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   Pages 1 to 50 | Pages 51 to 100 | Pages101 to 150 | Pages 151 to 200 | Pages 201 to 250 | Pages 251 to 279

Archived Transcript for 19 November 2001: Pages 1 to 50


1



1 Monday, 19th November 2001

2 (10.05 am)

3 THE CHAIRMAN: Morning ladies and gentlemen. Mr Garnham.

4 MR GARNHAM: Morning sir. Our first witness today is

5 Karen Jones, please.

6 PC KAREN JONES (sworn)

7 MR GARNHAM: Please have a seat. Good morning Ms Jones.

8 Would you give the Tribunal your full name.

9 PC JONES: My full name is Karen Jones.

10 MR GARNHAM: Your professional address.

11 PC JONES: Peel Centre, Hendon Recruit Training School.

12 MR GARNHAM: I think it is right that you have made one

13 statement for this Inquiry, a copy of which I hope will

14 now be put in front of you.

15 PC JONES: Yes.

16 MR GARNHAM: Sir, that statement is found in volume 4 at

17 page 121.

18 You also I think made a statement for the CPS.

19 PC JONES: Yes, I did.

20 MR GARNHAM: Sir, that is volume 46, page 105.

21 You also gave evidence during the course of the

22 criminal trial of Kouao and Manning.

23 PC JONES: Yes.

24 MR GARNHAM: Sir, 48/249.

25 THE CHAIRMAN: Thank you.

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2



1 MR GARNHAM: You have in front of you a file of some sort.

2 What is that?

3 PC JONES: It has some documents in there. There is the

4 "Working Together" book, Memorandum of Good Practice,

5 there is another book there by Kevin Smith which is

6 a reference book that we use, and my training manual.

7 MR GARNHAM: Thank you. Can I ask you not to look at it

8 until the point arises where you need to and then can

9 you let us know before you do.

10 PC JONES: Yes.

11 MR GARNHAM: I think it is right that you joined the

12 Metropolitan Police in 1987.

13 PC JONES: Yes, I did.

14 MR GARNHAM: What were you doing before that?

15 PC JONES: I was a civil servant at the Home Office.

16 MR GARNHAM: You were then immediately posted to the

17 Haringey CPT or did you do something else first?

18 PC JONES: No, in 1987 when I joined the Metropolitan Police

19 I was on uniform duties at West Hendon Police Station.

20 MR GARNHAM: For how long were you at West Hendon?

21 PC JONES: Sic years. Five or six years I think, Hendon.

22 MR GARNHAM: Then I think you joined Haringey CPT in July

23 1996?

24 PC JONES: Yes.

25 MR GARNHAM: You remained there until August 1998?

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3



1 PC JONES: Yes.

2 MR GARNHAM: There was then a period of about 10 months

3 before you returned to Haringey CPT?

4 PC JONES: Yes.

5 MR GARNHAM: What did you do in those 10 months?

6 PC JONES: I was on maternity leave.

7 MR GARNHAM: Then back to Haringey CPT?

8 PC JONES: Yes.

9 MR GARNHAM: Where you remained until February of last year?

10 PC JONES: Yes.

11 MR GARNHAM: What have you been doing since?

12 PC JONES: I have been at recruit training school.

13 MR GARNHAM: Thank you. You describe in your statement your

14 duties as encompassing those of a police constable in

15 the CPT, as they are set out in the CPT manual.

16 PC JONES: Yes.

17 MR GARNHAM: Let us make sure we know what that is;

18 volume 31, please, page 195. That is the beginning of

19 a document entitled "Job Descriptions of Child

20 Protection Team". Is that right?

21 PC JONES: Yes.

22 MR GARNHAM: If you go over the page you see

23 "Detective/Police Constable" at paragraph 7.4.

24 PC JONES: Yes.

25 MR GARNHAM: And what follows is a list of your jobs in that

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4



1 role, is that right?

2 PC JONES: Yes.

3 MR GARNHAM: In addition you tell us in your statement that

4 you had the long list of duties that are set out in

5 paragraph 2 of your statement.

6 PC JONES: Yes.

7 MR GARNHAM: It is fair to say, is it not, that you are not

8 there describing anything unusual for a police officer,

9 those are the routine tasks of any police constable?

10 PC JONES: Well, not any police constable, no. Some of the

11 things -- do you mean like every police constable may be

12 on a relief?

13 MR GARNHAM: You tell us in what respects it is additional

14 to or different from what an ordinary police constable

15 on relief does.

16 PC JONES: An ordinary police constable on relief probably

17 would not do memorandum interviews. They would not

18 normally work with general registry. They would not do

19 admin duties.

20 MR GARNHAM: They would not?

21 PC JONES: Would not normally do admin duties.

22 MR GARNHAM: I see.

23 PC JONES: They would not have to deal with referrals.

24 MR GARNHAM: Not of the sort that you are referring to

25 anyway.

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5



1 PC JONES: Yes, that is right. They would not deal with

2 videos. They would not attend strategy meetings. They

3 would not arrange for GN dockets to be obtained.

4 MR GARNHAM: Remind us what they are.

5 PC JONES: They are general registry dockets, in our case

6 they were dockets that would contain information about

7 children who had come to notice.

8 MR GARNHAM: Is it fair to say this list which is describing

9 general police duties is constructed in such a way as to

10 make it specific to your post in child protection?

11 PC JONES: Yes.

12 MR GARNHAM: And we need to read that list together with the

13 job description that I have just taken you to to get

14 a full picture of the job you were doing?

15 PC JONES: Yes.

16 MR GARNHAM: But there is a good deal in the list that you

17 put in paragraph 2 which would be common to any other

18 police constable?

19 PC JONES: Yes, there are some things, yes.

20 MR GARNHAM: You tell us that you reported direct to

21 DI Howard, you say in paragraph 4 of your statement.

22 PC JONES: Yes.

23 MR GARNHAM: Sergeant Cooper-Bland was your reporting

24 sergeant?

25 PC JONES: He was.

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6



1 MR GARNHAM: It would be he who conducted your annual

2 appraisals?

3 PC JONES: Yes.

4 MR GARNHAM: Why did you report direct to Howard rather than

5 to Cooper-Bland?

6 PC JONES: By that I meant that DI Howard was the Detective

7 Inspector. He was a grade higher than

8 Sergeant Cooper-Bland so he would be -- what I meant was

9 he was the person that was in charge of our small unit

10 within that unit.

11 MR GARNHAM: In practice how did it work? Were you

12 ordinarily reporting to Sergeant Cooper-Bland or were

13 you reporting to DI Howard?

14 PC JONES: In everyday duties?

15 MR GARNHAM: Yes.

16 PC JONES: In everyday duties I would report to anybody that

17 was there, any supervisor.

18 MR GARNHAM: You suggest a picture of the way in which

19 Haringey CPT operated as if it was very much a team

20 effort.

21 PC JONES: Yes.

22 MR GARNHAM: Without the usual lines of demarcation between

23 ranks.

24 PC JONES: I would not put it that way. There are other

25 lines of demarcation between ranks but I think that when

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7



1 you work in any small team it is always slightly

2 different than when you work on a relief when you are

3 a uniformed officer working with or going out on the

4 beats and things.

5 MR GARNHAM: Would you be on first name terms with

6 Cooper-Bland?

7 PC JONES: Yes.

8 MR GARNHAM: DI Howard?

9 PC JONES: No.

10 MR GARNHAM: He would be "Guv" or something?

11 PC JONES: "Guvnor", yes.

12 MR GARNHAM: Can I ask you a little about your experience of

13 child protection work, please. How many investigations

14 involving physical abuse had you been involved in prior

15 to July 1999? Is it a daily occurrence, a weekly

16 occurrence, once in a blue moon?

17 PC JONES: That is a very difficult question. I would

18 estimate maybe once or twice a week but it is quite

19 a difficult question.

20 MR GARNHAM: I am trying simply to get a feel of the sort of

21 work you were doing. Once or twice a week would be your

22 estimate?

23 PC JONES: Yes.

24 MR GARNHAM: Many of those incidents would involve

25 allegations of assault, would they?

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8



1 PC JONES: Yes.

2 MR GARNHAM: What about allegations of neglect, which can be

3 a criminal offence, can it not?

4 PC JONES: Yes.

5 MR GARNHAM: How often would you be dealing with that?

6 PC JONES: I have never -- on my time at the CPT I have only

7 ever known one case to go to court with neglect. It was

8 not my case.

9 MR GARNHAM: Do I take it from that that you personally have

10 never been involved in a case alleging neglect?

11 PC JONES: No.

12 MR GARNHAM: Even one that did not go to court?

13 PC JONES: Sometimes there are other concerns, some concerns

14 may be raised about neglect but I have never had to

15 arrest anybody, never had evidence to arrest anybody for

16 it.

17 MR GARNHAM: The first of the duties listed in the job

18 description that you have already looked at is the

19 investigation of allegations of crimes allocated to

20 them.

21 PC JONES: Yes.

22 MR GARNHAM: Did you regard that as your primary function?

23 PC JONES: Yes, one of them, yes.

24 MR GARNHAM: One of them?

25 PC JONES: Yes.

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9



1 MR GARNHAM: What are the others that you regard as primary?

2 PC JONES: Primary function?

3 MR GARNHAM: Yes, the most important functions.

4 PC JONES: Well, I would say a memorandum interview would be

5 an important function. An arrest of a suspect would be

6 an important function.

7 MR GARNHAM: Could it fairly be said that both of those two

8 are stages in the process of an investigation and so are

9 part of that first duty? That is why you have

10 a memorandum interview, is it not?

11 PC JONES: Well, it could be said to be part of it but --

12 MR GARNHAM: Why else do you have a memorandum interview

13 except in order to investigate an allegation of crime?

14 PC JONES: Well, you would have one to investigate an

15 allegation of crime but I would not put it in the way

16 you have just put.

17 MR GARNHAM: I do not want to put words in your mouth. You

18 tell me how you would put it. I am suggesting to you

19 that the investigation of crimes was your first and

20 primary function.

21 PC JONES: Yes.

22 MR GARNHAM: If that is not right you tell me how you saw

23 it.

24 PC JONES: I would not -- it was the first primary function

25 but I am saying that there were other things as well.

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10



1 MR GARNHAM: Were there other things that had nothing to do

2 with the investigation of crime?

3 PC JONES: Well, yes, there would be things. For instance,

4 a primary function must be to attend case conferences as

5 well.

6 MR GARNHAM: Why are you attending case conferences?

7 PC JONES: Sometimes there are childcare concerns that are

8 not necessarily criminal, a criminal investigation.

9 MR GARNHAM: Yes, and what did you in 1999 see as your

10 function in relation to cases where there were not going

11 to be allegations of crime but there were some other

12 childcare concerns?

13 PC JONES: You might have an input, know something about the

14 family. Police might have an input into that case

15 conference.

16 MR GARNHAM: And the purpose of it?

17 PC JONES: To help the case conference come to decisions.

18 MR GARNHAM: For what purpose?

19 PC JONES: To ...

20 MR GARNHAM: To safeguard the child?

21 PC JONES: Yes.

22 MR GARNHAM: To keep him or her from harm?

23 PC JONES: Yes.

24 MR GARNHAM: Can we say then that the next of your important

25 functions is to assist in protecting children from harm

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11



1 even where it does not involve a crime?

2 PC JONES: Yes.

3 MR GARNHAM: Any others you would put in that category of

4 importance, investigating crime and helping to protect

5 children from harm?

6 PC JONES: That would be the primary functions.

7 MR GARNHAM: Thank you. Whenever there is an allegation

8 that involves a suggestion of child abuse it is your

9 job, is it not, as the police officer in the case, to

10 form a judgment about whether or not a crime has been

11 committed?

12 PC JONES: To form a judgment?

13 MR GARNHAM: Yes. Do you not, together with the assistance

14 you get from your supervisors, have to decide whether or

15 not this is a crime that ought to be investigated and

16 prosecuted if necessary?

17 PC JONES: Well, if an allegation comes in it is your job to

18 try and find out exactly what the allegation is and if

19 it is going to be regarded as a crime.

20 MR GARNHAM: Yes, and that is a function which I have called

21 a judgment, but put it in your words if you prefer, that

22 is a function that is a police function rather than

23 a social services function.

24 PC JONES: Yes.

25 MR GARNHAM: Does it follow from that that for the police to

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12



1 obtain the witness evidence and the forensic evidence

2 that they need to make that decision --

3 PC JONES: Can you repeat that?

4 MR GARNHAM: Does it follow from that that it is for the

5 police to obtain the witness evidence and the forensic

6 evidence they need to make that decision?

7 PC JONES: Yes.

8 MR GARNHAM: Although it may be that in the course of an

9 investigation you are assisted by your social service

10 colleagues, that remains your job, does it not?

11 PC JONES: Yes.

12 MR GARNHAM: Is it right that as a police officer you are

13 responsible for your own case investigations?

14 PC JONES: Yes.

15 MR GARNHAM: You carry the can for the cases that are

16 allocated to you?

17 PC JONES: What do you mean carry the can?

18 MR GARNHAM: I probably should have stuck with "you are

19 responsible for", which is more precise. You are

20 responsible for?

21 PC JONES: What do you mean by responsible for?

22 MR GARNHAM: I will resist the temptation to say carry the

23 can. You look after the case and you see it through to

24 its conclusions?

25 PC JONES: Yes.

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1 MR GARNHAM: And you have a personal obligation to ensure

2 that that is done?

3 PC JONES: Yes.

4 MR GARNHAM: Looking back to the events of August 1999 and

5 your involvement with Victoria Climbie then, and bearing

6 in mind only what was known to you at the time, not what

7 you have learned as a result of Victoria's death, are

8 you content that you acted properly?

9 PC JONES: Yes.

10 MR GARNHAM: Looking back on the events of November 1999 and

11 your involvement with Victoria then, and again bearing

12 in mind only what was the information that was available

13 to you then, are you now content that you acted properly

14 in that regard?

15 PC JONES: No.

16 MR GARNHAM: Tell us in what respects you think you did not

17 act properly with regard to the November incident.

18 PC JONES: The November incident, I think I feel I acted

19 slowly. I should have been -- I should have made more

20 efforts to trace the family. I should have made more

21 efforts -- I should have gone round to the house at

22 Somerset Gardens. I should have delivered the letter by

23 hand. I feel I should have just made more attempts to

24 speak to the family.

25 MR GARNHAM: Thank you for that frankness. I will need to

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14



1 return to the November incident and indeed to the August

2 incident a little later. Let me turn to Victoria's

3 case. You tell us in your statement that you were

4 already at the North Tottenham District Office on

5 28th July when you first heard of Victoria's case.

6 PC JONES: Yes.

7 MR GARNHAM: I wonder if you could have volume 30 please,

8 page 132. That appears to be the referral to the Child

9 Protection Team. First of all, have you seen that

10 document before?

11 PC JONES: Yes.

12 MR GARNHAM: Can you tell us what it is?

13 PC JONES: It is a form 87X. What happens is if a referral

14 comes in from social services or anybody this form is

15 completed.

16 MR GARNHAM: By the police?

17 PC JONES: Yes, and then some of the information is placed

18 on to a computer. It is completed on the computer in

19 fact and you can print out the hard copy.

20 MR GARNHAM: Thank you. We see that the details of the

21 subject are described as "Anna Kovao" and her date of

22 birth and address are given.

23 PC JONES: Yes.

24 MR GARNHAM: And the details of her mother. Then under

25 "Details of Allegation":

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1 "Anna taken to NMH with burns to head. Old buckle

2 marks found on body."

3 PC JONES: Yes.

4 MR GARNHAM: You are then identified as the officer in the

5 case.

6 PC JONES: Yes.

7 MR GARNHAM: Do you know who would have completed this form?

8 PC JONES: No, I do not know.

9 MR GARNHAM: When you were at North Tottenham District

10 Office I think it is right that Sergeant Cooper-Bland

11 rang you?

12 PC JONES: Yes, he did.

13 MR GARNHAM: And you discussed Victoria's case with him?

14 PC JONES: Yes.

15 MR GARNHAM: What were you asked to do?

16 PC JONES: To attend a strategy meeting that was going to

17 take place later on in the afternoon and --

18 MR GARNHAM: At the same office?

19 PC JONES: Yes.

20 MR GARNHAM: I think it is right that you have been able to

21 check, have you not, from your records, your notes, to

22 discover whether you were indeed already at North

23 Tottenham District Office that day?

24 PC JONES: Yes.

25 MR GARNHAM: I think it is right that you were there for

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16



1 another case?

2 PC JONES: Yes.

3 MR GARNHAM: Turn to page 111 in that volume, please. That

4 is the first of the CRIS entries.

5 PC JONES: Yes.

6 MR GARNHAM: We see there the initial entry describing the

7 nature of the allegation. By "Suspect as yet unknown,

8 pouring hot water over child's head, evidence of old

9 scars, apparently belt marks", is that what you were

10 told by Cooper-Bland in the phone call?

11 PC JONES: What I was told -- may I have a look in my

12 statement?

13 MR GARNHAM: Yes, do.

14 PC JONES: I could not actually remember much of the

15 conversation, as I have written in my statement, but

16 I did remember about that Victoria was in hospital

17 suffering from scabies and about the belt buckle mark.

18 MR GARNHAM: Thank you. If we look at what I think is the

19 second entry on that page 111, we see that that is

20 entered by PS Cooper-Bland, refers to a reference by

21 Shanti Jacobs, reporting what she had been told by North

22 Middlesex.

23 PC JONES: Yes.

24 MR GARNHAM: "On 24th July mother presented at A&E with Anna

25 at about 5.25. Anna had some burns, scalds to face and

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17



1 head. Mother gave an explanation that Anna had scabies

2 which were irritating her. Mother saw Anna had poured

3 hot water over her own head to apparently ease the

4 irritation. This explanation was accepted by hospital

5 staff who admitted her for observation. Medical

6 concerns were raised when a nurse noticed old marks on

7 Anna's body. These apparently resembled buckle marks.

8 A full skeletal survey has now been done."

9 Yes?

10 PC JONES: Yes.

11 MR GARNHAM: Does anything in that conflict with your memory

12 of what you were told by Cooper-Bland?

13 PC JONES: From what -- I cannot remember much about what

14 Sergeant Cooper-Bland said to me. There seems to be

15 nothing conflicting but I cannot remember much about

16 what he said.

17 MR GARNHAM: Very well, thank you. You were instructed by

18 Cooper-Bland to attend a strategy meeting?

19 PC JONES: Yes.

20 MR GARNHAM: Which was to happen later that afternoon?

21 PC JONES: Yes.

22 MR GARNHAM: So it appears that we have got from the moment

23 of admission to CMH to your being informed and the

24 strategy meeting being arranged in about four days.

25 PC JONES: At CMH?

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1 MR GARNHAM: I meant NMH, in four days.

2 PC JONES: Yes.

3 MR GARNHAM: Is that normal? Would it normally take four

4 days for Haringey CPT to be informed of this sort of

5 referral into North Middlesex?

6 PC JONES: Well, not that I know of. I mean sometimes

7 referrals are late. I cannot say that --

8 MR GARNHAM: Four days strikes you as late, does it?

9 PC JONES: Yes, it is late.

10 MR GARNHAM: Allegations of this type you would expect

11 normally to reach the police in a shorter time than four

12 days?

13 PC JONES: Yes.

14 MR GARNHAM: What would be a more normal or average sort of

15 time delay between an admission and reference to the

16 police?

17 PC JONES: Well I would think it should have been done

18 straightaway, or at least as soon as somebody saw or had

19 the concerns.

20 MR GARNHAM: Did you raise that question of that delay with

21 anybody at the strategy meeting which you subsequently

22 attended?

23 PC JONES: No, because at the time I had -- I was led to

24 believe that the hospital had just found those marks and

25 that Victoria had been in the hospital since the 24th

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1 after having scalded herself and that was an explanation

2 that was accepted by the hospital, and as she was being

3 treated, it came to light some days later that she had

4 these marks on her body.

5 MR GARNHAM: You were informed, you tell us by reference to

6 that CRIS report, you had been informed by Cooper-Bland

7 that the hospital had accepted the explanation.

8 PC JONES: Yes.

9 MR GARNHAM: During the course of your dealings with this

10 case over the course of the following week, did you ever

11 question that conclusion?

12 PC JONES: About the hot water?

13 MR GARNHAM: Yes.

14 PC JONES: No.

15 MR GARNHAM: Did anybody else suggest to you anything that

16 raised a doubt about whether the hospital had accepted

17 that this was an accidental or self-inflicted injury?

18 PC JONES: Did anybody raise?

19 MR GARNHAM: Did anybody else suggest that this might be

20 a non-accidental injury?

21 PC JONES: No.

22 MR GARNHAM: You were assigned to attend this strategy

23 meeting by your sergeant?

24 PC JONES: Yes.

25 MR GARNHAM: Was that normal? Was it normally done by the

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1 sergeant rather than by an inspector?

2 PC JONES: By a sergeant.

3 MR GARNHAM: Yes, it was normal?

4 PC JONES: Yes.

5 MR GARNHAM: Were there arrangements in place for you to

6 report back to Cooper-Bland or to Howard the results of

7 this strategy meeting?

8 PC JONES: Well, what would normally happen is if you attend

9 the strategy meeting you would come, when you came back

10 you would write up your notes on the CRIS report or in

11 the general registry docket or we used to have another

12 docket, a confidential docket. You would write your

13 notes up in there.

14 MR GARNHAM: And they would then be read by the supervising

15 officers?

16 PC JONES: The CRIS machine would, yes.

17 MR GARNHAM: What about the other documents?

18 PC JONES: Well, I do not know. I am sure that they would

19 go through the files but maybe not just every single

20 file. It was more likely to be supervision on the CRIS

21 machine.

22 MR GARNHAM: Does that mean that the entry on the CRIS

23 machine is essential if you are to relay information

24 back to your supervising officers?

25 PC JONES: Yes, but you could speak to them as well but just

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1 saying the CRIS machine is where we would put things.

2 MR GARNHAM: Was the procedure that was normally in place

3 for reporting back after strategy meetings relying

4 simply on the reading of the CRIS entry or was there in

5 place a system for meetings to discuss what had been

6 talked about at the strategy meeting?

7 PC JONES: I would say it was more reliant on the CRIS.

8 MR GARNHAM: Thank you. This strategy meeting which was to

9 be held at North Tottenham District Office concerned

10 a child who was in hospital?

11 PC JONES: Yes.

12 MR GARNHAM: How often did strategy meetings in respect of

13 children in hospital take place at North Tottenham

14 District Office?

15 PC JONES: I think most strategy meetings took place at

16 North Tottenham if that was the area at the district

17 office.

18 MR GARNHAM: And not in the hospital?

19 PC JONES: Not in the hospital but I have been to strategy

20 meetings in the hospital.

21 MR GARNHAM: Is that the exception rather than the rule?

22 PC JONES: Exception rather than the rule.

23 MR GARNHAM: Were you aware of the fact that Haringey's

24 Child Protection Guidelines suggest or require that

25 strategy meetings involving children in hospital should

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1 be held in hospital?

2 PC JONES: I am now but I was not at that time.

3 MR GARNHAM: Did anybody every question the location for the

4 holding of the strategy meeting?

5 PC JONES: No.

6 MR GARNHAM: Because there were in fact no doctors or nurses

7 at the strategy meeting, were there?

8 PC JONES: That is right.

9 MR GARNHAM: Did that strike you as odd in the case of

10 a child in hospital?

11 PC JONES: No.

12 MR GARNHAM: Because it was commonplace?

13 PC JONES: Yes.

14 MR GARNHAM: I want to ask you about something that another

15 witness has said to us. I wonder if you could have

16 volume 2 of the witness bundle, please. Page 202.408.

17 This is a statement of Rose Kozinos and in the passage

18 that I am about to take you to she refers to

19 difficulties in arranging these meetings. Would you go

20 to the very last two words on page 202.

21 PC JONES: Yes.

22 MR GARNHAM: Do you have them: "As we ..."?

23 PC JONES: Yes.

24 MR GARNHAM: Over the page:

25 "As we had difficulties with police attendance due

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23



1 to their vacancies and workload we would tend to do

2 a number of strategy meetings one after another once

3 a police officer was present."

4 Do you see that?

5 PC JONES: Yes.

6 MR GARNHAM: Is that correct?

7 PC JONES: They would do strategy meetings one after another

8 but I would not have said -- obviously we have

9 a different opinion but I would not have said it was

10 because of police being unable to attend because we

11 would always attend the strategy meetings.

12 MR GARNHAM: It is right to say that they tended to be held

13 one after another?

14 PC JONES: Quite often.

15 MR GARNHAM: It is right to say that normally they were held

16 at North Tottenham District Office?

17 PC JONES: Yes.

18 MR GARNHAM: But you do not think it is for the convenience

19 of police?

20 PC JONES: No.

21 MR GARNHAM: Were you surprised to be allocated this

22 particular case?

23 PC JONES: No.

24 MR GARNHAM: Because it involved potentially quite a serious

25 incident, did it not?

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1 PC JONES: Yes.

2 MR GARNHAM: Arisen out of a scalding injury followed by

3 what was on any view an allegation of assault with

4 a belt?

5 PC JONES: (Witness nods).

6 MR GARNHAM: Being categorised as ABH by

7 Sergeant Cooper-Bland in the CRIS report but it might

8 have been GBH depending on how bad the injuries turned

9 out to be.

10 PC JONES: Depending on how bad the injuries turned out to

11 be, yes.

12 MR GARNHAM: But you were not surprised to be given this?

13 PC JONES: No.

14 MR GARNHAM: Was that the sort of normal case that you would

15 receive?

16 PC JONES: Yes. I was going to say yes, we -- what happened

17 was when a case came in there was a list by the

18 computer, the CRIS machine, and we -- and they would go

19 down the list and give the workload as evenly as

20 possible I think.

21 MR GARNHAM: So each case as it came in would be given to

22 the next person on the list who had the most space?

23 PC JONES: Yes.

24 MR GARNHAM: That suggests that the allocation is done

25 without reference to the complexity of the allegation.

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1 PC JONES: Maybe if somebody had been on the team for maybe

2 a few weeks they might not have one of the most complex

3 cases.

4 MR GARNHAM: But once they had been there, as you had, for

5 some months or years they would take whatever case came

6 in next?

7 PC JONES: Yes.

8 MR GARNHAM: Did you feel equipped to handle this sort of

9 case?

10 PC JONES: Yes, I did at the time, yes.

11 MR GARNHAM: You felt you had been adequately trained?

12 PC JONES: I felt so, yes.

13 MR GARNHAM: That you had had adequate experience?

14 PC JONES: Yes, I had been on the CPT for some years by

15 then.

16 MR GARNHAM: And that you had had adequate support from

17 those above you in the ranks?

18 PC JONES: From my team I had support I would say, yes.

19 MR GARNHAM: By your team you mean all of those in the Child

20 Protection Team at Haringey?

21 PC JONES: Yes.

22 MR GARNHAM: What was your immediate reaction to hearing the

23 details of this incident, Ms Jones?

24 PC JONES: My immediate reaction?

25 MR GARNHAM: Yes, an eight year old girl in hospital with

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1 scalding injuries to her head, marks on her body

2 including a belt buckle mark or marks.

3 PC JONES: Well, I mean, my immediate reaction was just

4 really to just go and attend the meeting and find out

5 what I could, to go to the meeting and hear what the

6 information was.

7 MR GARNHAM: Did you take the view when you first heard

8 about it that it was the sort of case that would

9 inevitably warrant a full investigation?

10 PC JONES: Yes.

11 MR GARNHAM: So it was clear from the beginning before you

12 even got to the strategy meeting that you were going to

13 have to investigate this?

14 PC JONES: Yes.

15 MR GARNHAM: The meeting I think was at 2.30 that day.

16 PC JONES: Yes.

17 MR GARNHAM: Were you present throughout?

18 PC JONES: Was I present throughout the meeting?

19 MR GARNHAM: Yes.

20 PC JONES: Yes.

21 MR GARNHAM: It lasted about half an hour.

22 PC JONES: Yes.

23 MR GARNHAM: So you were out by 3 o'clock-ish.

24 PC JONES: Yes.

25 MR GARNHAM: It was chaired I think by Rose Kozinos.

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1 PC JONES: Yes.

2 MR GARNHAM: We have a set of notes or minutes of that

3 meeting in that same volume that is in front of you at

4 page 4. First of all can you confirm that those are

5 minutes of that meeting?

6 PC JONES: You said page 4?

7 MR GARNHAM: Is it my mistake?

8 PC JONES: Yes, it is not that.

9 MR GARNHAM: Is that not the strategy meeting?

10 PC JONES: That is not the one.

11 MR GARNHAM: Is that not the strategy meeting record for

12 28th July?

13 PC JONES: No.

14 MR GARNHAM: Are you in volume 30?

15 PC JONES: No.

16 MR GARNHAM: You have the wrong one. Volume 30 please. Now

17 do you have it?

18 PC JONES: Yes, I have it.

19 MR GARNHAM: Are those the minutes of that meeting?

20 PC JONES: Yes, it is.

21 MR GARNHAM: Those are the minutes of that meeting?

22 PC JONES: Yes.

23 MR GARNHAM: When did you first see those minutes?

24 PC JONES: It was after Victoria died.

25 MR GARNHAM: After Victoria had died?

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1 PC JONES: Yes.

2 MR GARNHAM: Was that unusual to get minutes so much after

3 the meeting?

4 PC JONES: No.

5 MR GARNHAM: So it was a common problem, was it?

6 PC JONES: Yes.

7 MR GARNHAM: Because it must have been a problem that you

8 did not have the minutes or notes of the meeting

9 prepared by the chair promptly thereafter.

10 PC JONES: Well, what usually happened when you went to

11 a strategy meeting or a case conference, et cetera, you

12 would not get the minutes straightaway. What you tended

13 to happen was they would always arrive late and

14 sometimes they would arrive in bulk so you would get

15 lots of other minutes as well all sent in at one time.

16 MR GARNHAM: Victoria died in February of 2000. This was

17 a meeting at the end of July. So we are talking about

18 a delay in excess of six months.

19 PC JONES: Yes.

20 MR GARNHAM: Was that unusual, a delay of that sort of

21 period in this service of the minutes?

22 PC JONES: No.

23 MR GARNHAM: It was normal?

24 PC JONES: Quite normal.

25 MR GARNHAM: What was the point of minutes if they arrived

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1 six months later?

2 PC JONES: Well, it was a problem that we had but what we

3 would do was to write down what the police task for the

4 police was on the CRIS machine.

5 MR GARNHAM: So you would make your own notes by some means

6 or other but it meant you did not have the collective

7 view of the meeting prepared by the chair until much

8 later?

9 PC JONES: That is right.

10 MR GARNHAM: And if it is as late as six months after the

11 meeting, would it be fair to say they are pretty

12 useless?

13 PC JONES: Not pretty useless but it would have been

14 obviously more appropriate to have them straightaway.

15 MR GARNHAM: Presumably many of the cases that are discussed

16 at strategy meetings are urgent?

17 PC JONES: Yes.

18 MR GARNHAM: Because they involve child protection concerns?

19 PC JONES: Yes.

20 MR GARNHAM: So to get the minutes six months later is not

21 of enormous help, is it?

22 PC JONES: No, but you would have been at the strategy

23 meeting.

24 MR GARNHAM: And you rely on your own notes?

25 PC JONES: Yes.

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1 MR GARNHAM: You presumably made your own handwritten notes,

2 did you, during the course of this meeting?

3 PC JONES: Yes, I did.

4 MR GARNHAM: Were you noting down just the tasks that were

5 allocated to you or were you noting down everything else

6 that was decided at the meeting?

7 PC JONES: I think I -- I cannot remember.

8 MR GARNHAM: What was your usual practice?

9 PC JONES: My usual practice, it varies. If there were

10 many, many tasks, many people at the meeting I might

11 stick to my own tasks. If it was a shorter meeting and

12 I could write everything down I would write everything

13 down.

14 MR GARNHAM: Do you remember what you did in Victoria's

15 case?

16 PC JONES: I cannot remember for certain.

17 MR GARNHAM: That makes it sound as if you have some idea.

18 PC JONES: I think I may have written down everybody's tasks

19 but I cannot say for sure.

20 MR GARNHAM: Because unfortunately you did not keep those

21 notes?

22 PC JONES: No, I did not.

23 MR GARNHAM: You tell us that you used those notes as the

24 basis for your entry in the CRIS report?

25 PC JONES: Yes.

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1 MR GARNHAM: And then you destroyed them?

2 PC JONES: Yes.

3 MR GARNHAM: When you attended this meeting there was, to

4 put it at its lowest, the possibility that you were

5 investigating a crime?

6 PC JONES: Yes.

7 MR GARNHAM: Were those notes not then documents which you

8 ought to have kept? Might they become disclosable if

9 there were to be a subsequent prosecution, disclosable

10 to the defence?

11 PC JONES: Well, it could be. It could have been but I was

12 not actually dealing with a crime at that stage.

13 MR GARNHAM: Well you were at the very least dealing with

14 the early stages of what was potentially a criminal

15 investigation.

16 PC JONES: Yes.

17 MR GARNHAM: Is that right?

18 PC JONES: Yes.

19 MR GARNHAM: So should you not for that reason, if for none

20 other, have kept those notes?

21 PC JONES: Well, quite possibly I should have kept the notes

22 but I did not and I updated the CRIS machine using those

23 notes and destroyed the notes after.

24 MR GARNHAM: Yes. Let us look at your entry on the CRIS

25 printout. It starts at volume 30, page 111. Take us to

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1 the first entry you make. I think you may have to go on

2 a few pages.

3 PC JONES: Right.

4 MR GARNHAM: Can you find page 30/115.501.

5 PC JONES: Thank you.

6 MR GARNHAM: This is a continuation of the report. Where do

7 we find your first entry, please?

8 PC JONES: Well, my first entry would be to, if you look on

9 the first page, it has got that I noted the crime. It

10 is in the first section.

11 MR GARNHAM: This is at 115.501?

12 PC JONES: Yes. It has got my name, "investigating

13 officer", and a little bit down it has got "noted" with

14 a "Y", I would have put that.

15 MR GARNHAM: Y indicates yes to say you have noted it?

16 PC JONES: Yes.

17 MR GARNHAM: The time you did that was 7.47 on 2nd November.

18 I think that might be the wrong entry.

19 PC JONES: Yes, I thought it might be. You want July.

20 MR GARNHAM: Yes.

21 PC JONES: If you go to 30, 131 .501.

22 MR GARNHAM: Thank you.

23 PC JONES: The same thing again, I put "Y" in the "noted"

24 box on 29th July 1999, at 8.07.

25 MR GARNHAM: It is noted in the second line of that entry

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1 "Crime type: B." We have some explanation: "Enter A for

2 attempt or C for conspiracy". You have entered B. What

3 does B mean?

4 PC JONES: I did not enter that. This was my sergeant, by

5 Sergeant Cooper-Bland.

6 MR GARNHAM: Can you tell us what B means?

7 PC JONES: I cannot remember. I think it is a beat crime

8 but that does not -- I am not sure what the B means.

9 MR GARNHAM: You used your notes to complete your CRIS entry

10 I think?

11 PC JONES: Yes.

12 MR GARNHAM: Where do we find that?

13 PC JONES: If you go to --

14 MR GARNHAM: 504?

15 PC JONES: Yes.

16 MR GARNHAM: Yes.

17 PC JONES: That is where I begin my notes.

18 MR GARNHAM: So the passage that begins "Shanti Jacobs,

19 social worker"?

20 PC JONES: No. If you go down the page, at one part it says

21 "OIC changed", but if you go right down again to the

22 last, Karen Jones, "KJ Jones".

23 MR GARNHAM: "... said that the family had been in England

24 for four months".

25 PC JONES: Yes.

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1 MR GARNHAM: Then over the page.

2 PC JONES: Yes.

3 MR GARNHAM: "At hospital mother told Dr" -- that is meant

4 to be Forlee is it?

5 PC JONES: Yes.

6 MR GARNHAM: "... that on the 24th at about 12 midday Anna

7 had been itching and went to the bathroom. Child has

8 scabies. Highly infectious. Mum heard scream, went to

9 the bathroom to see that Anna had scalded her head by

10 pouring hot water on it to stop the itching. Hospital

11 noticed that the child was very unkempt, dirty dress, no

12 underwear. Mum well dressed. Child injuries bad, kept

13 on Rainbow Ward. Other old injuries noted on diagram.

14 11 scars in total, two of which are said to be the same

15 shape. Full body skeletal and photos taken by hospital.

16 They are not available yet but I have asked if it is

17 possible for hospital to use photos to save putting the

18 child through the ordeal of photos again. Has not been

19 spoken to about them."

20 There is a missing word there.

21 PC JONES: I think it must be "mother".

22 MR GARNHAM: "... has not been spoken to about the marks

23 when she visited Anna on the ward. The child wet

24 herself. There are concerns as to how she got the old

25 marks. I have asked for statement from the doctors.

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1 Have also asked if these could have been caused by the

2 child itching."

3 PC JONES: It goes on.

4 MR GARNHAM: "Secondly, how on earth did she get scabies and

5 how long has she had it? Apparently it can spread

6 through touch. Unsure if people are allowed to travel

7 with this disease."

8 I cannot read the next word.

9 PC JONES: "Unsure if people are allowed to travel with this

10 disease. How did the original injuries occur?" I think

11 that should say.

12 MR GARNHAM: "No records of family in England. Was decided

13 that police would contact Immigration. SS to contact

14 international SS. Hospital to provide statements.

15 Police and social workers to visit mother once statement

16 is available. Child not suitable to leave hospital

17 because of injuries and home condition unknown.

18 A PPO" -- is that Police Protection Order?

19 PC JONES: Yes.

20 MR GARNHAM: -- "can be taken out if mother attempts to take

21 her."

22 PC JONES: Yes.

23 MR GARNHAM: Is that right? Now, does that represent your

24 recollections of what went on at the strategy meeting?

25 PC JONES: Yes.

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1 MR GARNHAM: Does that reproduce what you had in your own

2 handwritten notes which you destroyed?

3 PC JONES: Yes.

4 MR GARNHAM: That being so, did you think you were

5 disadvantaged by not having the chair's notes of that

6 meeting?

7 PC JONES: I did not feel disadvantaged but obviously the

8 chair's notes would be helpful.

9 MR GARNHAM: For what purpose?

10 PC JONES: Because you could look back.

11 MR GARNHAM: Confirm the accuracy of your note?

12 PC JONES: Yes.

13 MR GARNHAM: Have you since read the chair's notes?

14 PC JONES: Yes, I have.

15 MR GARNHAM: Was there material there which you had not

16 recorded?

17 PC JONES: Could I have another look at it?

18 MR GARNHAM: You can. They are at page 4 in that bundle.

19 It is probably page 7 and 8 are the ones that matter.

20 You recall see in the first paragraph that they note

21 that the marks on Victoria's body look like a belt

22 buckle mark/marks.

23 PC JONES: Yes.

24 MR GARNHAM: That is not something you put in the CRIS

25 report but you knew it?

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1 PC JONES: Yes. Yes, I did know it but I think I did not

2 put it in the CRIS report but it was already in the CRIS

3 report.

4 MR GARNHAM: Quite right, but the point is you knew it?

5 PC JONES: Yes.

6 MR GARNHAM: There is also reference to concerns re neglect,

7 child very unkempt, mother was not, but you got the

8 substance of that point, did you not?

9 PC JONES: Yes, the child was said to be very unkempt, in

10 a dirty dress, no underwear, while mum was well dressed.

11 MR GARNHAM: There are on page 8 a list of eighteen tasks.

12 You do not get all of those?

13 PC JONES: No.

14 MR GARNHAM: Not all of them are directed to you?

15 PC JONES: No.

16 MR GARNHAM: Would it have been helpful to know by reference

17 to these notes what others were doing?

18 PC JONES: It would have been helpful but I was at the

19 meeting so I would have known. I know it is not on the

20 CRIS reports but ...

21 MR GARNHAM: But you personally were not disadvantaged then?

22 PC JONES: By not having the notes?

23 MR GARNHAM: Yes.

24 PC JONES: Well, as I say, I cannot say I was disadvantaged

25 but it would have been helpful to have the notes.

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1 MR GARNHAM: Can I ask you a little about how that meeting

2 progressed? I think it is right, is it not, that

3 Karen Johns was the main informant?

4 PC JONES: Yes.

5 MR GARNHAM: And you set out what you recall her saying in

6 paragraphs 10 to 13 of your statement. Karen Johns says

7 to us that she reported to the meeting Dr Rossiter's

8 views. Do you recall that?

9 PC JONES: No.

10 MR GARNHAM: I wonder if you could have volume 5, please,

11 page 253. At the bottom of 253, and this is

12 Karen Johns' notes, she records a telephone conversation

13 with Dr Rossiter. She notes "anxious attachment, at

14 least neglect, probably emotional abuse, possible

15 physical abuse". She has told us that she reported that

16 to the strategy meeting. Do you recall that?

17 PC JONES: No. I certainly knew there was, well, it was an

18 ABH, suspicion of an ABH that we were investigating.

19 MR GARNHAM: So that was the possible physical abuse?

20 PC JONES: Yes.

21 MR GARNHAM: Do you remember there being discussions about

22 probable emotional abuse?

23 PC JONES: No.

24 MR GARNHAM: Do you not recall the fact that one of the

25 decisions made at that strategy meeting was that

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1 a statement would be obtained from the ward dealing with

2 the emotional abuse allegations?

3 PC JONES: No.

4 MR GARNHAM: A task given to Karen Johns?

5 PC JONES: I do not recall that.

6 MR GARNHAM: It certainly is referred to as one of the

7 eighteen tasks in the notes I have referred you to but

8 you do not recall it?

9 PC JONES: No, I mean I know there was a task that she had

10 about collecting the statement of neglect possibly.

11 MR GARNHAM: I am sure that is related to the same subject

12 matter. You remember that?

13 PC JONES: Well, after seeing the notes, yes.

14 MR GARNHAM: There is also said to be reported to that

15 meeting concerns about Victoria's interaction with her

16 mother. Do you recall that being discussed? You told

17 us about dirty dress and smart dress by mother. Were

18 you told about how the two of them got on?

19 PC JONES: Not at that stage.

20 MR GARNHAM: Do you remember being told that mother had

21 brought no clean clothes in for Victoria?

22 PC JONES: Not at that stage.

23 MR GARNHAM: Do you remember it being discussed that

24 Victoria came to attention or behaved in an unusual way

25 when her mother arrived?

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1 PC JONES: No, not at that stage. I am trying to be careful

2 here because obviously I have read a lot and I do not

3 want to mix it up in my mind.

4 MR GARNHAM: Thank you for that care. Do you recall whether

5 at that meeting there was discussion about Victoria

6 wetting herself?

7 PC JONES: Yes, I definitely remember there was some

8 discussion about Victoria wetting herself.

9 MR GARNHAM: Do you remember whether Karen Johns took with

10 her to that meeting copies of some documentation from

11 the hospital?

12 PC JONES: Did she bring to the meeting? Yes, she did.

13 MR GARNHAM: In particular did she bring three copies of

14 a little bundle of documentation which included the

15 CP forms, the Accident and Emergency card and the body

16 maps?

17 PC JONES: Yes.

18 MR GARNHAM: Did you get a copy of that little bundle?

19 PC JONES: Yes, I did.

20 MR GARNHAM: Do you have any recollection of the way in

21 which Karen Johns made her contribution to that meeting?

22 PC JONES: Of the way?

23 MR GARNHAM: Yes, did she appear to know what she was about

24 or was she vague?

25 PC JONES: She appeared to know what she wanted to tell us.

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1 MR GARNHAM: And her contribution was precise enough, was

2 it, to enable the list of actions to be drawn up?

3 PC JONES: I think so, yes. The thing that was vague was

4 exactly what it was we were dealing with rather than

5 Karen Johns.

6 MR GARNHAM: Although even in that regard you knew that

7 there was talk about neglect or emotional abuse.

8 PC JONES: Well, there was talk about neglect in that

9 Victoria did not have clean clothes and such, and any

10 allegation could have that emotional abuse attached to

11 it as well.

12 MR GARNHAM: You knew that there was at least a suspicion of

13 physical abuse?

14 PC JONES: Yes.

15 MR GARNHAM: Did Karen Johns, do you recall, draw the

16 meeting's attention to the swellings and marks on

17 Victoria's upper arms?

18 PC JONES: She gave us the body map and I do not know if she

19 went through each -- I do not think she went through

20 each mark individually but I had the impression that we

21 had the body marks so we could see --

22 MR GARNHAM: You do not remember he expressing particular

23 concern about those?

24 PC JONES: No, but when you say concern...

25 MR GARNHAM: That she was particularly bothered, worried

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1 about marks on the upper arm?

2 PC JONES: She was not -- I would not say she was not

3 concerned but she -- I understood it that that map had

4 been drawn so that we could see exactly where the marks

5 were rather than her having to describe it to us.

6 MR GARNHAM: Can you go back to volume 30, page 8, please.

7 I do not want you to read them all out, there is

8 a lengthy list, but can you identify those which you

9 regarded as your job?

10 PC JONES: Okay.

11 MR GARNHAM: Starting from the top.

12 PC JONES: Number 18:

13 "PCPT complete immigration checks."

14 MR GARNHAM: Yes.

15 PC JONES: Then it says, if you look, I think it is

16 number 7:

17 "Once we have medical reports, arrange joint visit

18 with PCPT and explain fully the child protection

19 procedures to mother."

20 MR GARNHAM: Yes.

21 PC JONES: Then there is "Hospital social worker to inquire

22 re hospital photographs". That is the hospital and

23 social worker one but it says can this be given to

24 social services and police.

25 MR GARNHAM: That is number 12, is it?

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1 PC JONES: Yes, sorry.

2 MR GARNHAM: Yes.

3 PC JONES: And at the bottom, I think it is cut off, it is

4 number 16, there is a bit about where child to remain in

5 hospital; if mum attempts to take her hospital to

6 contact us. I think there had been more on that about

7 a police protection could be arranged if it was needed.

8 MR GARNHAM: Thank you. Would it be right that in addition

9 to item 12, which you have already told us about, the

10 hospital social worker Karen Johns would also be

11 responsible for item 4, "Obtaining report from hospital

12 social worker re concerns of neglect"?

13 PC JONES: Yes.

14 MR GARNHAM: And 5, "Staff nurses, hospital to monitor

15 contact with child and report back any concerns"?

16 PC JONES: Yes.

17 MR GARNHAM: I think 4 goes on where it becomes illegible:

18 "Hospital association worker to inform social services

19 when child ready for discharge."

20 PC JONES: Yes.

21 MR GARNHAM: And the bulk of the other tasks were for

22 Haringey.

23 PC JONES: Yes.

24 MR GARNHAM: Is that right?

25 PC JONES: Yes.

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1 MR GARNHAM: So who did you understand would be obtaining

2 the medical report which is referred to by I think item

3 number 2?

4 PC JONES: I understood that Karen Johns was going to obtain

5 that and pass it on to social services.

6 MR GARNHAM: You did not I think mention that when I asked

7 you to run through the list of tasks, but it may be

8 I misled you. You think that is her task as well?

9 PC JONES: Yes.

10 MR GARNHAM: Rather than Haringey?

11 PC JONES: Yes.

12 MR GARNHAM: Thank you. In fact, I think you tell us that

13 it was you who asked Karen Johns to obtain a medical

14 report.

15 PC JONES: And photos.

16 MR GARNHAM: And photos, and the reason that you wanted her

17 to do that?

18 PC JONES: Shall I start with the medical report?

19 MR GARNHAM: Please.

20 PC JONES: I wanted her to obtain the medical reports

21 because she was the hospital social worker, she had come

22 from the hospital, it would have been the easier link.

23 The link would have been much smoother if Karen Johns,

24 she would go back to her department and speak to the

25 doctors or staff who she knew and who were familiar with

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1 her, whereas it would be quite difficult from me to get

2 reports as easily as she could.

3 MR GARNHAM: I will come back to that. You also mentioned

4 the photographs.

5 PC JONES: The photographs had been taken by the hospital.

6 I think that Karen Johns had brought this information to

7 the meeting and I asked if I could use those photographs

8 rather than having another set.

9 MR GARNHAM: And you explained the reason for that is you

10 did not want to expose Victoria to the stress of having

11 another set of photographs.

12 PC JONES: Yes, that is right.

13 MR GARNHAM: Would you go to volume 5, please. Page 263.

14 Have you seen that before? That is a memo from

15 Karen Johns to Dr Meates. Have you seen it before?

16 PC JONES: I have seen it since disclosure from the Inquiry.

17 MR GARNHAM: Second paragraph:

18 "I would also like to ask your advice/assistance in

19 relation to a matter raised by Karen Jones. They would

20 find it very helpful to have copies of the medical

21 photographs. Could you please let me know if this is

22 possible and how it might be arranged."

23 So that faithfully represents her passing on your

24 request to the doctors.

25 PC JONES: Yes.

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1 MR GARNHAM: The reply is on the previous page and it is by

2 way of an endorsement and on a copy of the memo:

3 "Karen, medical photographs have been ordered but

4 not yet taken. If the police want copies of them there

5 should be no problem as long as they follow the

6 procedures, which I am sure you will know."

7 Did you get a copy of that?

8 PC JONES: No.

9 MR GARNHAM: Did you get told what is in it?

10 PC JONES: No.

11 MR GARNHAM: Did you know what the procedures were that you

12 should follow in order to get photographs?

13 PC JONES: No, I did not know them offhand but I would have

14 rung up and found out, if ever I needed a statement from

15 the hospital you would ring up and find out.

16 MR GARNHAM: It was, was it not, your job to obtain the

17 photographs if you wanted to use them for police

18 purposes?

19 PC JONES: Obtain as in go to the hospital and collect them?

20 MR GARNHAM: No, do whatever is necessary to make sure they

21 end up in your hands.

22 PC JONES: Yes.

23 MR GARNHAM: So that if the route you had suggested during

24 the course of that meeting, i.e. via Karen Johns, did

25 not work, it was still for you to get the photographs if

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1 you wanted them?

2 PC JONES: Yes.

3 MR GARNHAM: You did not get them through the route

4 suggested via Karen Johns?

5 PC JONES: That is correct.

6 MR GARNHAM: What did you do to make sure you had them?

7 PC JONES: Well, what happened was I had asked for the

8 photographs obviously so that I could have them. When

9 I spoke to Lisa on the 3rd, sorry, the 5th August, she

10 produced a letter from Nurse Quinn which contained

11 Dr Rossiter's diagnosis of Victoria and it led us, it

12 led me to believe that Victoria had not suffered

13 a non-accidental injury and as that had happened, as she

14 had not suffered a non-accidental injury, therefore I

15 did not need the photographs.

16 MR GARNHAM: I will come back to that letter in a moment but

17 make sure I have got your evidence clear. You decided

18 not to pursue what would otherwise have been one of your

19 jobs, getting these photographs, because of the memo or

20 the letter you saw from Nurse Quinn?

21 PC JONES: Yes, which contained Dr Rossiter's diagnosis.

22 MR GARNHAM: Yes.

23 PC JONES: I mean, when I got that letter, when I read what

24 happened to Victoria, which pointed out that there was

25 no non-accidental injury, then that meant there was no

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1 ABH and so there was no need for the photographs.

2 MR GARNHAM: I think you are going to tell us, are you not,

3 that it was that piece of information that led you to

4 suspend all of your investigations into this case?

5 PC JONES: Well, no, I did not suspend them all at that

6 point. I did carry on. I spoke to Marie-Therese Kouao

7 and to Victoria.

8 MR GARNHAM: But it is right, is it not, from the time you

9 saw that memo, that letter from Quinn, to which we will

10 return, you were of the view that there was no longer

11 a crime being alleged?

12 PC JONES: Yes.

13 MR GARNHAM: At the time when you were first considering

14 obtaining the photographs, would it not have been much

15 better practice for you to arrange for a police

16 photographer to see Victoria?

17 PC JONES: No, because a police photographer would just take

18 the same pictures.

19 MR GARNHAM: Yes, but a police photographer would be able to

20 provide continuity evidence were this matter to go to

21 trial.

22 PC JONES: Well, it is considered that in a case like this

23 it is perfectly okay to use hospital photographs.

24 MR GARNHAM: By whom is it considered?

25 PC JONES: At the CPT.

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1 MR GARNHAM: You mean in Haringey or wider?

2 PC JONES: I can only say for Haringey.

3 MR GARNHAM: Would you not agree though now, looking at it,

4 that it is much better for a police photographer to take

5 photographs that might be used for prosecution?

6 PC JONES: Are you talking in hindsight?

7 MR GARNHAM: Yes.

8 PC JONES: I would say yes but I still think that you would

9 have to consider it carefully because that means you are

10 putting a child -- to have these photographs again may

11 quite possibly -- not unnecessarily but you have to

12 think, "Is this going to be too distressful for

13 a child?"

14 MR GARNHAM: How else would you deal with an allegation,

15 a suggestion made by the defence in a criminal case that

16 followed that the photographs had been retouched?

17 PC JONES: Well, if you can take a second photo then that is

18 all well and good but if you are going to distress

19 a child then you have to take that chance I think.

20 MR GARNHAM: Did you consider that ultraviolet photographs

21 might assist in a case like this?

22 PC JONES: No, I did not consider it.

23 MR GARNHAM: Do you know what ultraviolet photography is

24 used for in child protection cases?

25 PC JONES: Well, I think, I do not really know but I think

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1 it might be useful to see semen stains and things, or

2 I might have that completely wrong.

3 MR GARNHAM: It can be used to detect bruises that are not

4 visible to the naked eye, amongst other things.

5 PC JONES: Right.

6 MR GARNHAM: It may well be that you would not have known

7 that because it is a photographic matter, but if you had

8 referred the matter to a police photographer he would

9 have been, or she would have been in a position to

10 advise whether that might be a course open to you, would

11 he or she not?

12 PC JONES: That might be so but at the time I was led to

13 believe that Victoria's marks had been seen with the

14 naked eye.

15 MR GARNHAM: Yes, but that begs the question as to whether

16 there were other marks that could not be so seen, does

17 it not?

18 PC JONES: Yes.

19 MR GARNHAM: Would good practice not have dictated that you

20 should have referred this case for a police photographer

21 to take photographs, not relying on the hospital?

22 PC JONES: No. I was never told to do that and I thought it

23 was good practice to just use the photographs from the

24 hospital.

25 MR GARNHAM: It appears from the way you deal with the

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