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Archived Transcript for 29 November 2001:
Pages 201 to 239
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1 because the offices were split and Ann was the advisor
2 for North Tottenham and I was the advisor for South
3 Tottenham and then the offices joined together to become
4 one.
5 MR GARNHAM: So Ann Graham may have had her own experiences
6 of Carole Baptiste from that?
7 MS GREEN: She may have done.
8 MR GARNHAM: Did you regard Carole Baptiste's work when you
9 last saw it as safe?
10 MS GREEN: It is very difficult to say. There were a number
11 of cases in her team that I brought to her attention
12 that worried me, and sometimes that went further up the
13 ladder in terms of concerns. I would not like to commit
14 myself either way on that.
15 MR GARNHAM: It may be that you are not able to answer this
16 question because of your lack of familiarity with the
17 office, so I will ask you a first question and if you
18 tell me you cannot I will not go on. Lisa Arthurworrey
19 described the atmosphere in her office as being like
20 a school.
21 MS GREEN: (Witness nods).
22 MR GARNHAM: She described the various functionaries in the
23 school, ascribing those roles of different managers.
24 Were you aware of that? Are you able to comment on
25 that?

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1 MS GREEN: I am not, no.
2 MR GARNHAM: You must in the course of your quality control
3 work have come across Carole Baptiste's work when she
4 was supervising. Seen her files on which she was
5 a supervisor.
6 MS GREEN: Possibly.
7 MR GARNHAM: Did you ever come across, either in the files
8 or in your conversations with social workers she was
9 supervising, accounts of her diverting attention away
10 from the case file towards other extrinsic matters?
11 MS GREEN: No.
12 MR GARNHAM: Her talking about religion or her experiences
13 as a black woman?
14 MS GREEN: No.
15 MR GARNHAM: Did her approach and your approach to social
16 work tally? Was she more interventionist or less
17 interventionist than you tended to be, or are you not
18 able to say?
19 MS GREEN: I am not really able to say.
20 MR GARNHAM: From what you were able to see, and again it
21 may not be much, did that team appear to act as a single
22 unit or were they divided into camps?
23 MS GREEN: I&A?
24 MR GARNHAM: Yes.
25 MS GREEN: I saw them as one team because I serviced them as

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1 one team, but I would not know.
2 MR GARNHAM: Thank you. Can I move to the next of my
3 topics: your involvement with the Moira Close Family
4 Centre.
5 MS GREEN: Okay.
6 MR GARNHAM: Could you have volume 26A, please? I think we
7 will have finished with those that are in front of you.
8 26A/141, please. That is the partnership agreement
9 between the NSPCC, the London Borough of Haringey and
10 Haringey Health Care NHS Trust.
11 MS GREEN: Yes.
12 MR GARNHAM: Signed a variety of dates in April and
13 May 1997, if you look to the end, and said to come into
14 effect on 1st April 1997 and to run for an initial
15 period of three years. All of that sound right?
16 MS GREEN: Yes.
17 MR GARNHAM: In the "Background" section there is reference
18 to the 1994 audit commission "seen but not heard" and
19 messages from research.
20 MS GREEN: Yes.
21 MR GARNHAM: I want to make sure that I have understood from
22 this document what the subject matter is, what is to be
23 the service to be provided. Is it what we find at
24 paragraph 2.3:
25 "Service development will specifically address the

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1 following issues..."
2 It does not win any prizes for clarity of
3 expression, but is that meant to be what the thing is
4 supposed to do?
5 MS GREEN: Say it again. Sorry, I was reading.
6 MR GARNHAM: What is the purpose of this agreement?
7 MS GREEN: This agreement?
8 MR GARNHAM: Yes. Where do we find what the service that is
9 going to be provided is?
10 MS GREEN: I do not know. I did not draw this up.
11 MR GARNHAM: No, but it is right to say that you became the
12 link worker --
13 MS GREEN: No, not for this. This is the --
14 MR GARNHAM: I have probably misunderstood so please tell
15 me.
16 MS GREEN: I was the link for the NSPCC Maya Angelou Centre.
17 This was a tri-part organisation which was Health and
18 NSPCC and Social Services led. So this was
19 a different -- I was not the link for this organisation.
20 MR GARNHAM: I see. Well that may help with one of the
21 questions Mr Sheldon put to an earlier witness and that
22 I was going to put to you. You will need another
23 volume, 26B, please. 26B/018.509. Those are the
24 meetings of --
25 MS GREEN: That is the NSPCC. That is the Maya Angelou

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1 Centre that I am linked to.
2 MR GARNHAM: And we find a reference to the fact that you
3 are to be the link on page 511, at the top of the page.
4 MS GREEN: Yes, but this is the Maya Angelou, are we clear?
5 MR GARNHAM: I am now clear. I was not, and I will explore
6 the extent of my ignorance in a moment.
7 MS GREEN: Okay.
8 MR GARNHAM: Sorry, what were you asking me to look at?
9 MS GREEN: 511, top line.
10 MR GARNHAM: "Historically Dawn [makes you sound about 97]
11 has been the link person to the NSPCC and will continue
12 this liaison role."
13 Now that is, I now understand, do I, the liaison
14 between you and the NSPCC in respect of this one centre?
15 MS GREEN: Maya Angelou Centre, yes.
16 MR GARNHAM: And am I also therefore to understand that the
17 contents of this meeting of which this is the last page
18 of the minutes relates to that centre and not to the
19 Moira Close Centre?
20 MS GREEN: That is correct.
21 MR GARNHAM: So the answer that we got earlier today that
22 suggested the procedure set out here applies equally to
23 the Moira Close Centre is correct or is not correct?
24 MS GREEN: It is not correct.
25 MR GARNHAM: Because what we find here applies only to

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1 the -- I have not yet succeeded in pronouncing it
2 properly.
3 MS GREEN: Maya Angelou.
4 MR GARNHAM: Thank you, that one. That centre.
5 MS GREEN: Shall I explain?
6 MR GARNHAM: Yes, in half a second. Since Victoria was
7 referred to the Moira Close Centre and not this one,
8 this had nothing to do with our case?
9 MS GREEN: Quite right.
10 MR GARNHAM: Now you can complete correcting my ignorance by
11 telling me the relationship between those two centres,
12 the NSPCC and --
13 MS GREEN: Moira Close. The NSPCC has been around a long
14 time and the Maya Angelou Centre has worked with us.
15 I was the link person for the Maya Angelou Centre. They
16 took referrals for us that came through the panel.
17 MR GARNHAM: And the panel?
18 MS GREEN: Right, okay. Carol Wilson wanted a one-entry
19 system for therapeutic work and support for children and
20 their families for statutory work, so that myself and
21 a team manager from North Tottenham and a team manager
22 from Hornsey were to facilitate a panel. I am trying to
23 explain it as simply as I can. Now, the panel consisted
24 of --
25 MR GARNHAM: Just so we know what we are talking about this

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1 is the Family Support Panel?
2 MS GREEN: That is the Family Support Panel.
3 MR GARNHAM: Yes, go on.
4 MS GREEN: Okay. Now, the Psychology Service and the NSPCC
5 did not attend the panel meetings but took referrals
6 from the panel meetings. The Family Centres,
7 Moira Close, Red Gables and the Child and Family Support
8 Team attended the meeting and they also took referrals
9 from us. Myself and the two managers went through the
10 forms and prioritised them in terms of need: which
11 family was in greatest need of service and what sort of
12 service? Then we would meet with the other three
13 people: two Family Centres and the Family Team, and one
14 of us would chair it and the work would be --
15 MR GARNHAM: Divvied up?
16 MS GREEN: Divvied up. Sometimes packages of support so
17 they might have joint things going on. Sometimes it was
18 decided that none of them were appropriate for any of
19 the services offered and should go somewhere else. So
20 depending on the nature of it. So the managers of those
21 services would attend the Family Support panel meeting
22 and between us we would divide the work up, if
23 appropriate.
24 MR GARNHAM: Does that mean that the only way that work
25 should reach the Moira Close Centre is through this

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1 panel?
2 MS GREEN: No. For the Family Centres anybody could refer
3 directly to the Family Centre for family support cases.
4 All statutory work should come through the panel.
5 MR GARNHAM: So, given the way Victoria's case was
6 understood to be in August 1998, was it or was it not
7 necessary for that case to go through the panel --
8 MS GREEN: Yes.
9 MR GARNHAM: It should have been done?
10 MS GREEN: Yes, and it should have gone after the
11 assessments.
12 MR GARNHAM: And the reason it should have done?
13 MS GREEN: Because it was a statutory case and it was
14 expected that people would make referrals after they had
15 done their initial assessments.
16 MR GARNHAM: Yes. So that in order to get to the Moira
17 Close Centre, Victoria's case should have been subject
18 firstly to a completed initial assessment?
19 MS GREEN: (Witness nods).
20 MR GARNHAM: And secondly to a reference to the panel?
21 MS GREEN: Yes. A form should have gone to the panel.
22 MR GARNHAM: I wonder if you could have a look, please, at
23 volume 2/190. We ought to start at 185, sorry. This is
24 a management review of the NSPCC Tottenham Child and
25 Family Centres which would have included Moira Close,

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1 would it not?
2 MS GREEN: Yes.
3 MR GARNHAM: It was undertaken following Victoria's death.
4 MS GREEN: Okay.
5 MR GARNHAM: If you go to page 190, you have what is called
6 the usual referral process:
7 "Referrals could be made via a number of routes,
8 primarily these came from social services department.
9 In general these should have come via a referral panel
10 which was attended by the service manager."
11 First of all, is that correct?
12 MS GREEN: That is correct.
13 MR GARNHAM: Do the words "in general" imply that that does
14 not always have to be the case?
15 MS GREEN: As I said before, statutory work should have come
16 through the panel. Family support cases could go
17 direct.
18 MR GARNHAM: Right.
19 "This system was not functioning well at the time
20 and frequently social workers would bypass this process
21 and make direct referrals. After a period this became
22 an unwritten but standard practice."
23 MS GREEN: Not to my knowledge.
24 MR GARNHAM: It certainly should not have been?
25 MS GREEN: It certainly should not have been.

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1 MR GARNHAM: Who was responsible for making sure in Haringey
2 Social Services that Moira Close Centre was functioning
3 properly, was being used properly? Sorry, that is two
4 different questions. Functioning properly first.
5 MS GREEN: The manager.
6 MR GARNHAM: Of?
7 MS GREEN: Moira Close.
8 MR GARNHAM: The manager would not have been a Haringey
9 employee, would he or she?
10 MS GREEN: Oh I see.
11 MR GARNHAM: Who in Haringey?
12 MS GREEN: There was a senior management group, was there
13 not, involved because it was tripartite between Health,
14 NSPCC and Social Services. I suppose it was Jean Croot.
15 MR GARNHAM: Being the representative from Haringey?
16 MS GREEN: Yes.
17 MR GARNHAM: Who should have been responsible for ensuring
18 it was being used correctly?
19 MS GREEN: I would have thought it was the responsibility of
20 the managers down there and the overall management team
21 for the centre.
22 MR GARNHAM: So who?
23 MS GREEN: I do not know their names. I do not know who
24 they were at that time.
25 MR GARNHAM: All right. In any event, it is your

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1 understanding that the process that we learned earlier
2 today from Mr Almedia was adopted in Victoria's case was
3 not the proper procedure in a case like that?
4 MS GREEN: No, not if it was -- no, because it was
5 a statutory case. I mean, there is an issue here as
6 well that they should not be taking referrals like that
7 from --
8 MR GARNHAM: You anticipate my next line of questioning and
9 I will come to that.
10 MS GREEN: Okay.
11 MR GARNHAM: At the moment I am trying to understand the
12 errors, if there be any, on the Haringey side of the
13 equation. I will then try to understand whether there
14 were errors on the other side of the equation.
15 As regards Haringey, was there an internal protocol
16 or criteria drawn up to direct social workers as to how
17 to use this?
18 MS GREEN: On the panel form were directions.
19 MR GARNHAM: On the panel form?
20 MS GREEN: Yes, there was a form that people had to fill in.
21 MR GARNHAM: To refer to the panel?
22 MS GREEN: To refer to the panel and at the front of that
23 was instructions blow by blow about how they were
24 supposed to go about referring to the panel and what
25 should happen following the panel.

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1 MR GARNHAM: I suppose if, as was found by whoever wrote
2 this management review or, as Mr Almedia told us, you
3 did not think you had to go to the panel, you would not
4 use the forms, so you would not know about that?
5 MS GREEN: That is possible I suppose but there would have
6 been statutory cases that would have gone through.
7 MR GARNHAM: Did the NSPCC refuse to accept referrals to the
8 Moira Close Centre if they had not been through the
9 panel?
10 MS GREEN: I do not know whether they did. Sometimes at the
11 panel they would say, "Someone has phoned me up about
12 that" or "I know a little bit about that", but then it
13 would have come through the panel. The idea was that
14 they would be suggesting to people that they need to go
15 through the panel.
16 MR GARNHAM: That sounds rather polite. If you had a case
17 on which there was statutory work to be done and it was
18 referred directly to the Moira Close Centre without
19 going through the panel NSPCC ought to be saying sorry,
20 we do not touch it unless it has been through the panel.
21 MS GREEN: That is right.
22 MR GARNHAM: Do you know whether statistics were kept as to
23 the --
24 MS GREEN: (Witness nods).
25 MR GARNHAM: Yes, tell me then.

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1 MS GREEN: Statistics were kept on how many referrals went
2 where and from where they were from, if you see what
3 I mean. From which district, east or west.
4 MR GARNHAM: Would those two districts refer whether they
5 went through the panel or would they be statistics --
6 MS GREEN: We only kept statistics of cases that went
7 through the panel. I have no idea what went the other
8 way.
9 MR GARNHAM: Did the panel eventually stop meeting?
10 MS GREEN: Yes, the panel did eventually stop meeting.
11 MR GARNHAM: Why?
12 MS GREEN: The two managers on either side got different
13 jobs.
14 MR GARNHAM: Two managers on either side?
15 MS GREEN: Yes, I had a manager from the east and a manager
16 from the west that assisted me in this process.
17 MR GARNHAM: Both Haringey employees?
18 MS GREEN: Both Haringey employees. They both have
19 different jobs which took them out of that.
20 MR GARNHAM: When was that? Before or after August 1999?
21 MS GREEN: I do not know.
22 MR GARNHAM: Could you find out for us?
23 MS GREEN: How?
24 MR GARNHAM: Some time after today?
25 MS GREEN: Okay, yes, I can try.

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1 MR GARNHAM: And let your solicitor know and we can have
2 that piece of information.
3 MS GREEN: Okay. It probably was after if I think about it
4 but I am not 100 per cent sure. But it did get
5 disbanded slowly.
6 MR GARNHAM: Who had the final decision whether or not to
7 accept a referral to the Moira Close Centre?
8 MS GREEN: Moira Close.
9 MR GARNHAM: Whose job was it to chase up family members to
10 ensure that they had engaged in the process once
11 a referral had been made?
12 MS GREEN: The process was it went to panel. As far as
13 I was concerned, when it was agreed at panel that they
14 would take it it was allocated to them, only in the
15 sense that social services remained the commissioning
16 workers, if you like, and they were taking on a piece of
17 work. They were supposed to contact the social worker
18 and say, "This case came up at panel. We have agreed to
19 take it on. Can we discuss it?" Then there was
20 supposed to be a meeting which drew up a contract of
21 work that that centre was going to be commissioned to
22 undertake, if you like, on behalf of the Social Services
23 Department. And that was the route.
24 MR GARNHAM: Because cases should only be referred, should
25 they not, to Moira Close to do a piece of work?

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1 MS GREEN: Absolutely.
2 MR GARNHAM: It was not intended as a way of simply moving
3 the case from Haringey to somebody else?
4 MS GREEN: No, and the responsibility -- there was an
5 allocated social worker who remained in the district who
6 was the social worker for the case who would be involved
7 in doing different pieces of work. So it was not as if
8 they went to there and then they were closed or
9 something. Because it was statutory work there was
10 a named social worker involved who would be the named
11 social worker after the commissioned piece of work was
12 completed.
13 MR GARNHAM: Thank you. Can I just, to complete my
14 re-education on this subject, get you to look at 26B
15 again, please? 26B/020.516. Which centre is the
16 subject matter of this meeting?
17 MS GREEN: Maya Angelou.
18 MR GARNHAM: Excellent. Thank you very much. That is all
19 I need to ask you about that subject. Let us move to
20 our fourth: your role in securing the file.
21 MS GREEN: (Witness nods).
22 MR GARNHAM: You raise your eyes heavenward.
23 25th February 2000 you tell us you received a telephone
24 call from Dr Rossiter following Victoria's admission to
25 hospital. You knew Dr Rossiter presumably?

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1 MS GREEN: Very well.
2 MR GARNHAM: You say that she was critical of Social
3 Services' involvement thus far.
4 MS GREEN: (Witness nods).
5 MR GARNHAM: She wondered what you had been doing, in
6 essence.
7 MS GREEN: (Witness nods).
8 MR GARNHAM: You nod?
9 MS GREEN: Yes.
10 MR GARNHAM: Why did she contact you? What was the purpose
11 of it?
12 MS GREEN: To let me know or let our section know of the
13 circumstances of the situation.
14 MR GARNHAM: Of Victoria's admission firstly to NMH and then
15 St Mary's.
16 MS GREEN: Yes.
17 MR GARNHAM: By that stage still NMH I suppose?
18 MS GREEN: Yes.
19 MR GARNHAM: You then did an index check?
20 MS GREEN: I did.
21 MR GARNHAM: Discovered the child had been known to
22 Lisa Arthurworrey?
23 MS GREEN: Yes.
24 MR GARNHAM: You contact her?
25 MS GREEN: Yes.

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1 MR GARNHAM: You then attempt to contact three line
2 managers?
3 MS GREEN: I did.
4 MR GARNHAM: All of whom were unavailable?
5 MS GREEN: Not in work, I think, actually.
6 MR GARNHAM: You could not get them?
7 MS GREEN: I could not get them.
8 MR GARNHAM: It does not sound terribly clever that you
9 cannot get one of three.
10 MS GREEN: No, but as I said when I contacted Carol Wilson's
11 PA she told me that Jean Croot was covering for their
12 absences and that she was the person that I should
13 contact.
14 MR GARNHAM: You spoke to Jean Croot?
15 MS GREEN: I did.
16 MR GARNHAM: And between you you decided that no other
17 children were at risk?
18 MS GREEN: That was the main thrust of our conversation yes.
19 MR GARNHAM: How did you reach that conclusion? On what
20 material?
21 MS GREEN: The social workers' information, the client index
22 check and the information known to me at that time, that
23 there was only one child in that household that we knew
24 of.
25 MR GARNHAM: Given what you went on to discover about the

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1 adequacy of the file, that sounds a slightly risky basis
2 for a conclusion of that sort.
3 MS GREEN: The client index check would tell you who was in
4 the household and that indicated there was only one
5 child in that household. That was also what Dr Rossiter
6 was saying and what the social worker seemed to be
7 saying. I had no reason at that stage to doubt that
8 information was not correct.
9 MR GARNHAM: That conclusion led you to decide that nothing
10 useful could be done that day and that the strategy
11 meeting could await the following Monday.
12 MS GREEN: Yes.
13 MR GARNHAM: So the 25th is a Friday and the strategy
14 meeting is fixed for the Monday?
15 MS GREEN: Yes.
16 MR GARNHAM: During which period Victoria tragically died.
17 MS GREEN: Yes.
18 MR GARNHAM: Ann Graham, I think it is right, then asked you
19 to go to North Tottenham District Office to secure the
20 file?
21 MS GREEN: Yes.
22 MR GARNHAM: What does that mean, "secure the file", to you?
23 MS GREEN: Get the file from North Tottenham and take it to
24 Carol Wilson's office.
25 MR GARNHAM: What did you understand by the word "secure"?

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1 MS GREEN: Not to be tampered with.
2 MR GARNHAM: If you are to ensure the integrity of the file,
3 you need first of all to obtain it as quickly as
4 possible?
5 MS GREEN: Yes.
6 MR GARNHAM: Why was it not done on the 25th, then?
7 MS GREEN: I suppose there were no senior managers available
8 at that time. I would not secure a file without
9 instruction from a senior manager, and that instruction
10 was not given to me.
11 MR GARNHAM: Because you could not find any of the three
12 senior managers that you tried for?
13 MS GREEN: But the manager that I did speak to did not
14 suggest that that was something that I should do.
15 MR GARNHAM: You have considerable experience in child
16 protection. Did it occur to you to suggest that it
17 might be sensible to secure the file that night?
18 MS GREEN: I did not think so.
19 MR GARNHAM: The dangers are obvious, are they not? This
20 was potentially going to turn into a murder
21 investigation, it was going to have serious
22 repercussions for your office and the file was the core
23 material that anybody investigating what was happening
24 to Victoria would need.
25 MS GREEN: Yes, but also -- I mean when I phoned

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1 Lisa Arthurworrey in the District she had known for
2 quite a while about the situation in relation to her
3 client. So before I knew the information which was in
4 the afternoon of the Friday she had already had that
5 information for a number of hours.
6 MR GARNHAM: Yes, but she is not the only person who could
7 conceivably want to have access to the file, is she?
8 MS GREEN: No. What I am saying is that I would not -- two
9 things I suppose I am saying. One is the District had
10 known about it for quite a while by the time I got to
11 know about it, which was in the afternoon. And secondly
12 I would follow instruction from a senior manager in
13 terms of securing a file. I would not think of it as
14 part of my responsibility. I would wait to be
15 instructed to do so.
16 MR GARNHAM: And you got those instructions on the Monday?
17 MS GREEN: I did indeed.
18 MR GARNHAM: The second element of securing the file after
19 getting hold of it quickly is to get hold of it without
20 anyone who might wish to tamper with it knowing you were
21 seeking to get hold of it, is it not?
22 MS GREEN: Yes.
23 MR GARNHAM: After you received that instruction you then
24 went to North Tottenham District Office?
25 MS GREEN: Yes.

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1 MR GARNHAM: Had someone warned them you were coming?
2 MS GREEN: Yes, I think so.
3 MR GARNHAM: Not very clever, was it?
4 MS GREEN: I did not warn them but somebody must have.
5 MR GARNHAM: And that was not very clever.
6 MS GREEN: Possibly.
7 MR GARNHAM: Not very clever for two reasons. Firstly
8 because it is conceivable that somebody being alerted
9 might tamper with the file, and secondly, just as
10 importantly, it was important to try and establish
11 a sequence of events that could show that nobody had
12 tampered with the file.
13 MS GREEN: Yes.
14 MR GARNHAM: So not only because one might fear that one of
15 your staff was going to tamper with it but also to
16 protect your staff against any allegations of tampering.
17 MS GREEN: (Witness nods).
18 MR GARNHAM: So for those two extremely good reasons it was
19 important that nobody alerted North Tottenham District
20 Office to the fact that you were turning up to secure
21 the file.
22 MS GREEN: Possibly.
23 MR GARNHAM: Why the doubt?
24 MS GREEN: Two reasons I suppose. One is that if you look
25 at the Child Protection Guidelines they also suggest

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1 that part of the securing process belongs to the team
2 manager. So the team manager is seen as someone who is
3 in a position to secure the file.
4 MR GARNHAM: Yes, but as it happened the team manager had
5 not been asked to, you had.
6 MS GREEN: Well securing the file has -- I was asked to
7 transport the file. So that was my part of securing the
8 file and ensuring that it was taken to Carol Wilson's
9 office.
10 MR GARNHAM: You say "securing" in your statement and you
11 have said "securing" so far and I had understood you to
12 have told the panel that you saw it as your function
13 that day to secure it, not merely to act as a securer.
14 MS GREEN: I would say it was my function to secure it but
15 I am also suggesting to you that it was not only one
16 person's function to secure the file. It actually came
17 under the auspices of the District Manager.
18 MR GARNHAM: Very well. When you arrived you say
19 Angella Mairs had already begun photocopying the file.
20 MS GREEN: Yes.
21 MR GARNHAM: Had you expected that?
22 MS GREEN: Yes.
23 MR GARNHAM: Why?
24 MS GREEN: That was normal custom and practice in Haringey
25 that files were photocopied so that there was a working

223
1 copy within the office.
2 MR GARNHAM: In the case of a dead child? What would you
3 need a working file for?
4 MS GREEN: I think that they did it because it was custom
5 and practice. Maybe they had not thought it through.
6 MR GARNHAM: The only reason you would want a file to
7 continue working on is if there was a child alive to be
8 the subject of it, would it not?
9 MS GREEN: I would have thought so, yes.
10 MR GARNHAM: But at any rate you were not surprised to find
11 Angella Mairs photocopying the file?
12 MS GREEN: No.
13 MR GARNHAM: Who was she working with?
14 MS GREEN: An administrator.
15 MR GARNHAM: Name?
16 MS GREEN: I do not know. I cannot even remember what the
17 woman looked like.
18 MR GARNHAM: Female?
19 MS GREEN: Yes.
20 MR GARNHAM: Black, white?
21 MS GREEN: I thought she was black, but I cannot swear to
22 it. I am not sure.
23 MR GARNHAM: Young or old? We will take 40 as the dividing
24 line.
25 MS GREEN: I really cannot remember in any detail.

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1 I suppose in her 30s.
2 MR GARNHAM: Young, then.
3 MS GREEN: Okay.
4 MR GARNHAM: You saw these two women photocopying the file?
5 MS GREEN: Yes.
6 MR GARNHAM: Why did you wait in the Investigation and
7 Assessment Team room?
8 MS GREEN: They had already begun photocopying the file. It
9 was probably halfway through. It was not a huge file
10 like some of them are. It was quite a slim volume.
11 They were probably halfway through that process when
12 I got there. So I felt it was important that they
13 completed that process. I did not know what the file
14 looked like when it was completed or indeed what was in
15 it or what should have been in it.
16 MR GARNHAM: Why did you wait in a different room? Why did
17 you not stay there?
18 MS GREEN: It is a very tiny room, the photocopying room.
19 There were two people already in it busily photocopying.
20 I did not see any particular role for myself standing
21 there with my back against the wall in a very tiny
22 office.
23 MR GARNHAM: This is quite an important job you are doing,
24 given how serious the events were that had prompted
25 somebody as senior as you to be sent on this errand.

225
1 They had not sent a school leaver who did not know one
2 end of a child protection file to another to pick it up.
3 They sent you.
4 MS GREEN: No.
5 MR GARNHAM: So it was self-evidently an important job.
6 MS GREEN: Yes.
7 MR GARNHAM: And yet you let the file out of your sight for
8 a lengthy period.
9 MS GREEN: Well the file had been out of my sight when -- it
10 had been partly photocopied before I had arrived. It
11 did not seem very sensible to stand there over the
12 second part of the photocopying process. I could not
13 see what useful purpose it would serve.
14 MR GARNHAM: You waited for half an hour?
15 MS GREEN: About half an hour.
16 MR GARNHAM: Before returning to the photocopy room?
17 MS GREEN: Yes.
18 MR GARNHAM: Had they finished photocopying it then?
19 MS GREEN: Nearly, I think. They had progressed it further.
20 MR GARNHAM: A slim file.
21 MS GREEN: I thought it was long enough.
22 MR GARNHAM: Already partly done when you arrived.
23 MS GREEN: Yes.
24 MR GARNHAM: Another half an hour of you waiting in the I&A
25 room.

226
1 MS GREEN: Yes.
2 MR GARNHAM: You got back to the room and they are still at
3 it.
4 MS GREEN: Yes.
5 MR GARNHAM: You asked for the file and Angella Mairs, as
6 you put it, rudely replied that you would get it when it
7 was ready.
8 MS GREEN: Mm-hmm.
9 MR GARNHAM: What did you think about that comment?
10 MS GREEN: I was annoyed.
11 MR GARNHAM: I can imagine that one would be annoyed at that
12 bad manners in any case, but it was more than that, was
13 it not?
14 MS GREEN: It was more than that, it was, yes.
15 MR GARNHAM: Because you had been sent over by a senior
16 manager, you, yourself no junior, to secure the file on
17 a very serious case where a child had died who had been
18 in your office's care. You found her photocopying the
19 file, she was already halfway through, she had taken
20 another half an hour and she still was not going to give
21 it to you. That was the position?
22 MS GREEN: That was.
23 MR GARNHAM: How long would you have expected her to take
24 photocopying this file if she had just gone through it
25 photocopying pages?

227
1 MS GREEN: I would have thought half an hour was
2 a reasonable amount of time.
3 MR GARNHAM: She was part way through it when you arrived,
4 you gave her another half an hour and she is still doing
5 something.
6 MS GREEN: Yes.
7 MR GARNHAM: Was she taking pages out of the file to
8 photocopy them or was she keeping them still bound?
9 MS GREEN: No, they were out as they were photocopied.
10 MR GARNHAM: Why did you not just take the file?
11 MS GREEN: I suppose because she had begun a process that
12 I felt needed to be concluded before I got involved.
13 I could not vouch at that point for the secureness of
14 the file and I felt that as she is a team manager on the
15 same level as me, had been given an instruction by her
16 manager to photocopy it, that I should let her complete
17 that part of the process which is why I gave her the
18 initial half an hour.
19 MR GARNHAM: How had you learnt she had been given an
20 instruction to photocopy it? Had she told you?
21 MS GREEN: No, I do not think so. I assumed her manager
22 would have given her that instruction.
23 MR GARNHAM: Which manager would that have been?
24 MS GREEN: That was Dave Duncan.
25 MR GARNHAM: So you were not told but you assumed that

228
1 Duncan had given Mairs the instruction to do this?
2 MS GREEN: Yes.
3 MR GARNHAM: Why did you not ask, "Why are you photocopying
4 it"?
5 MS GREEN: I assumed they were doing it in line with custom
6 and practice in Haringey. It had happened in terms of
7 other cases and it was not -- as I said I was not
8 surprised that it was being done.
9 MR GARNHAM: Despite all that had happened you decided it
10 was best to withdraw?
11 MS GREEN: Well I was not going to wrestle her for the file.
12 MR GARNHAM: Did you attempt to lay your hands on it?
13 MS GREEN: No.
14 MR GARNHAM: Why not?
15 MS GREEN: Because I did not think that that was either
16 prudent or sensible particularly.
17 MR GARNHAM: So you withdrew and left her with the file
18 again?
19 MS GREEN: Mm-hmm.
20 MR GARNHAM: Did it occur to you that it either might or
21 could be said to leave Ms Mairs with the opportunity to
22 tamper with it?
23 MS GREEN: I would have said that she would have had ample
24 opportunity to tamper with the file a long time before
25 that moment in time.

229
1 MR GARNHAM: True, but she appeared to be wanting more time
2 to do whatever it was she was doing and it was a long
3 time for photocopying a file.
4 MS GREEN: I agree with that and that is why I went down and
5 more or less demanded the file. When it was not
6 forthcoming, I decided to seek advice from my manager.
7 I was not going to wrestle with her for the file.
8 MR GARNHAM: And you then phoned Ann Graham?
9 MS GREEN: I phoned my manager and I said I was very annoyed
10 and she was irate that I had --
11 MR GARNHAM: What did she say?
12 MS GREEN: She said, "I am not having it and we are going to
13 get this sorted out and I will be contacting managers
14 and you will be given the file pronto" basically.
15 MR GARNHAM: And then you went?
16 MS GREEN: I went.
17 MR GARNHAM: Rather than pronto you had another 20 minutes?
18 MS GREEN: Yes, something like --
19 MR GARNHAM: Cooling your heels?
20 MS GREEN: Yes, and then the file was given to me.
21 MR GARNHAM: 20 minutes I got from your statement.
22 MS GREEN: Okay. Yes.
23 MR GARNHAM: So what are we talking about now, an hour and
24 20 minutes?
25 MS GREEN: An hour and 20 minutes.

230
1 MR GARNHAM: To finish a file that was half done when you
2 arrived?
3 MS GREEN: Yes.
4 MR GARNHAM: Any idea what she was doing?
5 MS GREEN: No idea.
6 MR GARNHAM: Have you any idea why it was necessary to
7 photocopy the file?
8 MS GREEN: As I say --
9 MR GARNHAM: Apart from this mysterious custom and practice?
10 MS GREEN: I think because there are usually other children
11 involved and other children and families that they want
12 to keep a working copy in the district and maybe it was
13 just done out of that custom and practice.
14 MR GARNHAM: You knew there was not in this case because you
15 already told us that was the reason you did not come
16 over on the Friday night.
17 MS GREEN: Yes.
18 MR GARNHAM: So the only child referred to on this file was
19 dead. No obvious explanation why anybody should want to
20 photocopy this, was there?
21 MS GREEN: I agree but I was confronted with that situation
22 when I got there. So that had already begun, that
23 process. Whether it was right or wrong it had started.
24 MR GARNHAM: And you let it continue for another hour and 20
25 minutes?

231
1 MS GREEN: I decided to let it continue for half an hour so
2 they could recompile the file.
3 MR GARNHAM: Lisa Arthurworrey, as I am sure you know, says
4 that she saw Angella Mairs remove the first contact
5 sheet from the file. You know that that is what
6 Lisa Arthurworrey says?
7 MS GREEN: I do know that is what Lisa Arthurworrey asserts.
8 MR GARNHAM: Did she report that to you, Lisa Arthurworrey?
9 MS GREEN: No.
10 MR GARNHAM: Would you have expected her to report it to
11 you?
12 MS GREEN: Absolutely.
13 MR GARNHAM: If she had reported it to you, what would have
14 happened?
15 MS GREEN: At that moment if she had reported it to me when
16 I was in the office?
17 MR GARNHAM: Well, let us do that moment first.
18 MS GREEN: I think I would have gone straight to Dave,
19 Dave Duncan, and said that this assertion has been made
20 and that perhaps Angella Mairs should not leave the
21 office.
22 MR GARNHAM: And?
23 MS GREEN: I would assume that they may have searched her
24 belongings. I mean, depending on where Lisa was saying
25 the paper had been put or whatever, I would have

232
1 suggested that there be an immediate investigation into
2 the situation.
3 MR GARNHAM: Where was Lisa Arthurworrey at the time?
4 MS GREEN: Surprisingly enough she was in the I&A room.
5 MR GARNHAM: With you?
6 MS GREEN: Some of the time, yes. She was sitting working
7 in there. I was not there all of the time because
8 I made a phone call from the next floor up, which was my
9 phone call to my manager. But she was in there a lot of
10 the time.
11 MR GARNHAM: So she had been with -- tell me whether this is
12 right or wrong on your understanding -- in the
13 photocopying room and had come out?
14 MS GREEN: Before I arrived?
15 MR GARNHAM: Yes.
16 MS GREEN: Quite possibly, yes. And she may have gone in
17 there when we were down there.
18 MR GARNHAM: Do you know when it was she went into the
19 photocopying room?
20 MS GREEN: No.
21 MR GARNHAM: If she had reported that Mairs had removed
22 a sheet, would she, Arthurworrey, have been at risk of
23 disciplinary sanction?
24 MS GREEN: No.
25 MR GARNHAM: You tell us that you logged out the file in

233
1 your name.
2 MS GREEN: I did.
3 MR GARNHAM: What is that, on a computer?
4 MS GREEN: No, I did it through an administrator so that
5 I was taking responsibility for any loss, damage or
6 whatever at that stage of the file.
7 MR GARNHAM: That had not already happened?
8 MS GREEN: I did not know that.
9 MR GARNHAM: Well we do not know that either.
10 MS GREEN: No. I put it in one of those very large
11 envelopes to ensure the security of the name so that
12 no-one could see it.
13 MR GARNHAM: So that it is clear, my concern is equally
14 whether in fact Mairs removed a page or whether the
15 opportunity was given for somebody wrongly to accuse her
16 of removing a page. Each of those are potentially
17 serious, are they not?
18 MS GREEN: Yes.
19 MR GARNHAM: You took the file, went back to Wilson's
20 office, arrived at 12 midday. What time had you set off
21 on this little expedition?
22 MS GREEN: I was thinking about that. I think I set off at
23 10 to go to North Tottenham. I would have arrived at
24 about half 10, made myself known, confronted her about
25 the file at about 11, got the final file at about 11.20,

234
1 got in my car, drove to Cumberland Road, parked it, got
2 there at about a quarter to 12. I am guessing.
3 Approximately, something like that.
4 MR GARNHAM: You then went through the file?
5 MS GREEN: With Carol.
6 MR GARNHAM: With Carol Wilson and together you compiled
7 what I take to be a fairly speedy case summary?
8 MS GREEN: Indeed.
9 MR GARNHAM: Have you still got volume 2 in front of you?
10 MS GREEN: Yes, I have.
11 MR GARNHAM: Can you go to page 172 and confirm to me that
12 that is not the document you compiled? That is not your
13 summary, is it?
14 MS GREEN: I do not think so.
15 MR GARNHAM: That looks like a rather lengthy --
16 MS GREEN: That is a little bit more involved.
17 MR GARNHAM: Was yours a handwritten summary?
18 MS GREEN: Yes. No. I dictated, she wrote.
19 MR GARNHAM: What were the time constraints under which you
20 were working?
21 MS GREEN: One hour.
22 MR GARNHAM: Why?
23 MS GREEN: We had a single agency meeting at 1 o'clock and
24 we had a multiagency meeting -- let me get this right --
25 at 2 o'clock.

235
1 MR GARNHAM: Single agency meeting. Is that an animal known
2 to science? Does that just mean meeting?
3 MS GREEN: Meeting, okay.
4 MR GARNHAM: And that is in-house?
5 MS GREEN: That is what I mean by single agency. Just us,
6 Social Services.
7 MR GARNHAM: That was a meeting with Duncan, Mairs,
8 Arthurworrey and Robertson?
9 MS GREEN: Yes.
10 MR GARNHAM: Anyone raise with Mairs what she had been doing
11 photocopying the file?
12 MS GREEN: No, we never got into anything about the file.
13 We went through the case papers before they arrived and
14 then we asked them questions about it when they did
15 arrive.
16 MR GARNHAM: Anyone raise with Mairs the delay in handing it
17 over to you?
18 MS GREEN: No, there was no discussion whatsoever about the
19 getting of the file.
20 MR GARNHAM: 2 o'clock that afternoon, multiagency strategy
21 meeting.
22 MS GREEN: Yes.
23 MR GARNHAM: Why not at St Mary's?
24 MS GREEN: It was at the Civic, I think, the Civic Centre.
25 MR GARNHAM: Why was it held at your offices rather than the

236
1 hospital where the child was?
2 MS GREEN: I suppose the majority of the agencies would have
3 found Haringey the central place.
4 MR GARNHAM: There was --
5 MS GREEN: It was a big meeting as well. There were a lot
6 of people. You would have needed a fair sized room --
7 MR GARNHAM: There was medical presence there. Dr Britto
8 was there, was he not?
9 MS GREEN: It was huge. There must have been 30 people.
10 MR GARNHAM: Volume 2 again, please, 219.
11 MS GREEN: Oh, smaller than I thought.
12 MR GARNHAM: It includes Joseph Britto, the paediatrician.
13 MS GREEN: Yes.
14 MR GARNHAM: But those were the people who were there.
15 MS GREEN: Yes.
16 MR GARNHAM: Should it not have been at the hospital?
17 MS GREEN: I would not have thought so.
18 MR GARNHAM: Is that not the usual procedure at Haringey?
19 MS GREEN: This was a multiagency strategy meeting to review
20 the case. I would have thought they would have -- I did
21 not organise the strategy meeting so I do not know what
22 the thinking was but if you look at it the vast majority
23 of people attending would have been Haringey based, so
24 it was probably felt as this doctor could travel or
25 whatever that --

237
1 MR GARNHAM: In fairness to you by then Victoria sadly had
2 died.
3 MS GREEN: Oh yes.
4 MR GARNHAM: The meeting lasted the rest of the day.
5 MS GREEN: Yes.
6 MR GARNHAM: Who wrote these minutes?
7 MS GREEN: Marie France Palmer.
8 MR GARNHAM: Did you read them either then or later?
9 MS GREEN: No.
10 MR GARNHAM: Have you ever read them?
11 MS GREEN: Probably -- not that I remember.
12 MR GARNHAM: There is a number of errors in them.
13 MS GREEN: Okay.
14 MR GARNHAM: Victoria's ethnicity is still misdescribed.
15 She is said to be Congolese. You do not know where that
16 came from?
17 MS GREEN: No, I do not know where that came from.
18 MR GARNHAM: You told the meeting, according to page 223,
19 that Social Services had some information about the
20 extended family in France.
21 MS GREEN: Yes, that must have been when I went through the
22 file.
23 MR GARNHAM: Do you recall what that information was?
24 MS GREEN: She had a family in France, other children and
25 a house, I think.

238
1 MR GARNHAM: Do you recall --
2 MS GREEN: And was a French national I think.
3 MR GARNHAM: Do you recall when that information had been
4 obtained?
5 MS GREEN: From the file? Sorry, ask me again.
6 MR GARNHAM: Do you recall when it was that the inquiry had
7 been made of the French Social Services or whoever it
8 was in France?
9 MS GREEN: From the social worker?
10 MR GARNHAM: Yes.
11 MS GREEN: No idea.
12 MR GARNHAM: Thank you. You end your statements by telling
13 us that you have received a letter from UNISON asking
14 whether you can assist them as to whether pages were
15 permanently removed from the file and you said you could
16 not. That presumably was because you did not see
17 Ms Mairs begin the photocopying.
18 MS GREEN: (Witness nods). Nor indeed did I see her remove
19 anything from the file.
20 MR GARNHAM: No. That was because either it did not happen
21 or alternatively because you withdrew and you were not
22 there when it happened if it did?
23 MS GREEN: Indeed.
24 MR GARNHAM: Angella Mairs told Monaghan that you,
25 Arthurworrey and she copied the file together.

239
1 MS GREEN: Wrong.
2 MR GARNHAM: Not true?
3 MS GREEN: Not true.
4 MR GARNHAM: Not true in two respects: firstly that you had
5 no part in the photocopying?
6 MS GREEN: Absolutely not.
7 MR GARNHAM: And secondly that from what you saw while you
8 were there Lisa Arthurworrey was not involved in it
9 either?
10 MS GREEN: No.
11 MR GARNHAM: Thank you very much, sir.
12 THE CHAIRMAN: Thank you, Mr Garnham. Ms Lawson, seeing the
13 time I think that we will adjourn until tomorrow
14 morning. That will mean that we will adjourn until 9.30
15 tomorrow morning and what it means, Ms Green, is that
16 you are definitely not allowed to discuss your evidence
17 overnight and you will remain under oath for that
18 period.
19 MS GREEN: Okay.
20 THE CHAIRMAN: So ladies and gentlemen we will adjourn until
21 9.30 tomorrow morning.
22 (4.50 pm)
23 (Hearing adjourned until 9.30 am the following day)
24
25

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