of it?
37
1 MS KOZINOS: They needed to go to the house of the
2 Kimbidimas and speak to mum and also take into
3 consideration some of the decisions I have made on the
4 strategy meeting.
5 MR GARNHAM: So the risk assessment would have involved
6 Jones and Arthurworrey going to find Victoria and Kouao
7 at the Kimbidimas' house?
8 MS KOZINOS: Yes, although there was a question mark whether
9 the police officer could go with her that day.
10 MR GARNHAM: What was that question mark? Jones's
11 availability?
12 MS KOZINOS: I have a vague recollection in terms of
13 childcare.
14 MR GARNHAM: So what was going to happen there? If Jones
15 was not available, what was going to happen? How was
16 this risk assessment going to be done?
17 MS KOZINOS: They were discussing whether she could go or
18 not and that is when -- this was at the end of the
19 strategy meeting when they were discussing arrangements.
20 I spoke to Carole and fed back to her and the
21 understanding was that a risk -- someone had to go
22 around that day to do an assessment. There was also
23 talk whether Valerie, the social worker at the time,
24 went with Lisa because she had seen the child
25 previously.
38
1 MR GARNHAM: I think this is the first time we have heard
2 any of this, is it not?
3 MS KOZINOS: No-one has ever asked me what happened after.
4 MR GARNHAM: I see. It must have been crucial, then, to
5 your understanding of the position that this visit was
6 paid to the Kimbidimas to speak to Victoria promptly
7 after the strategy meeting?
8 MS KOZINOS: Because no-one had spoken to her and also
9 because of the concerns I had raised in terms of --
10 because if you look on the form, I say that mother --
11 who we thought was mother, needed further assessment.
12 MR GARNHAM: Yes. So crucial that child and mother be seen
13 promptly after the strategy meeting?
14 MS KOZINOS: Of course.
15 MR GARNHAM: Both to reassure you about the circumstances of
16 the alleged abuse and to reassure you about the way in
17 which Victoria was being cared for at the time?
18 MS KOZINOS: Yes.
19 MR GARNHAM: And also I suppose to ensure that they were
20 indeed staying at the Kimbidimas?
21 MS KOZINOS: Yes.
22 MR GARNHAM: And that the Kimbidimas' home was suitable?
23 MS KOZINOS: Yes.
24 MR GARNHAM: Because there had been no enquiries, had there,
25 that the Kimbidimas' home was suitable, by you or anyone
39
1 else?
2 MS KOZINOS: I do not know if they made enquiries from the
3 previous --
4 MR GARNHAM: Did you ask at the strategy meeting?
5 MS KOZINOS: I do not recollect.
6 MR GARNHAM: Was that not essential?
7 MS KOZINOS: Yes, and I can only make the assumption that I
8 asked, but I do not know for certain. I do not have any
9 recollection of it, sorry.
10 MR GARNHAM: When did you think the risk assessment would be
11 completed? How long do they normally take?
12 MS KOZINOS: A day -- a judgment or a decision.
13 MR GARNHAM: A day.
14 MS KOZINOS: Yes, a decision has to be made whether the
15 child is safe or at risk, so that would have had to have
16 taken place on that day. Also, because we had the
17 weekend ahead.
18 MR GARNHAM: So you expected it to be done by when?
19 MS KOZINOS: That day. There is not a cut-off time because
20 when we work in crisis, if it means working through till
21 later ...
22 MR GARNHAM: So if you discovered that it had not been done
23 that day you would be extremely concerned?
24 MS KOZINOS: Yes, I would have been concerned.
25 MR GARNHAM: And vital that somebody checked that it had
40
1 happened?
2 MS KOZINOS: Yes, that is the part of the process that
3 Carole Baptiste was involved in.
4 MR GARNHAM: I understand that. Can you tell us who took
5 part in the discussion on 5th November as to where
6 Victoria and Kouao were? Was it Jones who told you that
7 they were still at the Mannings? Sorry, was it
8 WPC Jones who told you that Victoria and Kouao were
9 still at the Kimbidimas?
10 MS KOZINOS: No, I think she was hearing that, a lot of the
11 information about the second visit for the first time.
12 MR GARNHAM: She told us that she told the meeting that that
13 is where they were thought to be.
14 MS KOZINOS: Carole? The police?
15 MR GARNHAM: The police.
16 MS KOZINOS: Sorry, you have lost me. No.
17 MR GARNHAM: I am simply putting to you what we were told by
18 Karen Jones, namely that she, Karen Jones, thought that
19 Kouao and Victoria were at the Kimbidimas.
20 MS KOZINOS: That she was at Wood Green?
21 MR GARNHAM: So sorry, my mistake, I have been passed
22 a note. I have misread it. Ignore those last two
23 questions and let me put it to you again.
24 WPC Jones told us that she told the strategy meeting
25 on 5th November that Kouao and Victoria had returned to
41
1 Manning's flat.
2 MS KOZINOS: No.
3 MR GARNHAM: You say that was not said?
4 MS KOZINOS: No. Because that would have -- the immediate
5 reaction would have been very different.
6 MR GARNHAM: You were telling me that you regarded the home
7 visit to the Kimbidimas to see Kouao and Victoria as
8 essential.
9 MS KOZINOS: Yes.
10 MR GARNHAM: Without which it would be impossible to make
11 this risk assessment.
12 MS KOZINOS: There was a lot of things then we could not
13 proceed with.
14 MR GARNHAM: So why then does your decision at page 87 in
15 volume 6, decision 13, say "possible joint home visit
16 with PCPT"?
17 MS KOZINOS: Because -- it is not a possible home visit, it
18 is whether --
19 MR GARNHAM: Possible with the police?
20 MS KOZINOS: Yes, whether it was going to happen with the
21 police.
22 MR GARNHAM: In any event it would have to go ahead, with or
23 without the police?
24 MS KOZINOS: We would still have a duty as social services
25 to go ahead.
42
1 MR GARNHAM: It is not very clear that note, is it, because
2 it could read as if the "possible" describes the
3 occurrence at all?
4 MS KOZINOS: Yes, I accept that.
5 MR GARNHAM: Let me ask you a question in relation to this
6 strategy meeting, similar to the one I asked in respect
7 of the July strategy meeting. Why were you chairing it?
8 MS KOZINOS: Because Carole had asked me to.
9 MR GARNHAM: Do you accept that for you to chair it is
10 contrary to the Haringey Child Protection Guidelines?
11 MS KOZINOS: I do accept that but it was standard practice
12 at the time that senior practitioners chaired meetings.
13 MR GARNHAM: Even though the borough's guidelines say -- in
14 paragraph 2.3 sir for your note -- that they should
15 always be chaired either by a team manager or in
16 exceptional cases by a child protection advisor?
17 MS KOZINOS: Yes, but at the time the working practices
18 were -- and it was common knowledge and it was never
19 challenged.
20 MR GARNHAM: So routinely Haringey, in that regard, would
21 not follow its procedures?
22 MS KOZINOS: No, team managers also chair meetings.
23 MR GARNHAM: But if the requirement is that team managers
24 must, and you say commonly they did not, in that regard
25 they routinely did not follow their own procedures?
43
1 MS KOZINOS: Yes.
2 MR GARNHAM: There were 15 recommendations arising out of
3 that strategy meeting. We have them at page 87 in
4 volume 6. Can I just check that I am right to read one
5 sentence in your witness statement as containing a typo?
6 Page 17 of your witness statement. The penultimate
7 bullet point on that page says:
8 "The client to give the police a statement/and/or
9 one with the drawing".
10 I think you must mean "give the police a statement
11 or one withdrawing the allegation", do you not?
12 MS KOZINOS: Yes. Sorry.
13 MR GARNHAM: As with the July strategy meeting there was no
14 review mechanism put in place during the course of this
15 strategy meeting, was there?
16 MS KOZINOS: It was the same as the July one where it would
17 be reviewed by the team manager.
18 MR GARNHAM: So you say in respect of this, as you did in
19 respect of the other one, that the practice at Haringey
20 was that there should not be "fix review" strategy
21 meetings but instead progress on the recommendations
22 should be looked at during the course of supervisions?
23 MS KOZINOS: That is correct. We did not alter review
24 meetings.
25 MR GARNHAM: Again, the same question in respect of these
44
1 recommendations as I asked you in respect of the
2 previous strategy meeting recommendations. Your notes
3 at page 87 specify neither the date by which these
4 actions are to be taken nor the person who is to take
5 them. Why not?
6 MS KOZINOS: Again it is going to be a similar answer, I am
7 afraid. It is because at the time, but more so with
8 this one I think because we did have the two allocated
9 workers and the team manager was also aware of the
10 strategy meeting before and after, that --
11 MR GARNHAM: It was obvious to those who were there.
12 MS KOZINOS: They had a clear understanding that they needed
13 to carry out that work from after the strategy meeting
14 anyway.
15 MR GARNHAM: Do you agree good practice would dictate you do
16 record who is to do each task?
17 MS KOZINOS: In hindsight and looking back it at it now,
18 yes, it would have been.
19 MR GARNHAM: That was good practice at the time to do that?
20 MS KOZINOS: But I do say in some of the decisions who does
21 it.
22 MR GARNHAM: That is the point, is it not? You say in some
23 of the decisions you do, and that is right, but some of
24 them you do not.
25 MS KOZINOS: Because they were joint ones, yes. But they
45
1 were clear in regards to what they needed to do.
2 MR GARNHAM: For example, item 3, "Some proof that child is
3 hers", who did you see that as being directed towards?
4 MS KOZINOS: At the time, Lisa.
5 MR GARNHAM: So do we take your evidence on this subject to
6 be the same as in respect of the July strategy meeting,
7 that if it is not specified, everybody understood it was
8 to be the allocated social worker who did the job?
9 MS KOZINOS: Yes, or there would be some discussion around
10 it, because these decisions were fully discussed and
11 they were joint decisions, so the people present were
12 also the workers carrying out the work and allocated,
13 they were clear and they never expressed that
14 uncertainty and no-one came back to me.
15 MR GARNHAM: I see. By what date were they to do these
16 tasks?
17 MS KOZINOS: Dependent. They followed from each other. But
18 the first thing that needed to happen was the risk
19 assessment and the way to proceed with the memo
20 investigation.
21 MR GARNHAM: How do we understand from this list that that
22 is the first thing?
23 MS KOZINOS: You do not.
24 MR GARNHAM: It comes out of the discussion?
25 MS KOZINOS: Yes.
46
1 MR GARNHAM: How do they know by what date you expect each
2 of these 15 tasks to have been completed?
3 MS KOZINOS: There was a lot of discussion at the strategy
4 meeting and -- I mean, in terms of the case conference
5 that is something that should have been booked straight
6 away. The risk assessment should have happened that
7 day, depending -- the outcome of that would have
8 dictated the memorandum, then a possible medical.
9 MR GARNHAM: Do you agree that the problem with an undated
10 list of this sort is it is a recipe for drift?
11 MS KOZINOS: But you cannot always date the work because
12 certain actions follow from others.
13 MR GARNHAM: But can you not say the date by which this must
14 have happened otherwise we are to reconsider?
15 MS KOZINOS: Like a deadline?
16 MR GARNHAM: Yes.
17 MS KOZINOS: I accept that.
18 MR GARNHAM: And good practice should dictate each of these
19 should have a date put on it?
20 MS KOZINOS: In hindsight that may have been better, yes,
21 but at the time I did feel that the people present were
22 clear.
23 MR GARNHAM: Why were no representatives from the NHS
24 invited to this strategy meeting?
25 MS KOZINOS: Because when we hold strategy meetings the
47
1 working practice is it would be the police, ourselves,
2 and if the referrer at the time was a professional they
3 would be invited, and in this case it was a new
4 allegation, the referral was Kouao.
5 MR GARNHAM: You knew at least because you had picked up
6 what -- you realised, it was the same case as you
7 chaired in July, you realised that hospitals had been
8 involved in this case in the past.
9 MS KOZINOS: Yes, but that matter had been fully
10 investigated and there were no outstanding concerns.
11 MR GARNHAM: You did not think it worthwhile checking with
12 the hospital that there were no outstanding concerns?
13 MS KOZINOS: No, I accepted the explanation by the two
14 workers and also the team manager who were working on
15 the case, or had worked on the case.
16 MR GARNHAM: I imagine you would give the same explanation
17 as to why the NHS were not contacted during the course
18 of the meeting?
19 MS KOZINOS: Yes.
20 MR GARNHAM: Why were they not sent a copy of the minutes at
21 the end?
22 MS KOZINOS: Of this one?
23 MR GARNHAM: Yes.
24 MS KOZINOS: Who, the NHS?
25 MR GARNHAM: The two hospitals we are concerned with, the
48
1 NMH and CMH.
2 MS KOZINOS: It was not practice to send the strategy
3 meeting minutes to them and they also were not involved
4 in this meeting.
5 MR GARNHAM: Why was there no requirement to have Victoria
6 examined by a police surgeon?
7 MS KOZINOS: Because the way we have always worked in terms
8 of sexual abuse we always speak to the child first.
9 MR GARNHAM: Is there not a danger that the evidence will be
10 lost if you do that?
11 MS KOZINOS: But it could also be very abusive.
12 MR GARNHAM: Yes, but so it might be if a sexual abuser goes
13 unprosecuted. Say for example there was evidence of
14 penetration.
15 MS KOZINOS: But there was not in this case, the incidents
16 went -- the first incident --
17 MR GARNHAM: Was much longer ago?
18 MS KOZINOS: Yes, I cannot remember the exact date but
19 I think it was one of the first ones.
20 MR GARNHAM: Yes, it was.
21 MS KOZINOS: I think three were reported.
22 MR GARNHAM: That is your reason for not suggesting a police
23 surgeon examine --
24 MS KOZINOS: For not going in first with the medical, rather
25 than speaking to the child first.
49
1 MR GARNHAM: Thank you. Before we leave the strategy
2 meeting itself, can I just ask you to look at page 76,
3 please, in volume 6. Under the heading "Significant
4 Others" we have:
5 "Family were residing with friends."
6 Then the Kimbidima's address is given. Why is it
7 put in the past tense?
8 MS KOZINOS: I know, I have thought about this, having
9 looked at the file as well.
10 MR GARNHAM: Why not "are residing"?
11 MS KOZINOS: The only explanation I can have is in terms of
12 grammar and the way Lisa presented but at the strategy
13 meeting I was very clear that is where they were
14 staying.
15 MR GARNHAM: Because that would be consistent with what
16 I told you WPC Jones said, that they were no longer with
17 the Kimbidimas.
18 MS KOZINOS: Yes.
19 MR GARNHAM: You say that is merely an example of poor
20 expression?
21 MS KOZINOS: I noticed it -- yes, I can only put it down as
22 the way Lisa has written it.
23 MR GARNHAM: You said in answer to that last question that
24 that is the way Lisa wrote it. Did Lisa complete this
25 part of the form then?
50
1 MS KOZINOS: I need to see because I have the typed copy but
2 yes, it would have, from what I recollect is there.
3 MR GARNHAM: There is a handwritten version at pages 83 and
4 84.
5 MS KOZINOS: Yes it was. That is Lisa's handwriting.
6 MR GARNHAM: Thank you. As I have understood your evidence
7 so far, the crucial link in ensuring that the work you
8 specify in the strategy meeting actually gets done is
9 the supervision sessions with the allocated social
10 worker.
11 MS KOZINOS: No, not all of it. Also after risk assessments
12 you feed back to team manager because the assessment
13 needs to be discussed.
14 MR GARNHAM: I see that. But in order for example to check
15 that the risk assessment has been completed, the
16 mechanism that was in place in Haringey at the time was
17 that there would be supervision of the allocated social
18 worker by the relevant manager?
19 MS KOZINOS: Yes, but if something had occurred before then
20 they would feed back verbally as well.
21 MR GARNHAM: I understand that. But the safety net, the
22 catch of reviewing whether the work has happened is the
23 supervision with the manager?
24 MS KOZINOS: Yes.
25 MR GARNHAM: Because since no review strategy meeting has
|
