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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 151 to 200

151



1 MR GARNHAM: Because the CRIS notes suggest incident at

2 12 midday, arrival at hospital at 5.25. I can take you

3 to them if you need it, but would you accept that from

4 me?

5 PC JONES: I accept that.

6 MR GARNHAM: If you had done that check you would have seen

7 this was an inconsistent story?

8 PC JONES: Yes.

9 MR GARNHAM: Even on what you were told by Kouao, it is

10 a bit odd, is it not, 3 o'clock incident, 5 o'clock

11 arrival at the hospital?

12 PC JONES: There was a time delay, yes. But --

13 MR GARNHAM: What did you think about that when you heard

14 it?

15 PC JONES: I overlooked it.

16 MR GARNHAM: I see, you overlooked both --

17 PC JONES: I did not realise the time delay.

18 MR GARNHAM: I am sorry, I had thought you merely overlooked

19 the point that if you had gone back to the notes you

20 would have seen there was a five hour delay, but you are

21 saying you also overlooked the fact that on her own

22 account there was a two hour delay plus?

23 PC JONES: I overlooked the entire delay, if you want it put

24 like that.

25 MR GARNHAM: Thank you. Did you ask Kouao about any of the

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1 concerns that had been expressed about Victoria?

2 PC JONES: Yes, I did.

3 MR GARNHAM: Did you ask her about how the marks came to be

4 on her body?

5 PC JONES: Yes, I did.

6 MR GARNHAM: What was your answer? Scratching?

7 PC JONES: She said that it was more or less down to

8 scratching. Victoria would use a wooden fork or

9 a spoon, she said, to scratch her.

10 MR GARNHAM: Did you ask her about the scar, the shape of

11 which resembled a belt buckle mark?

12 PC JONES: I asked her about scars and she said Victoria had

13 had a few from before.

14 MR GARNHAM: She had had a few from before?

15 PC JONES: Yes.

16 MR GARNHAM: And you regarded that as an adequate

17 explanation, did you?

18 PC JONES: Well, yes I did. Because the doctor -- the

19 hospital had -- Victoria had been in hospital for some

20 days now and nobody had said -- or no one reported their

21 concerns about Victoria or the marks or scars that she

22 had.

23 MR GARNHAM: Well, you know I have suggested the contrary to

24 you, but assuming you are right about that, the fact

25 that they were old scars does not explain, does it, the

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1 fact that there are scars there that resemble a belt

2 buckle?

3 PC JONES: Can you ask that again?

4 MR GARNHAM: She said to you, when you asked her about the

5 scars, some of them were old.

6 PC JONES: Yes.

7 MR GARNHAM: That alone, even if they were old, would not

8 explain, if they resembled a belt buckle, why they

9 resembled a belt buckle?

10 PC JONES: No, but the hospital should have done that.

11 MR GARNHAM: Yes, but the fact that the hospital say nothing

12 about it does not help you decide the cause of those

13 scars, does it?

14 PC JONES: It does not help me decide cause but what it

15 tells me is that we are not dealing with

16 a non-accidental injury.

17 MR GARNHAM: I see. Did you ask Kouao about the suggestion

18 that Anna, as she was being called, wet herself when her

19 mother came to visit?

20 PC JONES: No, what I asked her about bed wetting -- if

21 I can just have a look at my statement?

22 MR GARNHAM: Yes.

23 PC JONES: I asked her about bed wetting and she said that

24 Victoria had been bed wetting since her father had died.

25 MR GARNHAM: Did you ask her about the suggestion in the

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1 notes to the effect that, when Kouao came to visit her

2 daughter, as she was made out to be, Victoria wet

3 herself where she stood?

4 PC JONES: No I did not.

5 MR GARNHAM: Why not?

6 PC JONES: I am not quite sure if I knew about the bed

7 wetting in detail at that time.

8 MR GARNHAM: You say that had not been discussed at the

9 strategy meeting.

10 PC JONES: No.

11 MR GARNHAM: Did you ask her why she had brought no clean

12 clothes for Victoria in hospital?

13 PC JONES: I did not ask her why she had brought no clean

14 clothes. I asked her about --

15 MR GARNHAM: She turned up in a dirty dress?

16 PC JONES: Yes.

17 MR GARNHAM: What about not bringing clean clothes while

18 Victoria was in hospital?

19 PC JONES: I did not ask her about that. After she had

20 explained about picking up the dirty dress and after we

21 had spoken to her it became clear they just seemed to be

22 a family of very little means or little money.

23 MR GARNHAM: Yes, but even the poorest family can wash

24 clothes.

25 PC JONES: Well --

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1 MR GARNHAM: So why had she not brought in some clean

2 dresses and underwear for Victoria in hospital?

3 PC JONES: I did not ask her that.

4 MR GARNHAM: Why not?

5 PC JONES: I asked her in general -- I do not think that

6 everybody brings in clean clothes for their children all

7 the time. Some families are quite different from

8 others.

9 MR GARNHAM: But according to the information you had, this

10 woman had never done that. Never brought in clean

11 clothing. But you did not ask.

12 PC JONES: I did not ask, no.

13 MR GARNHAM: Did you ask her about schooling?

14 PC JONES: I did not ask her about schooling.

15 MR GARNHAM: Why not?

16 PC JONES: That would not be part of my role, my job. The

17 schooling would be for social services to consider.

18 MR GARNHAM: Did you ask whether Victoria had a GP?

19 PC JONES: No, once again that would be something for social

20 services to consider.

21 MR GARNHAM: You then obtained Kouao's permission to speak

22 to Victoria.

23 PC JONES: Yes.

24 MR GARNHAM: And Kouao told you Victoria could speak and

25 understand English.

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1 PC JONES: Yes.

2 MR GARNHAM: Had there been any discussion about Victoria's

3 use of English at the strategy meeting?

4 PC JONES: Not that I can remember.

5 MR GARNHAM: Did you know Victoria's first language was

6 French?

7 PC JONES: I knew her name was Anna, you see.

8 MR GARNHAM: Sorry, how does that help us?

9 PC JONES: You asked me if it was French. I would not

10 regard --

11 MR GARNHAM: Her language, her first language.

12 PC JONES: I thought you said her name. I think at first we

13 were told the family were French. But I cannot remember

14 about language. But I would have probably assumed they

15 spoke French.

16 MR GARNHAM: Were you able to have a free conversation with

17 Victoria in English?

18 PC JONES: Yes.

19 MR GARNHAM: You describe her English at one point in your

20 statement as being broken English.

21 PC JONES: Yes.

22 MR GARNHAM: Did you think that a conversation in broken

23 English was sufficient for an interview of this sort?

24 PC JONES: Yes, I could understand Victoria and she appeared

25 to understand me.

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1 MR GARNHAM: Were you confident you could get from her the

2 subtleties of the conversation in English?

3 PC JONES: Yes.

4 MR GARNHAM: It had been suggested, had it not, that Kouao

5 would need an interpreter?

6 PC JONES: Yes.

7 MR GARNHAM: And an interpreter turned up for that meeting,

8 although not much used?

9 PC JONES: Yes.

10 MR GARNHAM: Why did you not offer the same facility when

11 you spoke to Victoria?

12 PC JONES: Well, at the meeting Mrs Kouao said Victoria

13 could speak English and we took her word for it and

14 Victoria did speak English.

15 MR GARNHAM: Broken English.

16 PC JONES: Maybe I can help you. If you can maybe imagine

17 going to France and speaking to someone in France and

18 they have an accent and if they are speaking in English

19 they have an accent and maybe they will not pronounce

20 all their verbs as you might pronounce them, that is

21 what I mean by broken English.

22 MR GARNHAM: Apart from accent and correct pronunciation of

23 verbs her English was fine?

24 PC JONES: I could understand her and she could understand

25 me.

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1 MR GARNHAM: Kouao told you Victoria had been bed wetting

2 since her father died.

3 PC JONES: Yes.

4 MR GARNHAM: Did that not prompt you to ask whether Victoria

5 had seen a doctor about this?

6 PC JONES: We asked about bereavement counselling.

7 MR GARNHAM: With what reply?

8 PC JONES: She said Victoria had not had any.

9 MR GARNHAM: Did you pursue that any further?

10 PC JONES: That was a matter for social services.

11 MR GARNHAM: I wonder if you could have a look again at

12 Lisa Arthurworrey's witness statement, please.

13 Volume 2, page 81, in paragraphs 116 to 118

14 Miss Arthurworrey sets out her observations arising out

15 of that interview:

16 "...Kouao seemed to be very focused on her own

17 social issues such as finding work and housing."

18 Arthurworrey had to emphasise that, "The purpose of our

19 meeting was to see whether it was safe for Victoria to

20 be discharged."

21 Do you agree with that?

22 PC JONES: Well, I would not disagree with it but I perhaps

23 maybe would not put it in the same way as Lisa.

24 MR GARNHAM: How would you put it differently then?

25 PC JONES: Mrs Kouao, she responded to the questions that we

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1 asked her and she spoke about wanting to find work, and

2 about her housing situation. And -- but my impression

3 was that she -- we did not have to say to her, you know,

4 refocus on Victoria; she seemed to be -- playing the

5 part as I put it I think, that she was focused on

6 Victoria.

7 MR GARNHAM: "The hospital had described Kouao as being

8 elegantly dressed. However, when we met with her

9 I considered she had normal clothing which did not

10 strike me as being particularly elegant. I thought

11 Kouao's manner was that of a very proud woman."

12 Agree?

13 PC JONES: I certainly considered her clothing to be of --

14 MR GARNHAM: Normal?

15 PC JONES: Normal, yes. I would -- I do not know what she

16 means by "proud woman".

17 MR GARNHAM: "Prior to the office visit I had been concerned

18 that the home environment may not be too good based on

19 the suspicion that Victoria had caught scabies from the

20 home address. After interviewing Kouao, it appeared

21 that Victoria had caught scabies from a filthy bed and

22 breakfast hotel. Kouao explained to us that the home

23 was very good, was kept clean and tidy, and that the

24 only problem with their current accommodation was that

25 it was too small."

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1 Agree?

2 PC JONES: Yes.

3 MR GARNHAM: You say you think you went straight home after

4 that meeting?

5 PC JONES: Yes.

6 MR GARNHAM: By the time you left, what conclusions had you

7 reached about Kouao and Victoria?

8 PC JONES: Well, the conclusions I reached were that we were

9 not dealing with a non-accidental injury and it --

10 MR GARNHAM: Had that been a possibility when you entered

11 the meeting then?

12 PC JONES: Before meeting Lisa?

13 MR GARNHAM: Yes.

14 PC JONES: Yes, because I did not seen the report yet, and

15 that we would speak to Victoria the next day, and she

16 answered all our questions, she had turned up -- she was

17 acting as appropriately as she could, except her

18 parenting skills seemed little bit poor.

19 MR GARNHAM: So the position was you would speak to Victoria

20 the next day and if there was nothing different that

21 would be the end of that?

22 PC JONES: Yes.

23 MR GARNHAM: Did you discuss the case with Sergeant Bird or

24 with any of your other supervising officers?

25 PC JONES: No, I spoke to Sergeant Bird to tell him I was

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1 going to the hospital, because it would have -- I could

2 not have fitted it in during the day.

3 MR GARNHAM: That was all just to inform him you were going

4 to the hospital?

5 PC JONES: Yes, I think so.

6 MR GARNHAM: Did you then write your notes that night?

7 PC JONES: I think I wrote them up the following day.

8 MR GARNHAM: Next day you met Arthurworrey at North

9 Tottenham, travelled together to the NMH?

10 PC JONES: Yes.

11 MR GARNHAM: How long did the meeting at the NMH last?

12 PC JONES: I would say half an hour to three-quarters of an

13 hour.

14 MR GARNHAM: All that time spent with Victoria?

15 PC JONES: There would be about maybe five or ten minutes in

16 the ward in the beginning and at the end roughly.

17 MR GARNHAM: So between 10 and 20 minutes on the ward, and

18 the remaining --

19 PC JONES: No, maybe ten minutes on the ward and the

20 remaining --

21 MR GARNHAM: Half an hour with Victoria?

22 PC JONES: Yes.

23 MR GARNHAM: A nurse had introduced you to Victoria.

24 PC JONES: Yes.

25 MR GARNHAM: Did you know the name of the nurse?

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1 PC JONES: No.

2 MR GARNHAM: You still do not?

3 PC JONES: I have read it but I do not remember, I am sorry.

4 MR GARNHAM: Presumably you could see the scars to

5 Victoria's face as soon as you met her.

6 PC JONES: Yes.

7 MR GARNHAM: I wonder if you could have volume 37, please.

8 Is that still in front of you? Page 211, the first of

9 the photographs after that page show Victoria, and they

10 are ones we in this Inquiry have seen before. They show

11 her with a significant marking to her face.

12 PC JONES: Yes.

13 MR GARNHAM: If you look through them, it is suggestive of

14 widespread scalding injuries across her face and

15 forehead.

16 PC JONES: Yes.

17 MR GARNHAM: Was that how she looked to you?

18 PC JONES: I cannot remember.

19 MR GARNHAM: But you must have a picture in your mind of

20 what Victoria looked like when you first met her.

21 PC JONES: Yes, but it seemed to be just -- more to this

22 side of the face (indicates) from memory.

23 MR GARNHAM: What was your reaction to the sight of her with

24 those burns?

25 PC JONES: Well, it was horrible to see.

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1 MR GARNHAM: You then introduced yourself to her in French.

2 PC JONES: Yes.

3 MR GARNHAM: She told you she spoke English.

4 PC JONES: Yes.

5 MR GARNHAM: What did you ask her?

6 PC JONES: I asked her her name, I introduced -- as you say

7 I introduced myself, introduced Lisa, I said it was okay

8 and that Mrs Kouao had said she could talk to us. And

9 so we went into a private room -- sorry, can I have

10 a look at my statement?

11 MR GARNHAM: Yes.

12 PC JONES: I asked her about her account of what had

13 happened to her.

14 MR GARNHAM: With regard to the scalding?

15 PC JONES: Yes.

16 MR GARNHAM: And she said?

17 PC JONES: That she had poured water on to her head.

18 And I asked her about -- I think, I do not know if

19 I said scars, but I asked her about scars or marks and

20 she said she itched sometimes with a wooden fork.

21 MR GARNHAM: Did you ask to look at the scars?

22 PC JONES: No, that would not be my place to do that.

23 MR GARNHAM: Did you think her explanation of how the

24 scarring to the face had occurred fitted with a child of

25 her age and intelligence?

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1 PC JONES: Well, that was something that the doctors --

2 Victoria had been in hospital since the 24th and it was

3 now the 6th and it was something that the doctors had

4 looked into and they had accepted that that could have

5 happened.

6 MR GARNHAM: But did you ask yourself from an ordinary human

7 point of view how it is that a child first of all starts

8 to tip water hot enough to burn her over her face, and

9 then continues to do it to produce the scars you could

10 see?

11 PC JONES: I accepted what the hospital had said, because

12 they were the experts in this.

13 MR GARNHAM: So you did not go on to ask yourself the

14 ordinary question: how could a girl do this? This is

15 a fairly extraordinary mechanism for an injury, is it

16 not?

17 PC JONES: Well, I had never seen -- it is not as if I have

18 experience with that type of injury, whereas a doctor

19 would have experience with that type of injury.

20 MR GARNHAM: Yes, others with experience of it were prompted

21 to make comments like: "I do not see how once the first

22 drop of water had hit her face she could go on pouring".

23 PC JONES: Who are those others and why did they not tell

24 us?

25 MR GARNHAM: Nurses.

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1 PC JONES: Why did they not say?

2 MR GARNHAM: Another point, but I want to know your reaction

3 to that. Did it not occur to you it was a fairly odd

4 way for an injury to occur?

5 PC JONES: I would not say I thought it was a very odd way

6 for an injury to occur, especially as Victoria had had

7 scabies and maybe it had been itching her so badly she

8 did this. I just cannot tell you, I do not know.

9 MR GARNHAM: While you were on the ward did you speak to any

10 of the nurses?

11 PC JONES: Yes.

12 MR GARNHAM: Who did you speak to?

13 PC JONES: A nurse came into the room with us -- I know her

14 name has been mentioned, I think in your opening

15 statement, the nurse that came into the room with us, to

16 sit with Lisa, me and Victoria.

17 MR GARNHAM: Did you ask her about the facts of the burning?

18 PC JONES: I asked her I think -- I cannot remember what my

19 exact words were, but: was Victoria all right, or how

20 was Victoria, or something to that effect and she said

21 the scabies had cleared.

22 MR GARNHAM: And no mention of the marks?

23 PC JONES: No, or any concerns.

24 MR GARNHAM: Did you make notes during the course of this

25 conversation?

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1 PC JONES: No.

2 MR GARNHAM: Why not?

3 PC JONES: As I explained in my statement, in my experience,

4 sometimes it can put children off if you sit there

5 note-taking.

6 MR GARNHAM: So presumably you made your notes as soon as

7 you left the room, did you?

8 PC JONES: No I did not.

9 MR GARNHAM: Why not?

10 PC JONES: I remember Victoria's account, I remember

11 Mrs Kouao's account and at that stage I was not dealing

12 with a crime, so it was not necessary for me to go

13 immediately and make my notes. I made my notes on

14 a CRIS machine when I got to it next.

15 MR GARNHAM: Did you not consider it good practice to make

16 contemporaneous notes during the course of this sort of

17 interview?

18 PC JONES: No.

19 MR GARNHAM: You were asked that question during the course

20 of the criminal trial -- sir, for your note it is

21 48/293 -- and the question is:

22 "Is it not good police practice to write down, if it

23 is possible in the circumstances, what people are saying

24 at the time or immediately after they have said it?"

25 And you say, "Yes".

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1 PC JONES: If it is possible.

2 MR GARNHAM: Well, if not possible for the reasons you say

3 at the time, it was certainly possible the moment the

4 incident was finished, the conversation was finished,

5 was it not?

6 PC JONES: What I would say is I was not dealing with

7 a criminal investigation, and I made my note -- I did

8 not make notes when I left, I did make them on a CRIS

9 machine. I still had memory of what had been said.

10 MR GARNHAM: You tell us that the account Victoria gave was

11 very similar to the account that Kouao had given you the

12 previous day.

13 PC JONES: Yes.

14 MR GARNHAM: That might be the result of two different sets

15 of circumstances, might it not? Either it might be

16 because that is the truth, or it might be because

17 Victoria had been coached by Kouao into saying the same

18 thing?

19 PC JONES: Yes, I agree.

20 MR GARNHAM: How does your conversation with Victoria help

21 you resolve which of those two it is?

22 PC JONES: What helps me resolve which of those two is

23 falling back on the evidence that the doctors -- well,

24 falling back on what the doctors had told me.

25 MR GARNHAM: Again we come back to the same assertion:

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1 namely, that all your actions thereafter turn on your

2 interpretation of the facts from Quinn.

3 PC JONES: Yes, which contained the doctor's diagnosis.

4 MR GARNHAM: Yes. You tell us that you were assured by the

5 nurse that Victoria's skin infection had been cleared

6 up.

7 PC JONES: Yes.

8 MR GARNHAM: Was it then debated between you and

9 Lisa Arthurworrey whether there should then be a home

10 visit?

11 PC JONES: No.

12 MR GARNHAM: Why not?

13 PC JONES: Because once my investigation had led me to

14 believe that there was no non-accidental injury, then

15 there was no place for me to go round to Victoria's home

16 address. There was no need for me to go there. There

17 was no investigation to follow there.

18 MR GARNHAM: But you had said to us before that it was not

19 to pursue a criminal investigation that you were

20 planning to go to Victoria's house in the first place.

21 PC JONES: That is right.

22 MR GARNHAM: Why the difference?

23 PC JONES: I had already done my task in that respect. My

24 task was to speak to Mrs Kouao and explain to her my

25 role, that had been done.

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1 MR GARNHAM: Did you say a moment ago that after the

2 interview with Victoria, although you did not make any

3 notes, you made some notes on the CRIS report?

4 PC JONES: Yes, I did write on the CRIS reports.

5 MR GARNHAM: The reason I hesitated was to try and find the

6 passage in your statement where you deal with it.

7 Paragraph 46:

8 "I did not record Victoria's account on the CRIS

9 report."

10 PC JONES: I see what you are saying. Can I have a copy of

11 the CRIS report please? It might help me to explain.

12 MR GARNHAM: Volume 30, 131.507. I think the passage you

13 want to refer us to is at the foot of that page.

14 PC JONES: Thank you. Right. To answer your question,

15 I put in my statement I did not record Victoria's

16 account. By that I mean I did not record it

17 word-for-word. Some of it I put is similar to

18 Mrs Kouao's account. I put:

19 "Her account of how she began to itch and how she

20 got some of the scars on her body were the same as that

21 of her mother's."

22 That is what I meant by that.

23 MR GARNHAM: And that is normal practice, is it, where you

24 get a confirming account of that sort: that you just put

25 a note to that effect?

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1 PC JONES: Well, I would not say it is normal practice, it

2 is my practice. It is not something that was wrong,

3 or ...

4 MR GARNHAM: You and Lisa Arthurworrey then drove back to

5 North Tottenham District Office.

6 PC JONES: Yes.

7 MR GARNHAM: You say in your statement that you were clear

8 that there was no evidence that amounted to an

9 allegation of crime.

10 PC JONES: Yes.

11 MR GARNHAM: I am interested in your use of the word

12 "allegation". Allegation by whom? Who were you

13 expecting might make an allegation? Victoria?

14 PC JONES: Victoria may have made an allegation, Mrs Kouao

15 may have made an allegation, the hospital may have made

16 an allegation in the form of a doctor saying that this

17 is a non-accidental injury.

18 MR GARNHAM: But the only one of those three possibilities

19 that could have arisen out of the work that day was

20 Victoria.

21 PC JONES: Right. Okay. Well I would be referring back to

22 all the information that I had had.

23 MR GARNHAM: I see. I have to suggest to you that the

24 decision you reached that day was extraordinary, because

25 you still had not dealt with the belt buckle allegation.

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1 PC JONES: It had been dealt with. A nurse had seen what

2 she thought looked like a belt buckle. But the doctors

3 had examined Victoria, she had been in hospital for a

4 number of days and they had not come up with any

5 concerns, they had not come up with any evidence of

6 non-accidental injury.

7 MR GARNHAM: You had not dealt with the delay in getting

8 Victoria to hospital on the 24th.

9 PC JONES: The delay in getting Victoria to hospital on the

10 24th?

11 MR GARNHAM: And whether that was indicative --

12 PC JONES: I do not understand the question, I am sorry.

13 MR GARNHAM: When you left and made your decision there was

14 nothing else to investigate, you had not dealt with the

15 fact that there was a a delay in getting Victoria to the

16 hospital.

17 PC JONES: No.

18 MR GARNHAM: An omission by you.

19 PC JONES: I did -- I totally overlooked the whole delay

20 thing.

21 MR GARNHAM: You had not investigated the possibility that

22 the scalding was deliberate.

23 PC JONES: I had investigated that and I was satisfied that

24 the hospital had looked into it and had deemed that it

25 could be -- it was accidental.

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1 MR GARNHAM: Based on what you had learned, you say, in

2 the --

3 PC JONES: Strategy meeting and also what

4 Sergeant Cooper-Bland had learned.

5 MR GARNHAM: You had not investigated why there was a poor

6 relationship between mother and child.

7 PC JONES: That was not for me to investigate.

8 MR GARNHAM: But it might have been important in deciding

9 the other questions I put to you, might it not?

10 PC JONES: No, my -- what I would have been looking for was

11 evidence, and in this case there was no evidence, and so

12 the mother and child thing was for social services to

13 explore.

14 MR GARNHAM: Did you have any remaining concerns when you

15 finished with this matter in August?

16 PC JONES: No I did not -- well, if I can just clarify that,

17 I knew that Lisa would remain as a single agency and she

18 would remain because of housing, so to say there were

19 totally no concerns --

20 MR GARNHAM: But there were no concerns which concerned the

21 police.

22 PC JONES: That is right.

23 MR GARNHAM: I need to suggest to you, Ms Jones, that you

24 were guilty of a clear breach of your duty as a police

25 officer in failing to speak to Victoria before

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1 6th August.

2 PC JONES: No, I would disagree with you.

3 MR GARNHAM: That you ought to have conducted a memorandum

4 interview with Victoria promptly after you heard of the

5 original allegation.

6 PC JONES: No, because a Memorandum of Good Practice says

7 you should have clear indication that a crime may have

8 taken place, and we never had a clear indication.

9 MR GARNHAM: And that you had such an indication in the

10 facts of the scalding, the allegations of marks to her

11 body, and in particular the allegation of belt buckle

12 shaped marks.

13 PC JONES: I would disagree with you, because the hospital

14 had accepted the scalding and they had examined Victoria

15 and said that her marks were not as a result of

16 a non-accidental injury in nature.

17 MR GARNHAM: And that you failed in your duty in failing to

18 record what Victoria told you, except by that small

19 reference.

20 PC JONES: I did not fail in my duty there.

21 MR GARNHAM: I suggest to you that the whole of your

22 investigation into this alleged crime was inadequate.

23 PC JONES: No, I would not agree.

24 MR GARNHAM: That you should have seen the victim.

25 PC JONES: I did see Victoria.

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1 MR GARNHAM: And a taken a proper interview from her.

2 PC JONES: That was a proper interview, a memorandum --

3 there was no clear indication of a crime, so no

4 memorandum of interview took place.

5 MR GARNHAM: That you should have seen the witnesses,

6 including the doctors.

7 PC JONES: Karen Johns was -- her task was to go to the

8 hospital, liaise with them and get a medical report. If

9 that medical report had said: "This is as a result of

10 a non-accidental injury", then I would have taken

11 statements from all the people concerned or involved who

12 had information to give, including the nurses.

13 MR GARNHAM: That you misinterpreted a memo from a nurse

14 dealing with emotional abuse as if it was a medical

15 report dealing with all of Victoria's complaints?

16 PC JONES: No, that memo, it included Dr Rossiter's

17 observations and she would have known if there was

18 a non-accidental injury and she would have written it

19 down.

20 MR GARNHAM: That you proceeded on an assumption about what

21 that memo meant which coloured the whole way you managed

22 the case thereafter.

23 PC JONES: Well, what I say to that is I read the memo and

24 it did not indicate that any of the marks were from a --

25 of a non-accidental nature, it only dealt with the

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1 emotional concerns which were the concerns -- the only

2 concerns that the hospital had.

3 MR GARNHAM: That you failed to test out the assumptions you

4 were making about the information you received.

5 PC JONES: I disagree.

6 MR GARNHAM: That you failed in particular to visit what

7 might have been an obvious candidate for the scene of

8 the crime to see whether there was evidence to support

9 that possibility.

10 PC JONES: You had to identify the crime first before there

11 could be a scene.

12 MR GARNHAM: That the only reason you failed to identify the

13 crime was because of your misreading of the memo from

14 Quinn.

15 PC JONES: No, I disagree.

16 MR GARNHAM: Thank you. Can I turn then to the incident

17 of November 1999. It is right, is it not, that you had

18 no contact with Victoria from the 6th August until

19 2nd November?

20 PC JONES: That is right.

21 MR GARNHAM: Did you hear anything from Lisa Arthurworrey in

22 that intervening period?

23 PC JONES: No, because it was single agency investigation.

24 MR GARNHAM: Did you have occasion to meet Lisa Arthurworrey

25 on any other case?

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1 PC JONES: Not that I can remember, no.

2 MR GARNHAM: The relevant CRIS entries for the November

3 incident are volume 30, page 88. Could you have that

4 open, please? Do you have that?

5 PC JONES: Yes.

6 MR GARNHAM: The first entry -- can you tell us who made

7 that?

8 PC JONES: I think it was made by the administration clerk.

9 MR GARNHAM: Name?

10 PC JONES: Paula Waldron.

11 MR GARNHAM: There is a a reference to "Civ P Waldron" at

12 the top. Does that mean "civilian"?

13 PC JONES: Yes -- well, yes, but that is because -- yes,

14 sorry, yes.

15 MR GARNHAM: The offence is said to run from 1st June

16 through to 1st November.

17 PC JONES: Yes.

18 MR GARNHAM: A period of five months. What does that mean?

19 PC JONES: When Paula was giving the details, which appear

20 in the back of the crime (sic) she would have put an

21 estimated date, if we did not know exact dates.

22 MR GARNHAM: The crime type is said to be C, which is

23 defined as a conspiracy.

24 PC JONES: Yes.

25 MR GARNHAM: What did you understand that to mean in the

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1 context of this case?

2 PC JONES: It is not a conspiracy --

3 MR GARNHAM: What does type C mean?

4 PC JONES: It is a major crime. C for major. A B might be

5 a beat crime.

6 MR GARNHAM: Help me then with the words that follow that:

7 "Enter A for attempt or C for conspiracy."

8 PC JONES: I am not sure why they call it that, but that is

9 my understanding of the C.

10 MR GARNHAM: So your understanding is that C is the gravity

11 of the offence, is it?

12 PC JONES: Yes.

13 MR GARNHAM: The substantive entries about this are found at

14 page 92. Miss Waldron has recorded that that morning,

15 1st November, Kouao telephoned Lisa Arthurworrey to make

16 allegations to the effect that Manning had sexually

17 assaulted Victoria.

18 PC JONES: Yes.

19 MR GARNHAM: We see -- page 88 if you want to look at it --

20 that Miss Waldron allocated the case to you at 3 minutes

21 past 4 on 1st November.

22 PC JONES: Yes.

23 MR GARNHAM: But you tell us by then you had already left

24 the office.

25 PC JONES: Yes.

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1 MR GARNHAM: Was that common practice, that a case would be

2 allocated by the civilian administrative worker to

3 somebody who was not in the office?

4 PC JONES: Well, the reason why she would have given it to

5 me is because she would have probably have realised

6 I had dealt with the case with the same family from

7 before.

8 MR GARNHAM: But if there was anything urgent, you were not

9 going to be able to look at it before the following

10 morning.

11 PC JONES: She would not allocate it to me then.

12 MR GARNHAM: If it was urgent it would not have gone to you?

13 PC JONES: No.

14 MR GARNHAM: But the view was taken that it was not urgent?

15 PC JONES: Yes.

16 MR GARNHAM: If something came up urgently on a case that

17 had been allocated in that way to someone who had gone

18 off duty, what would happen?

19 PC JONES: We have an on-call officer. The office is

20 covered 24 hours and the on-call officer might be

21 bleeped or there are always police officers in uniform

22 that can help.

23 MR GARNHAM: What is the process by which the case then gets

24 to your attention?

25 PC JONES: How do you mean?

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1 MR GARNHAM: Well, she has entered this in the computer.

2 How do you then get to be aware you are the officer in

3 the case?

4 PC JONES: When -- the usual practice, when I come on in the

5 morning I would go to the CRIS machine and check for any

6 crimes allocated to me.

7 MR GARNHAM: You did that in this case the following

8 morning?

9 PC JONES: I think -- well I did do that but it may have

10 been that Paula left me a copy of the CRIS report on my

11 desk.

12 MR GARNHAM: You say you went back to the machine and made

13 an entry to the effect that you had noted it at 7.47

14 that morning.

15 PC JONES: Yes.

16 MR GARNHAM: Can you give us the page reference for where

17 that is?

18 PC JONES: 30.88.

19 MR GARNHAM: Help me with whereabouts that is.

20 PC JONES: Right, this was printed out on 1st November 1999,

21 this report that you have.

22 MR GARNHAM: Yes.

23 PC JONES: So there would be another report -- I could help

24 you with one, it is in my bag. It would be printed out

25 afterwards.

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1 MR GARNHAM: There is another report, is there, that shows

2 you the time you took that --

3 PC JONES: What I am saying is when Paula printed this --

4 this might be the copy she left on my desk -- she

5 printed it on 1st November 1999 at 5 o'clock. I had not

6 noted the crime by then but later on I did note the

7 crime, so if you get another print-out on a different

8 date ...

9 MR GARNHAM: So it is not on this page, but it would be

10 possible to find one, would it?

11 PC JONES: Yes.

12 MR GARNHAM: And you have one with you. At the end of your

13 evidence we might ask you if you would let us have that.

14 PC JONES: Okay.

15 MR GARNHAM: Had you done anything on this case before you

16 learned that Kouao and Victoria had withdrawn the

17 allegation of sexual assault?

18 PC JONES: No.

19 MR GARNHAM: You were told, were you, that Kouao had come

20 into North Tottenham District Office with the intention

21 of withdrawing it?

22 PC JONES: She had come in and had withdrawn it.

23 MR GARNHAM: As soon as you heard that, you must have been

24 concerned?

25 PC JONES: I was concerned -- there were concerns about the

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1 case from the beginning.

2 MR GARNHAM: And you tell us in paragraph 52 of your

3 statement that there were three real reasons that made

4 you concerned about that chain of events: firstly, her

5 first visit, her previous visits to North Tottenham

6 District Office in Manning's company.

7 PC JONES: Yes.

8 MR GARNHAM: Secondly the fact that the incidents occurred

9 whilst Kouao was in contact with social services and had

10 never been mentioned.

11 PC JONES: Yes.

12 MR GARNHAM: Thirdly it was not clear what had made Victoria

13 change her mind.

14 PC JONES: Yes.

15 MR GARNHAM: All of that must be apparent to you as soon as

16 you heard that the story had been withdrawn.

17 PC JONES: Yes.

18 MR GARNHAM: Why then did you do nothing for three days?

19 PC JONES: Well, at the time the reason was that there were

20 concerns about the way in which the allegation had been

21 made. If I can go back even to before then, Lisa had

22 been involved with the family since July, and she had

23 never ever reported any concerns, although she had seen

24 an interaction between Victoria and Mrs Kouao. She had

25 been in the home address; she had time to assess the

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1 family and she had never had any concerns in that

2 regard.

3 Then there was the way in which the allegation had

4 been made. Lisa had visited the home address on the --

5 on the day before, the Thursday, and spoke to Mrs Kouao

6 about how she had made herself intentionally homeless,

7 and that Housing were not going to -- she was not going

8 to receive any housing or benefit, and that the only way

9 she could possibly receive housing or benefit was if her

10 child -- Victoria was at risk. Then the next thing, the

11 next day the allegation came in and the way the

12 allegation had come in as well, in that Mrs Kouao had

13 attended North Tottenham District with the suspect,

14 Carl Manning, and -- with Victoria, and had made this

15 allegation. It seemed quite -- an odd way to do it,

16 with the suspect. Then there was a belief -- what

17 social services were saying that they felt that it

18 was -- the allegation had been made because Mrs Kouao

19 wanted to have housing.

20 MR GARNHAM: Yes, I understand all that from your statement.

21 Those are the reasons why this all sounded a bit odd.

22 PC JONES: Yes, then there was a retraction the very next

23 day.

24 MR GARNHAM: But you were not content, you tell us in

25 paragraph 52, just to assume that?

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1 PC JONES: No, I was not content just to assume that.

2 MR GARNHAM: That being so, because you were not content

3 just to assume it is right, why did you do nothing for

4 three days? If there was a real concern there, for

5 those reasons, why sit on it for three days?

6 PC JONES: Okay. Well, there was a concern there, my --

7 I think -- I would have to say I did tend to side with

8 social services in that I believe that Mrs Kouao was

9 making the allegation up in order to get housing for

10 herself and Victoria --

11 MR GARNHAM: I can understand why you might think this is

12 a distinct possibility --

13 PC JONES: And it was the inappropriate way she had come

14 about making the allegation.

15 MR GARNHAM: But there was also a possibility, was there

16 not, that the sexual abuse had happened and that

17 Victoria was being pressurised for some other reason to

18 withdraw it?

19 PC JONES: Yes.

20 MR GARNHAM: So why did you wait three days before you acted

21 on those concerns?

22 PC JONES: What I am trying to say is I sided with or

23 believed more of what social services were saying, and

24 also Victoria (sic) had come into North -- North

25 Tottenham District Office with Victoria and she had been

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1 seen, they had both been seen and they had been sent

2 away. It was deemed that Mrs Kouao could protect

3 Victoria at that time and they were sent away from

4 Carl Manning.

5 MR GARNHAM: Yet again is this not an example of you

6 delegating the job you should be doing, of investigating

7 this allegation, to other people?

8 PC JONES: No. Well, at the time no, I did not feel so.

9 MR GARNHAM: Now?

10 PC JONES: I would do it quite differently.

11 MR GARNHAM: You would have investigated straightaway, not

12 waited for three days?

13 PC JONES: Yes, but I am trying to explain to you why

14 I waited, because that was your question. As I said,

15 I tended to side with the social services and I felt

16 that Victoria -- I did not feel Victoria would come to

17 significant harm and I decided to wait for the strategy

18 meeting, wait the three days.

19 MR GARNHAM: That would be a a fair assumption provided

20 social services were right. If it turned out they were

21 wrong, and Victoria had withdrawn the allegation because

22 of pressure from Kouao, you were leaving her

23 potentially, were you not, in a situation that was

24 dangerous?

25 PC JONES: No, because she had been sent away to another

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1 place, and it was -- I still believe that Mrs Kouao

2 could protect Victoria.

3 MR GARNHAM: I see. You tell us you attended the strategy

4 meeting on 5th November, again at North Tottenham.

5 PC JONES: Yes.

6 MR GARNHAM: We have the minutes that were produced by

7 Rose Kozinos at page 25, in volume 30. When did you

8 first see those minutes?

9 PC JONES: I think I saw these after Victoria had died.

10 MR GARNHAM: Again an instance of them being distributed

11 rather slowly, to put it mildly.

12 PC JONES: Yes.

13 MR GARNHAM: You had attended this meeting with

14 Pauline Ricketts on behalf of the police?

15 PC JONES: Yes.

16 MR GARNHAM: And social services were represented by

17 Lisa Arthurworrey and Rose Kozinos?

18 PC JONES: Yes.

19 MR GARNHAM: So four of you?

20 PC JONES: Yes, it was not -- I was the only officer invited

21 to the meeting. The reason why Pauline Ricketts was

22 there was because we were trying to save money, using

23 one car, basically.

24 MR GARNHAM: During the course of that meeting, did you have

25 available to you the minutes of the previous strategy

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1 meeting?

2 PC JONES: No.

3 MR GARNHAM: Was any reference made to the previous strategy

4 meeting during the course of this one?

5 PC JONES: I think that there was some reference made to the

6 previous strategy meeting, or to the previous concerns.

7 MR GARNHAM: Did all four of you there realise that this was

8 the same child who had been the subject of that previous

9 incident?

10 PC JONES: The three of us would have. Pauline Ricketts

11 would not have known anything of it.

12 MR GARNHAM: No, but would she know there had been

13 a previous incident because of what she heard during the

14 course of this strategy meeting.

15 PC JONES: Yes.

16 MR GARNHAM: Page 27, details about Anna, as she is called.

17 "Ethnicity and religion: Zairean - Catholic".

18 PC JONES: Yes.

19 MR GARNHAM: Was that an error that was noted at the time?

20 That she was not Zairean.

21 PC JONES: I do not remember anybody saying that at the

22 strategy meeting.

23 MR GARNHAM: "First language: French. School: Bruce Grove

24 Primary School."

25 Where did that come from?

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1 PC JONES: I cannot remember -- I am sorry, I cannot

2 remember about the school at the strategy meeting.

3 MR GARNHAM: Do you know whether any checks were made to

4 confirm her attendance at that school?

5 PC JONES: I cannot say for sure. That would have been the

6 job of the social services but I cannot remember it

7 being mentioned.

8 MR GARNHAM: Over the page, the three allegations of sexual

9 abuse are recorded and the next paragraph deals with

10 relevant previous incidents or concerns and notes:

11 "Child Protection concerns - investigated, injuries

12 deemed as accidental, child had scabies, scratching

13 them, marked skin."

14 Is that right?

15 PC JONES: Yes.

16 MR GARNHAM: So are we to take it from that that no one at

17 that meeting gave any thought to the possible

18 alternative causes for the marks on Victoria's body?

19 PC JONES: No, not at that meeting, no.

20 MR GARNHAM: It was regarded as having been decided they

21 were all accidental.

22 PC JONES: Yes.

23 MR GARNHAM: Who was it who informed the strategy meeting of

24 that? Did that come from you?

25 PC JONES: No.

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1 MR GARNHAM: Who did then?

2 PC JONES: Well it would have been either Rose Kozinos or

3 Lisa Arthurworrey.

4 MR GARNHAM: Over the page the plan is set out and there are

5 15 steps to be undertaken. You were to check with

6 immigration, what was the point with that, since you had

7 already done it?

8 PC JONES: It had been already done and I -- I do not know

9 why that was put down again.

10 MR GARNHAM: You were to carry out a check on Carl Manning.

11 You had done that before but I suppose it might be

12 worthwhile doing it again.

13 PC JONES: Yes.

14 MR GARNHAM: The client was to give a police statement. Is

15 the client Victoria?

16 PC JONES: What we were told at the strategy meeting was

17 that Mrs Kouao was to give a statement.

18 MR GARNHAM: I see. So Mrs Kouao was regarded as the

19 client --

20 PC JONES: Yes.

21 MR GARNHAM: -- for these purposes?

22 PC JONES: Yes.

23 MR GARNHAM: In that case, was there anything here --

24 I probably missed it -- about taking a a statement from

25 Victoria? We see at 8 there is a a reference to

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1 "talking to child on her own with mother's permission";

2 was that as far as it was going to go?

3 PC JONES: Well it would all -- how you spoke to Victoria

4 might depend on what unfolded. If that makes sense.

5 MR GARNHAM: It does not entirely. I had understood you to

6 be of the view that it is important that, if you are

7 going to take evidence from a child in a case of

8 a serious offence, that it ought to be done via

9 memorandum interview.

10 PC JONES: Well, as I say, how you talk to the child,

11 whether it is going to be verbally or memorandum, but

12 what the process was to be was that -- the allegation

13 had already been withdrawn, so according to the

14 Memorandum of Good Practice it is not a clear indication

15 that a crime may have occurred, so the process would

16 have been to speak to Mrs Kouao and take a statement

17 from her and find out what had happened, and then take

18 it from there. You might have a memorandum or you might

19 not. You might speak to Victoria verbally.

20 MR GARNHAM: There was to be a possible joint home visit,

21 with you, with PCPT how was that to be taken forward?

22 What was to happen next to ensure that happened?

23 PC JONES: It was possible home visit, so that would have

24 been --

25 MR GARNHAM: Dependent upon what?

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1 PC JONES: Dependent upon probably -- it did not say at the

2 strategy, it did not clarify, but I assumed dependent

3 upon what Mrs Kouao had said when she made her

4 statement.

5 MR GARNHAM: I do not think any of the other items are

6 expressly allocated to you. Was there anything that you

7 took away from that meeting as being a job for you?

8 PC JONES: No.

9 MR GARNHAM: Did you have any information at the time of

10 that strategy meeting which had not come from social

11 services in relation to this incident?

12 PC JONES: No.

13 MR GARNHAM: Did you make any independent enquiries yourself

14 before you came to this meeting?

15 PC JONES: No, I would have done -- probably would have done

16 a check on the family, on Carl Manning.

17 MR GARNHAM: So your investigation of the possible crime --

18 PC JONES: Yes.

19 MR GARNHAM: -- thus far consisted of turning up at this

20 meeting?

21 PC JONES: Yes.

22 MR GARNHAM: You say in paragraph 53 that you agreed that

23 there were childcare concerns and you should try to get

24 the matter to case conference.

25 PC JONES: Yes.

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1 MR GARNHAM: We see from page 31 in these minutes that

2 a case conference was required. Paragraph 15:

3 "Is a child protection conference required? Yes."

4 PC JONES: Yes.

5 MR GARNHAM: Does that tally with your recollection?

6 PC JONES: Yes.

7 MR GARNHAM: So there was no doubt then that a case

8 conference was going to be needed?

9 PC JONES: One was requested.

10 MR GARNHAM: By whom?

11 PC JONES: Well, we had requested it at the strategy

12 meeting.

13 MR GARNHAM: We are look at the strategy meeting here. So

14 in the strategy meeting you four decide there should be

15 a case conference, do you?

16 PC JONES: Yes, three of us.

17 MR GARNHAM: Ricketts was just an observer?

18 PC JONES: Yes.

19 MR GARNHAM: What was involved in getting the matter to

20 a case conference?

21 PC JONES: It was something -- first of all, assessments

22 would have to be done on the family, then it would be

23 put -- well, social services would decide whether it did

24 go to conference or not.

25 MR GARNHAM: Can go back one page, please, to page 30:

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1 "Investigative interview/medical."

2 Under that heading the words "not at this stage"

3 have been written in. What are we to take that to mean?

4 PC JONES: That -- well, I do not know why they write

5 "investigative" but I would say that is a memorandum.

6 "Not at this stage".

7 MR GARNHAM: It read to me as if it was an indication that

8 no further investigation was going to be taken out after

9 that occasion, is that right?

10 PC JONES: Well, no --

11 MR GARNHAM: Nothing further beyond the listed items was to

12 be done.

13 PC JONES: I see what you mean. Well, yes, "not at this

14 stage", not at that stage.

15 MR GARNHAM: At page 31, paragraph 10.1:

16 "What is the plan for protecting the child? Full

17 investigation."

18 What is that to be?

19 PC JONES: That would be a full investigation by social

20 services and police, joint.

21 MR GARNHAM: And what would that involve?

22 PC JONES: It would involve me investigating the crime,

23 taking a statement from Mrs Kouao about the allegation,

24 and the withdrawal, and getting the permission to speak

25 to Victoria, probably speak to Victoria and whatever

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1 else might lead.

2 MR GARNHAM: You tell us at the meeting it was discussed

3 whether or not a home visit should be made.

4 PC JONES: Yes.

5 MR GARNHAM: What was the concern?

6 PC JONES: Well, the concern was that, if we did do home

7 visit, we would visiting in Carl Manning's house, rather

8 than Mrs Kouao's own house. It was not her house.

9 MR GARNHAM: Could you not have invited Mr Manning to absent

10 himself for the purpose of that meeting?

11 PC JONES: Yes, it is possible we could, but --

12 MR GARNHAM: Why was that not done?

13 PC JONES: That was not discussed and it was just that that

14 is Carl Manning's house, we could ask him to leave but

15 it just did not seem appropriate.

16 MR GARNHAM: Instead of which you decide it would be proper

17 to see Kouao at a police station?

18 PC JONES: Yes.

19 MR GARNHAM: Why not just ring her up and invite her?

20 PC JONES: At the time I felt that -- well, it was decided

21 at the strategy it would be more official to write.

22 MR GARNHAM: You then embark on what I think you would

23 probably agree was fairly extraordinary course of trying

24 to get a letter translated.

25 PC JONES: Yes.

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1 MR GARNHAM: You set that out in some detail in your

2 statement.

3 PC JONES: Yes.

4 MR GARNHAM: It meant that week after week after week went

5 by with no letter going out.

6 PC JONES: Yes.

7 MR GARNHAM: When you eventually got one translated back

8 ready to go out, the date for the appointment had

9 already passed.

10 PC JONES: Yes.

11 MR GARNHAM: That continued over Christmas, when I think you

12 went away.

13 PC JONES: Yes.

14 MR GARNHAM: Or you took leave. And it was not until the

15 end of January that Kouao was invited back for an

16 interview.

17 PC JONES: Yes.

18 MR GARNHAM: How do you regard that sequence of events now?

19 PC JONES: It is obviously too long, too late.

20 MR GARNHAM: It was unnecessary; it could have been

21 foreshortened, could it not?

22 PC JONES: Yes.

23 MR GARNHAM: Either by a phone call to Kouao or by

24 a personal visit?

25 PC JONES: Yes.

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1 MR GARNHAM: One or other of those two things should have

2 happened?

3 PC JONES: Yes.

4 MR GARNHAM: How did it come about that you were so

5 distracted by trying to get this letter translated?

6 PC JONES: Well -- how did it come about?

7 MR GARNHAM: What was going through your mind which made you

8 think: "I must get this letter translated"?

9 PC JONES: What was going through my mind, to make the

10 letter get so delayed, was all the history behind the

11 case. How, I explained to you before, how social

12 services had been involved with the family, had reported

13 no concerns, the ways in which the allegation had been

14 made, the reasons why social services thought it had

15 been made, the withdrawal, the fact that I thought that

16 Mrs Kouao was using Victoria to get housing for herself

17 and Victoria, albeit -- it was an inappropriate way and

18 really I did not -- I think my judgment was clouded by

19 all of those things.

20 MR GARNHAM: It was made worse, was it not, by the fact that

21 you took two periods of absence during that time: you

22 took nearly three weeks at the end of November

23 into December and you then took from about 23rd December

24 to 9th January leave?

25 PC JONES: Yes.

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1 MR GARNHAM: All of which meant nothing was happening on

2 this case?

3 PC JONES: That is right.

4 MR GARNHAM: Did you consider where you might have seen

5 Kouao and Victoria, because was it not right that she at

6 least immediately after the strategy meeting was at

7 a different address from Manning's?

8 PC JONES: I did consider that, but the information I got --

9 and this was not changed at the strategy meeting -- was

10 that they had returned to Carl Manning's house.

11 MR GARNHAM: That they had returned?

12 PC JONES: Yes.

13 MR GARNHAM: I had better make sure I am certain about this.

14 You tell us that at this strategy meeting you were told

15 Victoria and Kouao had moved away but had come back?

16 PC JONES: When I had received notification about the

17 allegation being withdrawn, I was told then that -- I am

18 pretty certain I was told then that they were returning

19 to the home address.

20 MR GARNHAM: By whom were you told that?

21 PC JONES: Well, I think it was by Paula Waldron, but it may

22 not have been. I cannot remember.

23 MR GARNHAM: She would have been just the conduit, would she

24 not?

25 PC JONES: Yes, oh, I see what you mean, from social

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1 services?

2 MR GARNHAM: Yes.

3 PC JONES: I cannot remember who, I thought it was Lisa, but

4 from reading this I do not think it was. Then when

5 I went to the strategy meeting, I cannot remember

6 exactly what we discussed about address, but it was

7 never -- they knew I had to write the letter. It was

8 never said: write it to Cedar Avenue or Cedar Road.

9 Even on the strategy meeting minutes it says -- if

10 I could just have a look ... on the strategy meeting, if

11 you look on page 27, it says their address is Somerset

12 Gardens, and if you look on the previous page it says:

13 "Were residing".

14 MR GARNHAM: Yes, that passage has been redacted on our

15 copy:

16 "Family were residing with friends."

17 But the missing address I think is the address in

18 Wood Green, is it not?

19 PC JONES: Yes.

20 MR GARNHAM: Of people who we know now are called Kimbidima?

21 PC JONES: Yes.

22 MR GARNHAM: So you understood by that time she was back

23 with Manning, did you?

24 PC JONES: Yes.

25 MR GARNHAM: Would it not have been appropriate at that very

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1 early stage, immediately after the strategy meeting, to

2 have a memorandum interview with Victoria?

3 PC JONES: No, because the memorandum does say you need to

4 have a clear indication that a crime may have taken

5 place and this crime had been withdrawn. Also the

6 circumstances in which it had been made and withdrawn,

7 it was -- I felt it was important to find out the issues

8 behind that.

9 MR GARNHAM: What was it that Kouao could have told you that

10 would have persuaded you it was not necessary to have

11 a memorandum interview?

12 PC JONES: Well, once speaking to Mrs Kouao, I would have

13 asked her for permission to speak to Victoria. I do not

14 know what she would have said about --

15 MR GARNHAM: And that meeting would then have not been

16 memorandum?

17 PC JONES: That would have been something that we would have

18 to think about carefully. It might be that it was not.

19 It might be that we just spoke to Victoria first.

20 MR GARNHAM: In what circumstances could you be persuaded by

21 what Kouao said not to memorandum interview Victoria?

22 PC JONES: Well, you are asking me to comment on something

23 that -- I do not know what she would have said.

24 MR GARNHAM: No, but you have suggested there were two

25 possibilities: one is having a word with Victoria, the

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1 other have a memorandum interview.

2 PC JONES: Yes.

3 MR GARNHAM: What could conceivably lead you to think you

4 did not need a memorandum interview?

5 PC JONES: Well, that is a difficult question for me.

6 MR GARNHAM: You see I want to put it to you that you

7 should, without any doubt, have arranged a memorandum

8 interview of Victoria immediately upon hearing of this

9 serious allegation of sexual assault.

10 PC JONES: The thing about it was that it had been

11 withdrawn, and the circumstances in which it had been

12 withdrawn as well.

13 MR GARNHAM: Yes, but there was always a possibility it had

14 been withdrawn because pressure had been placed on

15 Victoria to do so.

16 PC JONES: That could have been a possibility.

17 MR GARNHAM: And that needed investigating.

18 PC JONES: Yes.

19 MR GARNHAM: If you were going to investigate it, the only

20 way you could do so properly would be to memorandum

21 interview Victoria.

22 PC JONES: No, it would be to speak to Mrs Kouao.

23 MR GARNHAM: What could she conceivably say to you that

24 would lead you to say, "That is fine then. I do not

25 need to see Victoria"?

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1 PC JONES: We do not know, she may have changed her mind

2 again.

3 MR GARNHAM: Even more reason for memorandum interviewing of

4 Victoria.

5 PC JONES: Then I would have.

6 MR GARNHAM: If she had not changed her mind, but had kept

7 to the story, you would still need to give Victoria --

8 PC JONES: Is might be we spoke to Victoria first, to find

9 out what she had to say.

10 MR GARNHAM: If she said, "Oh no, my mother is absolutely

11 right", you would have left it there?

12 PC JONES: I would not say we would have just left it there.

13 I think that -- we wanted the case to go to conference

14 and that is what we would have pursued.

15 MR GARNHAM: I suggest to you, Ms Jones, that you should,

16 immediately you learned of the details of this

17 incidence, have visited Manning at his address.

18 PC JONES: Manning?

19 MR GARNHAM: Yes.

20 PC JONES: Well, no, because -- as soon as I learned of

21 this, what I feel I should have done is to immediately

22 visit Mrs Kouao.

23 MR GARNHAM: Yes, I have suggested that to you already.

24 PC JONES: Manning would have to come after and the

25 allegation against him had been withdrawn.

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