Archived Transcript for 30 November 2001: Pages 151 to 195

151



1 MR GARNHAM: And the case was left to be actioned by

2 an allocated social worker with the review being through

3 her line manager?

4 MS KOZINOS: And her Team Manager who would have been fully

5 aware of the strategy meeting. We would have to have

6 authorised the decisions.

7 MR GARNHAM: And all that was happening against the

8 background of a child in hospital, about whom there were

9 serious concerns, who you do not want to leave the

10 hospital before the assessment had been completed?

11 MS KOZINOS: That is right.

12 MR GARNHAM: Yes, thank you. 1st November. You have no

13 further involvement before 1st November?

14 MS KOZINOS: That is right.

15 MR GARNHAM: 1st November you are the Duty Senior

16 Practitioner in the office?

17 MS KOZINOS: Yes.

18 MR GARNHAM: Lisa Arthurworrey comes to ask you advice?

19 MS KOZINOS: That is right.

20 MR GARNHAM: She asks you advice about a telephone call she

21 has had from Kouao in which Kouao has alleged that

22 Manning had on three occasions sexually abused Victoria?

23 MS KOZINOS: That is not what she says, no.

24 MR GARNHAM: What did she tell you?

25 MS KOZINOS: She did not say who the case was, she came and

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1 said to me that she could not find her Team Manager.

2 One of her cases --

3 MR GARNHAM: Who was she referring to?

4 MS KOZINOS: Carole Baptiste is her Team Manager, sorry.

5 She had said she had received a phone call from a mother

6 making allegations regarding her child being sexually

7 abused.

8 MR GARNHAM: Yes.

9 MS KOZINOS: And I said to her -- I gave her guidance and

10 consultation and I said, "Invite her in. Carry out

11 a risk assessment and arrange a strategy meeting ASAP.

12 When Carole comes in, discuss it with her as well."

13 MR GARNHAM: Did you look at the file before you gave that

14 advice?

15 MS KOZINOS: No.

16 MR GARNHAM: Why not?

17 MS KOZINOS: I based it on the information she had given me.

18 MR GARNHAM: Did you envisage, when you gave that advice,

19 Kouao coming in alone or coming in with Victoria?

20 MS KOZINOS: With Victoria.

21 MR GARNHAM: Did you know at that time whether Victoria was

22 memorandum trained?

23 MS KOZINOS: No.

24 MR GARNHAM: "No" you did not know, or "no" you knew she was

25 not?

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1 MS KOZINOS: No, I would not have known or I did not know.

2 I would not have known.

3 MR GARNHAM: What was intended to happen then? The mother

4 and child were to come in with a view to doing what?

5 MS KOZINOS: To find out what mother was saying on the phone

6 and also speak to the child.

7 MR GARNHAM: And who was to conduct those enquiries?

8 MS KOZINOS: The allocated social worker in conjunction with

9 her Team Manager.

10 MR GARNHAM: So Lisa Arthurworrey would do that?

11 MS KOZINOS: Yes.

12 MR GARNHAM: Is it the case that three people then turned up

13 at the office?

14 MS KOZINOS: So I believe, yes.

15 MR GARNHAM: Were you involved at that stage?

16 MS KOZINOS: Only to ask -- when Lisa came in, she said

17 Carole still had not come in and that Mr Manning had

18 also attended and I said for him to be sent straight

19 away away. It was not appropriate for him to be there.

20 MR GARNHAM: And she did as you suggested?

21 MS KOZINOS: That is right.

22 MR GARNHAM: Did you have any further involvement then?

23 MS KOZINOS: No, Carole had to come back in then.

24 MR GARNHAM: Carole Baptiste was--

25 MS KOZINOS: The allocated Team Manager to the case.

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1 MR GARNHAM: You told Lisa Arthurworrey also to arrange

2 a strategy meeting?

3 MS KOZINOS: That is right.

4 MR GARNHAM: With the Police Child Protection Team?

5 MS KOZINOS: That is right, or recommended a strategy

6 meeting.

7 MR GARNHAM: When did you envisage that happening?

8 MS KOZINOS: As soon as possible.

9 MR GARNHAM: What day of the week was this? Friday?

10 MS KOZINOS: I do not know, sorry.

11 MR GARNHAM: It is 1st November.

12 MS KOZINOS: I do not know. I think, is it Monday?

13 MR GARNHAM: I am told it was the Monday.

14 MS KOZINOS: Yes.

15 MR GARNHAM: When was the strategy meeting to be arranged?

16 MS KOZINOS: She was to discuss it with her Team Manager who

17 would have had to chair it.

18 MR GARNHAM: When would you have expected the strategy

19 meeting in such a case to take place?

20 MS KOZINOS: 72 hours, sexual abuse.

21 MR GARNHAM: 72 hours, sexual abuse?

22 MS KOZINOS: Yes.

23 MR GARNHAM: Would you have a look at volume 24, please.

24 Page 44, please. This is part of Haringey's Purple

25 Book.

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1 MS KOZINOS: Yes.

2 MR GARNHAM: Chapter 9:

3 "Initial Investigations/Risk Assessment for Cases of

4 Alleged Sexual Abuse. Timescale: A strategy meeting

5 must be called within 72 hours of receipt of all

6 referrals indicating high level of suspicion."

7 Is that the provision you had in mind?

8 MS KOZINOS: Yes.

9 MR GARNHAM: Go on to page 49, please. Paragraph 2.1:

10 "Set up the strategy meeting within 72 hours of

11 receipt of referral."

12 The passage in the last sentence in bold:

13 "This meeting/discussion must take place immediately

14 if the alleged incident occurred within the last

15 72 hours in order to make arrangements for an urgent

16 medical examination."

17 So if the allegation that is being made is that the

18 child has been sexually abused within 72 hours, you

19 should not wait for another 72 hours for the strategy

20 meeting; instead, it should be done immediately. Is

21 that not right?

22 MS KOZINOS: I think so.

23 MR GARNHAM: And the reason for that is obvious, is it not:

24 that it might be possible if you have a strategy meeting

25 very promptly after a sexual abuse has taken place to

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1 get forensic medical evidence that would establish the

2 nature of the abuse? So how is it that in this case the

3 strategy meeting is not set up for three days?

4 MS KOZINOS: You would need to ask Karen, the responsible

5 Team Manager. I did not attend the strategy meeting.

6 MR GARNHAM: Well, you suggested it was done. Did you

7 suggest that it take place straight away?

8 MS KOZINOS: I advised her to do it as soon as possible.

9 MR GARNHAM: You just said to us 72 hours.

10 MS KOZINOS: You asked me what you thought the expectation

11 was. I advised her as soon as possible. She went to

12 discuss it with her Team Manager who would have chaired

13 it.

14 MR GARNHAM: Did you say to her, "Given that the allegation

15 is of recent sexual abuse it must be done as soon as

16 possible to preserve the medical evidence"?

17 MS KOZINOS: No, I just said do it as soon as possible. It

18 was a very brief discussion.

19 MR GARNHAM: I asked you when would you have expected this

20 strategy meeting to take place, and you said 72 hours.

21 MS KOZINOS: Yes.

22 MR GARNHAM: So you expected --

23 MS KOZINOS: You said what I would have expected.

24 MR GARNHAM: Yes.

25 MS KOZINOS: Yes, for myself, but Lisa was told to do it as

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1 soon as possible.

2 MR GARNHAM: So you expected 72 hours, but you told her to

3 do it as soon as possible and despite the fact that you

4 expected it to happen in 72 hours you knew that she

5 should do it much quicker than that.

6 MS KOZINOS: No, it was for her to discuss with her Team

7 Manager who would be chairing it. It would be her Team

8 Manager who would decide with the allocated worker when

9 he would chair it.

10 MR GARNHAM: She has come to you for advice as a senior

11 practitioner?

12 MS KOZINOS: That is right and I have recommended or

13 suggested that she needs to book a strategy meeting as

14 soon as possible and redirected her back to her Team

15 Manager.

16 MR GARNHAM: But you did not expect her to do it for three

17 days?

18 MS KOZINOS: That was my experience but that is not what was

19 conveyed to Lisa.

20 MR GARNHAM: I see, so the situation is this: you expected

21 her to fix this three days later. By chance you

22 happened to use the words "as soon as possible", and

23 what she should have done, having heard those words, is

24 comply with this rule, even though you did not indicate

25 it to her.

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1 MS KOZINOS: No. You said to me what would I have expected.

2 That would have been my expectations.

3 MR GARNHAM: You should have expected her to do it

4 immediately.

5 MS KOZINOS: But I was to be in consultation with her

6 manager, who would have chaired it.

7 MR GARNHAM: What is the purpose of your advice, then? Your

8 advice, if she had asked what you expect, would have

9 been positively misleading.

10 MS KOZINOS: Possibly and this is why it is good to check it

11 with your Team Manager.

12 MR GARNHAM: I see. You seem to find this amusing.

13 MS KOZINOS: I do not, that is what I am saying. I do not

14 find it amusing at all.

15 MR GARNHAM: Later that day, after you told Lisa that

16 Manning should not remain, did you discover what had

17 happened?

18 MS KOZINOS: Sorry, say that again?

19 MR GARNHAM: Later on that day, after you had advised --

20 MS KOZINOS: Actually, can I have a break, if that is okay?

21 THE CHAIRMAN: How long a break do you want?

22 MS KOZINOS: Three minutes.

23 THE CHAIRMAN: Three minutes, of course. You can have

24 a break for three minutes, if that is the case.

25 MS KOZINOS: Thank you.

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1 (2.04 pm)

2 (A short break)

3 (2.07 pm)

4 MS KOZINOS: For the record, in reference to your earlier

5 comment, which I did not appreciate and I think is

6 misleading, in terms I find this Inquiry amusing, I do

7 not find it amusing but it is not easy giving evidence,

8 it is nerves, and you have interpreted my nervousness as

9 amusement and I would like that to be put on the record,

10 please.

11 MR GARNHAM: That is very fair of you. So when you laugh or

12 smile, it is not because you are finding it funny, but

13 because you are nervous?

14 MS KOZINOS: I am very nervous, you can hear that.

15 MR GARNHAM: I will try to avoid making you more nervous.

16 A second act of fairness I need to do is the

17 allegations -- let me ask you this. Did you know the

18 nature of the allegations that had been made in respect

19 of Victoria?

20 MS KOZINOS: I did not know the details. I was told they

21 were of a sexual abuse nature.

22 MR GARNHAM: Because in fact the instance of digital

23 penetration of Victoria had occurred long before in

24 September, so that a medical examination would not have

25 assisted in that regard, would it?

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1 MS KOZINOS: I would not have known that at the time.

2 MR GARNHAM: Because you did not know anyway, all right.

3 At any time during those early days of November did

4 you read Victoria's file?

5 MS KOZINOS: No.

6 MR GARNHAM: You say that later that day Carole Baptiste

7 asked you a favour to see Kouao to explain the child

8 protection procedures.

9 MS KOZINOS: Yes.

10 MR GARNHAM: Why were you being asked to do favours for

11 Carole Baptiste?

12 MS KOZINOS: She asked me.

13 MR GARNHAM: Was it unusual to be asked to do favours by

14 Carole Baptiste?

15 MS KOZINOS: No.

16 MR GARNHAM: Was that because everybody used to ask others

17 to do them favours or was she particularly enthusiastic

18 about asking others to do favours for her?

19 MS KOZINOS: It is not unusual to support your colleagues

20 but in fairness she asked more in particular than

21 others.

22 MR GARNHAM: By that time, by November of 1999, did you

23 think Carole Baptiste was capable of doing her own job?

24 MS KOZINOS: I could not comment, I was concerned about her

25 attendance and her non-commitment.

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1 MR GARNHAM: Did you think she was following up the work

2 that had been given to her?

3 MS KOZINOS: I do not know. I would not know.

4 MR GARNHAM: Did you start to feel that the time was coming

5 for others to take over her work?

6 MS KOZINOS: No, I would not say that.

7 MR GARNHAM: You then met Kouao and explained the child

8 protection procedures to her.

9 MS KOZINOS: (Nods).

10 MR GARNHAM: She agreed not to go back to Manning's house

11 and you authorised funding for a minicab to Mr and

12 Mrs Kimbidima's address in Wood Green.

13 MS KOZINOS: That was after Lisa went back on Duty and

14 I authorised what is called the Section 17, it needs

15 a senior practitioner's signature or a Team Manager's

16 signature.

17 MR GARNHAM: Yes. What checks were made to the

18 appropriateness of the premises before you agreed that?

19 MS KOZINOS: I did not agree it, I just aided the process in

20 terms of funds. Carole was supervising that process.

21 MR GARNHAM: Did you discover whether any checks had been

22 made about the adequacy of those premises?

23 MS KOZINOS: No, I did not ask Carole or Lisa.

24 MR GARNHAM: Did you find out about the sleeping

25 arrangements?

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1 MS KOZINOS: No, they would have been discussed between Lisa

2 and the Team Manager.

3 MR GARNHAM: About the suitability of Mr and Mrs Kimbidima

4 to have a child in their house?

5 MS KOZINOS: No, like I say to you, that would have been

6 the --

7 MR GARNHAM: Whether they had the food or money to look

8 after another two mouths?

9 MS KOZINOS: No, I did not make any enquiries. I would have

10 expected that to have been done with the allocated

11 worker and the manager who were both there?

12 MR GARNHAM: Whether or not an emergency contact number had

13 been given to the Kimbidimas? All down to the allocated

14 social worker?

15 MS KOZINOS: And the Team Manager, who are both present, who

16 have case responsibility for this case.

17 MR GARNHAM: So you understood the favour you were doing for

18 Carole Baptiste was limited to explaining literally what

19 the child protection procedures were?

20 MS KOZINOS: I gave her the booklets.

21 MR GARNHAM: You did not see it as any part of your function

22 to ensure that what happened to Victoria thereafter was

23 appropriate?

24 MS KOZINOS: That would be the Team Manager. It is not for

25 me to monitor team managers. I am a senior

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1 practitioner.

2 MR GARNHAM: The Team Manager has asked for your assistance

3 and you are giving it.

4 MS KOZINOS: And I did that specific piece of work for her

5 which is very short and very brief.

6 MR GARNHAM: Who do you think was going to ensure all the

7 steps I have mentioned are done?

8 MS KOZINOS: Hopefully the Team Manager.

9 MR GARNHAM: It is essential that enquiries are made to make

10 sure the Kimbidimas were a suitable couple to take this

11 woman and child.

12 MS KOZINOS: You would have to do checks, yes.

13 MR GARNHAM: That the premises were adequate, enough food in

14 the house and enough beds into sleep in?

15 MS KOZINOS: Yes.

16 MR GARNHAM: That was necessary?

17 MS KOZINOS: You would have to check if it is a safe

18 environment for the child to be living.

19 MR GARNHAM: Since you had assumed the role of supervisor in

20 this case, was it not part of your function to ensure

21 that happened?

22 MS KOZINOS: No, that was part of the Team Manager's

23 function whose case it is and who has the allocated

24 worker.

25 MR GARNHAM: When you were asked to do this favour by

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1 Carole Baptiste, what was she going to be doing? What

2 was she doing at the time?

3 MS KOZINOS: I do not recall, to be honest with you.

4 MR GARNHAM: Was she asking to you do this favour because

5 she was busy?

6 MS KOZINOS: I am not sure.

7 MR GARNHAM: Is that not the likely reason why she should

8 ask you to do a favour, because she is not busy or she

9 is not going to be there?

10 MS KOZINOS: No, most probably she was busy in the middle of

11 something. I do not know.

12 MR GARNHAM: You authorised the taxi fare?

13 MS KOZINOS: Yes, I signed the Section 17 funds.

14 MR GARNHAM: Why did you not say, "That is not my job, that

15 is the Team Manager's job"?

16 MS KOZINOS: We had the funds on Duty, that is why it came

17 to me. we had a float on Duty.

18 MR GARNHAM: You mean that was not available to

19 Carole Baptiste?

20 MS KOZINOS: No, I had the float for Duty that --

21 MR GARNHAM: I see.

22 MS KOZINOS: I was holding it on Duty.

23 MR GARNHAM: Did you not consider it any part of your

24 function before letting this little girl go out of your

25 offices to ensure that the place she was going was okay?

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1 MS KOZINOS: No, I would have expected the Team Manager to

2 have done that.

3 MR GARNHAM: Was there any evidence the Team Manager was

4 doing anything about this case?

5 MS KOZINOS: It is not for me to monitor the Team Manager.

6 MR GARNHAM: I know, but you are a senior social worker with

7 some years of experience and you have a little girl who

8 has come in, about whom there have been allegations of

9 sexual abuse. It has been decided to send her to a safe

10 house, so to speak. The Team Manager is not involved

11 because she has asked you to do the job. Do you not

12 assume --

13 MS KOZINOS: She is involved. She has asked me to do

14 certain bits. She is an experienced manager of four

15 years. I would have no reason to believe that she would

16 not carry out --

17 MR GARNHAM: How could you let this little girl leave

18 without ensuring that those things had happened?

19 MS KOZINOS: It was for the Team Manager whose case it was

20 to do.

21 MR GARNHAM: You do not shut your eyes to something going

22 wrong in your office, do you?

23 MS KOZINOS: I did not see anything going wrong at the time.

24 There is no indication there that Carole would not have

25 recommended that or Lisa would not have followed it up.

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1 MR GARNHAM: But there is no indication that they were doing

2 any of those things.

3 MS KOZINOS: I think it is fair to say people are employed

4 to do certain jobs.

5 MR GARNHAM: What made you think that those steps would be

6 taken after you had authorised the taxi fare?

7 MS KOZINOS: Because there had been case discussions. I do

8 not know. I would not have been involved in that

9 process or privy to that discussion.

10 MR GARNHAM: Did you see them leave?

11 MS KOZINOS: No. I was managing Duty, in terms I had the

12 float that came.

13 MR GARNHAM: Did you see Victoria leave to get in a taxi?

14 MS KOZINOS: I did not even see Victoria this day.

15 MR GARNHAM: Do you know how long it was after your

16 conversation with them that they did leave?

17 MS KOZINOS: No, I have no idea.

18 MR GARNHAM: Do you know whether Carole Baptiste ever

19 involved herself with things that afternoon?

20 MS KOZINOS: No idea.

21 MR GARNHAM: You did not see Victoria that day, you have

22 just said so.

23 MS KOZINOS: No.

24 MR GARNHAM: But Lisa Arthurworrey and Valerie Robertson

25 interviewed her?

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1 MS KOZINOS: Yes. I was not involved in that process and

2 I did not have any contact with Victoria.

3 MR GARNHAM: You say you then updated Carole Baptiste as to

4 what had happened?

5 MS KOZINOS: In terms of I had done what she had requested,

6 I had given the mother the child protection procedures.

7 Like I said, she was very brief.

8 MR GARNHAM: And you told her presumably that you had

9 authorised the taxi fare.

10 MS KOZINOS: No, I had not authorised it. She asked me for

11 funds. It was on her recommendation I had done the

12 process. I was on Duty.

13 MR GARNHAM: You went through the process of signing for the

14 money?

15 MS KOZINOS: Yes, and taking it out of the float which

16 I had.

17 MR GARNHAM: Did you and she have any conversation about the

18 adequacy of the place the child was going to go to?

19 MS KOZINOS: No, she was discussing it with Lisa.

20 MR GARNHAM: I see. The following day, 2nd October, you

21 were in the office when Kouao visited with Victoria?

22 MS KOZINOS: Yes.

23 MR GARNHAM: She asked to see Lisa Arthurworrey?

24 MS KOZINOS: Yes.

25 MR GARNHAM: Lisa Arthurworrey I think was on a course that

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1 day, was she not?

2 MS KOZINOS: So I heard after, yes.

3 MR GARNHAM: Kouao asked to see you?

4 MS KOZINOS: Yes.

5 MR GARNHAM: Yes?

6 MS KOZINOS: The receptionist recognised her from the day

7 before and asked if she wanted to see me and she said

8 yes.

9 MR GARNHAM: She began talking to you whilst she was in the

10 reception area?

11 MS KOZINOS: That is right.

12 MR GARNHAM: You led her into an interview room and you got

13 Victoria to wait in the reception room cared for by the

14 receptionist?

15 MS KOZINOS: Yes, the reception was busy.

16 MR GARNHAM: When you got Kouao into the interview room she

17 told you that the allegations had been made up by

18 Victoria?

19 MS KOZINOS: That is right.

20 MR GARNHAM: What were your feelings about that when you

21 first heard it?

22 MS KOZINOS: I asked her why Victoria would make such

23 a thing up.

24 MR GARNHAM: Yes. And?

25 MS KOZINOS: Sorry, can I refer back to my --

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1 MR GARNHAM: Yes, please do.

2 MS KOZINOS: Is it in here?

3 MR GARNHAM: Paragraphs 22 and 23. Sorry, and 21.

4 MS KOZINOS: Thank you. Yes.

5 MR GARNHAM: You were telling me why it was that Victoria --

6 you asked Kouao why it was Victoria would make such

7 things up, and what did she say?

8 MS KOZINOS: She was vague. She did not really give an

9 adequate explanation, apart from referring to her as

10 a silly girl, she made it up.

11 MR GARNHAM: And your reaction to that?

12 MS KOZINOS: I questioned her why Victoria would make such

13 a thing up and why has not she reported it earlier?

14 MR GARNHAM: And the response?

15 MS KOZINOS: Looking back, I can see from my write-up she

16 says that the reason she had not reported it was because

17 initially she had not believed it because she considered

18 Mr Manning to be a close friend.

19 MR GARNHAM: Let me help you a little because this is not

20 meant to be a memory test and I see you are struggling

21 to find your places. Will you go to the notes that you

22 say set out your recollection of this meeting.

23 Volume 6, page 144. Before I ask you for the details of

24 what these notes reveal Ms Kozinos, can I ask you about

25 when these notes came to be compiled?

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1 MS KOZINOS: On that day.

2 MR GARNHAM: You say they were compiled that same day,

3 2nd November?

4 MS KOZINOS: That is right.

5 MR GARNHAM: You appreciate that Lisa Arthurworrey says that

6 they were not completed until 25th February?

7 MS KOZINOS: So I have heard but if you look on the file on

8 5/11th she clearly states and refers backs to this

9 write-up.

10 MR GARNHAM: I am going to ask you about that in a moment.

11 These are completed on a form called an SS5 form and we

12 can see that numbering in the top right-hand corner.

13 MS KOZINOS: That is right.

14 MR GARNHAM: Why are they completed on those forms? Is that

15 where you always put interviews?

16 MS KOZINOS: Yes, because it is not a telephone

17 conversation, that is a lengthy ...

18 MR GARNHAM: Go to page 52. These are Lisa Arthurworrey's

19 notes for 5th November and I do not want to ask you

20 about 5th November for the moment, I am interested in

21 what she says about the 2nd. She says:

22 "Discussion with Duty Senior ..."

23 Who is you?

24 MS KOZINOS: That is right.

25 MR GARNHAM: "... and informed [I think she means I was

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1 informed] Marie-Therese had come to the department on

2 Tuesday 2nd November and retracted the allegations.

3 Said Anna had told her she had made everything up."

4 Then these words appear:

5 "See SS5 for more details."

6 That is right?

7 MS KOZINOS: Yes.

8 MR GARNHAM: You say, do you, that that is a reference to

9 the notes you completed that we were just looking at at

10 page 144?

11 MS KOZINOS: Yes it must be because she is talking about the

12 retraction. I assume it is because --

13 MR GARNHAM: She is indeed talking about the incident where

14 the allegation is retracted and your notes are indeed

15 ended on an SS5 form.

16 MS KOZINOS: That is right.

17 MR GARNHAM: So you say that must establish when she,

18 Lisa Arthurworrey, completed these notes on 5th November

19 she had sight of your notes that we have at page 144.

20 MS KOZINOS: Yes.

21 MR GARNHAM: Is that right?

22 MS KOZINOS: Yes, that is the assumption from reading that,

23 yes.

24 MR GARNHAM: That is certainly one possible explanation of

25 events and I want to make sure we look at all of the

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1 possibilities. The first is that the SS5, the note you

2 completed, had been completed prior to 5th November,

3 when Lisa Arthurworrey completed the notes we have on

4 that page.

5 MS KOZINOS: Yes.

6 MR GARNHAM: The second possibility is that

7 Lisa Arthurworrey did not complete her notes for

8 5th November until much much later, after you had

9 completed yours. That is a theoretical possibility, is

10 it not?

11 MS KOZINOS: Yes.

12 MR GARNHAM: The third possibility is that Lisa Arthurworrey

13 expected you to complete the SS5, because you had told

14 her that you had had this discussion.

15 MS KOZINOS: Possibly, but it could have been a short

16 conversation been recorded on a contact.

17 MR GARNHAM: And that what she was saying here was: "This is

18 what I was told by Rose Kozinos, looked to her to

19 complete the form SS5 to set out the details", even

20 though at that stage she did not know whether or not you

21 had done it at all.

22 MS KOZINOS: That is not what it says, though. It does not

23 say "outstanding write-up" or -- it says "see SS5 for

24 more details".

25 MR GARNHAM: So you say that makes it clear that that

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1 already existed by the time --

2 MS KOZINOS: To me it does but I am also clear when I wrote

3 the --

4 MR GARNHAM: Absolutely.

5 MS KOZINOS: So ...

6 MR GARNHAM: You say that is support for your direct

7 evidence you give the Inquiry now to the effect that you

8 completed those notes on 2nd November as they are dated.

9 MS KOZINOS: I know I did not complete them on -- at the day

10 she suggested, which is a considerable time after.

11 MR GARNHAM: When did you first learn of Lisa Arthurworrey's

12 suggestion that you only completed the notes of

13 2nd November in February 2000?

14 MS KOZINOS: I think it is from her statement to the

15 Inquiry.

16 MR GARNHAM: Not until then?

17 MS KOZINOS: Yes I think so, yes.

18 MR GARNHAM: I think it is right that in October of 2000 you

19 had sight of the draft Part 8 review prepared by or for

20 Haringey. Do you --

21 MS KOZINOS: I did not really.

22 MR GARNHAM: Do you remember being asked to comment on

23 a recommendation relating to that report that was faxed

24 to you from an address in the USA?

25 MS KOZINOS: Yes. My memo. You are talking about my one?

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1 MR GARNHAM: Yes.

2 MS KOZINOS: Yes.

3 MR GARNHAM: Your memo was not from the USA, was it?

4 MS KOZINOS: It was. I went abroad but this had happened --

5 MR GARNHAM: It was faxed to you in the USA.

6 MS KOZINOS: No, I was asked to respond to Carol Wilson by

7 a certain deadline but because I was away I sent it from

8 the USA.

9 MR GARNHAM: Sir, I am afraid I have lost my note of where

10 we find that. It may take us a few moments to locate

11 it. Let me press on until we get it in this way. Let

12 me understand how it came about. You were in the USA?

13 MS KOZINOS: And I faxed -- you are referring to the same

14 thing I am?

15 MR GARNHAM: Yes, I think we are.

16 MS KOZINOS: I think it was a response just to --

17 MR GARNHAM: Had you taken something with you then?

18 MS KOZINOS: Sorry, I do not know what -- I remember it was

19 something to do with the Part 8 and we had to respond by

20 a certain deadline. I think he asked for comments or --

21 sorry, I am not clear.

22 MR GARNHAM: Sir, this is entirely my fault because I have

23 not got this reference and we do need it if we are going

24 to pursue this properly. It might be sensible if we

25 take a five minute break while I locate it and people

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1 stretch their legs. I am sorry, sir, that I have not

2 got it to hand.

3 THE CHAIRMAN: That is fine, Mr Garnham. I fully

4 understand. We will adjourn for five minutes. 2.35,

5 ladies and gentlemen.

6 (2.30 pm)

7 (A short break)

8 (2.35 pm)

9 MR GARNHAM: It is volume 45A, please, page 137. Do you

10 remember writing this?

11 MS KOZINOS: Yes, vaguely. From America.

12 MR GARNHAM: This is the one you wrote in America?

13 MS KOZINOS: That is right.

14 MR GARNHAM: You had obviously got some Haringey Council

15 notepaper with you, had you?

16 MS KOZINOS: That is right, because I was asked to respond

17 at the time.

18 MR GARNHAM: You had taken with you an inquiry report? You

19 head it "Re Inquiry Report".

20 MS KOZINOS: Yes, because it is regarding that.

21 MR GARNHAM: What were you responding to?

22 MS KOZINOS: I assume it is the Part 8.

23 MR GARNHAM: Did you have a copy of the report in your hand

24 when you wrote this memo or were you responding to

25 a memo you had received from somebody else?

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1 MS KOZINOS: Yes and that we never had a copy of the Part 8.

2 MR GARNHAM: What were you responding to, then? A letter,

3 a memo, a scribbled note, a phone call, an e-mail?

4 MS KOZINOS: No. Sorry.

5 MR GARNHAM: You cannot remember?

6 MS KOZINOS: No.

7 MR GARNHAM: In any event something or other leads you to

8 write this:

9 "Following memorandum faxed and sent from the USA,

10 as I am currently abroad on annual leave."

11 I see. "The following memorandum" we should read

12 that as, should we?

13 MS KOZINOS: Yes.

14 MR GARNHAM: What you mean is:

15 "The following memorandum is faxed and sent from the

16 USA, as I am currently abroad on leave"?

17 MS KOZINOS: Yes, sorry.

18 MR GARNHAM: Not at all. I just thought you were replying

19 to something that had been sent from the USA but you are

20 in the USA. I understand.

21 MS KOZINOS: I am in the USA.

22 MR GARNHAM: It is obvious that you are correcting some

23 information.

24 MS KOZINOS: Yes.

25 MR GARNHAM: And you are correcting some information that is

177



1 contained in the report which you think might be but

2 possibly was not the Part 8?

3 MS KOZINOS: That is right.

4 MR GARNHAM: You said in note 1: "Office visit 1st November

5 1999", then I cannot quite read the next word. Is it

6 MSK? MTK?

7 MS KOZINOS: Yes, MSK.

8 MR GARNHAM: Marie-Therese Kouao?

9 THE CHAIRMAN: I think it must be Manning inquiry, is it?

10 MS KOZINOS: No --

11 MR GARNHAM: Ms K.

12 "Ms K was seen by myself alone in the office for ten

13 minutes. There was no social worker with me as the

14 report states and I met with her in my role as Duty

15 Senior Practitioner," yes?

16 MS KOZINOS: Yes.

17 MR GARNHAM: That is describing the office visit on

18 1st November?

19 MS KOZINOS: The one where she retracted the allegations,

20 yes.

21 MR GARNHAM: "Decision to convene second strategy meeting.

22 After the meeting [which we now know is the one where

23 she withdrew the allegation] I decided to convene the

24 strategy meeting."

25 So it is you deciding to convene it, is it?

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1 MS KOZINOS: Well I was advised. I advised her.

2 MR GARNHAM: I thought you had explained when we discussed

3 the time that it was fixed for in the future that you

4 were not convening it.

5 MS KOZINOS: No, I had recommended it.

6 MR GARNHAM: Yes. So "I decided to convene the strategy

7 meeting" is not quite right?

8 MS KOZINOS: No.

9 MR GARNHAM: "I updated the social worker on her return from

10 AL ..." annual leave?

11 MS KOZINOS: Yes. I assumed at the time she was on annual

12 leave. I did not know she was in training.

13 MR GARNHAM: "... who sought advice from me as to whether

14 strategy meeting necessary after allegations of sexual

15 abuse retracted."

16 MS KOZINOS: That is right.

17 MR GARNHAM: "Social worker agreed to go ahead with the

18 strategy meeting."

19 The social worker there is presumably a reference to

20 Lisa Arthurworrey.

21 MS KOZINOS: That is right.

22 MR GARNHAM: "I also discussed strategy meeting with

23 responsible Team Manager ..." that is Baptiste?

24 MS KOZINOS: That is right.

25 MR GARNHAM: "... who is reluctant for this to go ahead as

179



1 allegations retracted."

2 MS KOZINOS: That is right.

3 MR GARNHAM: "However, she agreed to strategy meeting and

4 asked me to chair."

5 MS KOZINOS: That is right.

6 MR GARNHAM: We do not see there any reference to making

7 what was quite a lengthy record of this on the SS5, do

8 we?

9 MS KOZINOS: No, I did not log it on the file. I did not

10 have the file.

11 MR GARNHAM: And it did not seem to you worthwhile saying in

12 this that you had made a note of this?

13 MS KOZINOS: No.

14 MR GARNHAM: Because, you see, you have troubled to tell

15 Carol Wilson that you updated the social worker on her

16 return, but you do not mention that you also completed

17 a lengthy memorandum on the subject.

18 MS KOZINOS: Yes, because this is into something specific,

19 where the -- I was trying to correct some information

20 for the Part 8 and I think the Part 8, at the time, had

21 said that both Lisa and the Team Manager were reluctant

22 to have the strategy meeting and I am trying to point

23 out here that it was not Lisa who was saying to cancel

24 it, she asked should it go ahead --

25 MR GARNHAM: The only person who was reluctant was

180



1 Carol Wilson.

2 MS KOZINOS: Yes, so I made that point because --

3 MR GARNHAM: Sorry, Carole Baptiste.

4 MS KOZINOS: Yes, Carole Baptiste. So that is what it was

5 in relation to. I was trying to clarify the confusion

6 because that was not accurate.

7 MR GARNHAM: And for those purposes you did not need to

8 mention that you had made a three or four page note of

9 that meeting?

10 MS KOZINOS: No, because we were not talking about that. It

11 is the allegation, the Part 8, that Lisa did not want it

12 to go ahead.

13 MR GARNHAM: Thank you for that. Let us go back to the real

14 events of November 1999. Once the sexual abuse

15 allegation had been withdrawn, the need for a strategy

16 meeting became all the more acute, did it not?

17 MS KOZINOS: That is right.

18 MR GARNHAM: Because now you were dealing with query sexual

19 abuse and query some form of abuse of Victoria which was

20 leading her to make and withdraw allegations for

21 somebody else's convenience, possibly.

22 MS KOZINOS: Yes, it was concerning.

23 MR GARNHAM: Did that not make the strategy meeting all the

24 more urgent given there were now two levels of concern?

25 MS KOZINOS: Possibly, but I discussed it with the Team

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1 Manager.

2 MR GARNHAM: I suspect I know what your answer to the next

3 question is going to be. Why then not bring the

4 strategy meeting forward? And you are going to say it

5 mattered to the Team Manager and the allocated social

6 worker, are you?

7 MS KOZINOS: No, because I challenged the Team Manager about

8 cancelling it, and no, I did not discuss about bringing

9 it forward.

10 MR GARNHAM: Why not?

11 MS KOZINOS: I do not know. I do not recollect at the time.

12 MR GARNHAM: How long did the meeting that you had with

13 Kouao, when the matter was retracted, last?

14 MS KOZINOS: It felt like ten minutes. It was done very

15 quickly whilst on Duty.

16 MR GARNHAM: You told the Monaghan investigation that it

17 lasted seven minutes. I can take you to that if

18 necessary. Sir, for the reference it is 46/135.602.

19 MS KOZINOS: It is not necessary. It is approximate.

20 MR GARNHAM: It was a relatively short period of time.

21 MS KOZINOS: It was a short period of time because I was on

22 Duty.

23 MR GARNHAM: The notes of the meeting cover three pages.

24 That would suggest a pretty comprehensive record of

25 a seven or ten minute meeting, would it not?

182



1 MS KOZINOS: Yes.

2 MR GARNHAM: But that was your purpose, presumably, to make

3 a comprehensive note of this worrying meeting?

4 MS KOZINOS: There was concerns from that meeting.

5 MR GARNHAM: You tell us that you updated Carole Baptiste

6 and Carole Baptiste asked whether in those

7 circumstances -- sorry, Lisa Arthurworrey asked whether

8 in those circumstances a strategy meeting was necessary.

9 MS KOZINOS: That is right.

10 MR GARNHAM: Carole Baptiste positively suggested it was

11 not?

12 MS KOZINOS: Went ahead when she heard my concerns.

13 MR GARNHAM: But when you expressed your concerns everybody

14 agreed it should happen.

15 MS KOZINOS: Yes, it was agreed to go ahead, it was not

16 agreed to cancel.

17 MR GARNHAM: Did Carole Baptiste advise to you talk to

18 Angella Mairs because Carole Baptiste was going to be

19 handing over responsibility to Mairs?

20 MS KOZINOS: No, and that is not my understanding she was

21 going to hand over responsibility.

22 MR GARNHAM: When did Baptiste cease to act as Team Manager.

23 MS KOZINOS: I do not know. My understanding was she was

24 going to stay to assist in the transition.

25 MR GARNHAM: Let us go on to 5th November. 5th November

183



1 Carole Baptiste asked you to do another favour. The

2 second favour of the week.

3 MS KOZINOS: Yes.

4 MR GARNHAM: Yes?

5 MS KOZINOS: Yes.

6 MR GARNHAM: This time it was to chair the strategy meeting?

7 MS KOZINOS: That is right.

8 MR GARNHAM: What time was that strategy meeting to take

9 place?

10 MS KOZINOS: I do not remember the time.

11 MR GARNHAM: Morning or afternoon?

12 MS KOZINOS: I have no recollection.

13 MR GARNHAM: How long before it was due to start did Carole

14 Baptiste make the request?

15 MS KOZINOS: It seemed very close to the time.

16 MR GARNHAM: Within a few minutes?

17 MS KOZINOS: Possibly.

18 MR GARNHAM: Did you read the case file?

19 MS KOZINOS: No, I did not.

20 MR GARNHAM: This is your fourth contact with this case, the

21 fourth time you have been involved with Victoria's case

22 we now know, and you have still never read the case

23 file.

24 MS KOZINOS: No, it was not standard practice.

25 MR GARNHAM: Given that you were about to chair a strategy

184



1 meeting into serious sex abuse allegations, was it not

2 essential that you read the case file?

3 MS KOZINOS: I did not, no.

4 MR GARNHAM: That was not my question. Was it not essential

5 that you did?

6 MS KOZINOS: No, we did not, because I would rely on the

7 information I had and what the social worker would bring

8 to the meeting and what I had also been told by Carole

9 that it was a Family Support case.

10 MR GARNHAM: Could you have volume 27A, please, page 26A.

11 Strategy meeting guidelines prepared by Miss Mairs.

12 MS KOZINOS: Yes.

13 MR GARNHAM: With which you have already told us you were

14 familiar. Item 15:

15 "If you are to attend a strategy meeting you are

16 expected to complete form as much as possible and read

17 the file and update yourself on the case, including work

18 other social workers have done."

19 MS KOZINOS: That is referring to the social worker.

20 MR GARNHAM: I see. So the social workers are expected to

21 read the file but the senior practitioner who is

22 chairing them was not?

23 MS KOZINOS: Because you rely on the information they bring.

24 MR GARNHAM: I see, thank you. Did you undertake any

25 preparation before you chaired this strategy meeting?

185



1 MS KOZINOS: No because I was told at short notice. No,

2 I did not.

3 MR GARNHAM: And that you say was standard practice at

4 Haringey: that the chairman or chairwoman would know

5 nothing about the matters that were going to be

6 discussed at the meeting?

7 MS KOZINOS: You could go into meetings cold, yes.

8 MR GARNHAM: You were expected to manage the business and

9 conduct the business in a sensible manner knowing

10 nothing about the case?

11 MS KOZINOS: Yes, on the information brought up at the

12 meeting, yes.

13 MR GARNHAM: So you would rely on what you were told and try

14 and direct matters in the light of that?

15 MS KOZINOS: That is right.

16 MR GARNHAM: How do you regard that now?

17 MS KOZINOS: As a poor practice. It is not the best way

18 to --

19 MR GARNHAM: Did you say it is poor or it is the best?

20 MS KOZINOS: No, it is not the best way to practice. In

21 hindsight it is not.

22 MR GARNHAM: It is put as an example of poor practice, is it

23 not?

24 MS KOZINOS: Yes, it could be interpreted as poor practice.

25 MR GARNHAM: Because it would be common sense as well as

186



1 good practice for a chair of a strategy meeting to know

2 something about the case they were looking at.

3 MS KOZINOS: Yes. Well in this case I was told it was

4 Family Support from Carole. That is as much

5 information.

6 MR GARNHAM: Well, it had been Family Support. It was

7 plainly more than that from the time you got to deal

8 with it on 5th November, was it not?

9 MS KOZINOS: Oh yes, definitely.

10 MR GARNHAM: I am trying to get a picture of what the usual

11 practice was. Would you say normally you would not read

12 the file before chairing a strategy meeting, that you

13 would never read the file, or that you would

14 occasionally not read the file?

15 MS KOZINOS: It depends but it was certainly quite common to

16 go in cold, or you would be asked by a colleague at the

17 last minute to cover because it was just a busy office.

18 MR GARNHAM: You chair many strategy meetings you have told

19 us.

20 MS KOZINOS: Yes.

21 MR GARNHAM: And because you had not had occasion to read

22 the file, you made no connection when you started the

23 meeting between this case you were about to chair and

24 the one you chaired back in July?

25 MS KOZINOS: That is right.

187



1 MR GARNHAM: It is inevitable that if you had read the file

2 at any stage you would have become aware of your

3 previous involvement, would you not?

4 MS KOZINOS: Absolutely.

5 MR GARNHAM: Midway through this strategy meeting you

6 twigged that you had been involved in this case

7 previously?

8 MS KOZINOS: That is right.

9 MR GARNHAM: Nobody had told you that?

10 MS KOZINOS: No.

11 MR GARNHAM: Nobody had said, "But you remember this case,

12 you chaired it back in July"?

13 MS KOZINOS: No.

14 MR GARNHAM: When you suddenly remembered that that is what

15 happened, did you ask to see the file from that earlier

16 strategy meeting?

17 MS KOZINOS: No, I did not, but relied solely on the two

18 officers there who were the allocated workers.

19 MR GARNHAM: Had not the way things gone so far demonstrated

20 that you could not safely rely on it?

21 MS KOZINOS: But I did not know that then. That is in

22 hindsight what we know now.

23 MR GARNHAM: No. You had so far got halfway through the

24 meeting and nobody had mentioned to you that this had

25 been a case where there had been a previous strategy

188



1 meeting or a previous strategy meeting which in fact you

2 chaired.

3 MS KOZINOS: Yes, that is right.

4 MR GARNHAM: Did that not demonstrate you were not getting

5 a proper report from the social workers of what was

6 happening?

7 MS KOZINOS: Not a proper report because when I asked them

8 about it they felt it had been investigated and there

9 were no concerns. I do not know if that is the reason

10 why they had not raised it.

11 MR GARNHAM: And you regarded that as satisfactory, did you,

12 as an explanation?

13 MS KOZINOS: Well at the time of it I did rely on what they

14 told me, yes.

15 MR GARNHAM: And the fact that they had not mentioned it to

16 you, for whatever reason, did not prompt you to say,

17 "Well, I must see that file"?

18 MS KOZINOS: No it did not.

19 MR GARNHAM: Should it have done, do you think, looking

20 back?

21 MS KOZINOS: With hindsight, yes, but at the time I had

22 two -- a police officer and a social worker who had had

23 the case allocated and were joint working it in terms of

24 the previous investigation, who were giving feedback

25 regarding their case.

189



1 MR GARNHAM: Where is the file kept? Where was it kept?

2 MS KOZINOS: It would have been upstairs in our room.

3 MR GARNHAM: So it could have been recovered in a couple of

4 minutes?

5 MS KOZINOS: Five minutes you would have had to go up, yes.

6 We were in the back room.

7 MR GARNHAM: But you decided that was not necessary because

8 you could rely on what you were being told by the people

9 who were there?

10 MS KOZINOS: I did not consider it because I had no reason

11 not to trust the two workers on the information they

12 were giving me.

13 MR GARNHAM: Are you sure it is the case that they did not

14 tell you that there had been a previous strategy

15 meeting?

16 MS KOZINOS: Yes, definitely.

17 MR GARNHAM: Would it not have been worthwhile to adjourn

18 the strategy meeting long enough to get the file so

19 everybody could see it?

20 MS KOZINOS: In hindsight, yes, that would have been.

21 MR GARNHAM: So that you could check that the steps that you

22 had wanted to take place on the previous occasion had

23 taken place?

24 MS KOZINOS: Yes. But at the time I relied on the

25 information they gave me.

190



1 MR GARNHAM: Was it not your duty to review Victoria's case

2 properly, either prior to chairing this case conference

3 or at the very least before you concluded the case

4 conference?

5 MS KOZINOS: Strategy meeting.

6 MR GARNHAM: So sorry, strategy meeting.

7 MS KOZINOS: Sorry, can you ask the question again, sorry?

8 MR GARNHAM: Was it not your duty to review Victoria's case

9 file properly before you chaired the strategy meeting or

10 at least before the strategy meeting was finished?

11 MS KOZINOS: I did not see it like that at the time, no.

12 The case should have been reviewed all along through the

13 supervision but I did not check the information, no.

14 MR GARNHAM: Once you had called the earlier meeting, was it

15 right that Arthurworrey and Jones spoke about their

16 earlier involvement?

17 MS KOZINOS: They did.

18 MR GARNHAM: And you say they told you that it was a Family

19 Support case only?

20 MS KOZINOS: No, that they had fully investigated -- when

21 I remembered the previous meeting they said that the

22 allegations had been fully investigated and that there

23 were no concerns, that they had also discussed it with

24 a child protection advisor and they had medical records

25 that showed it was accidental injuries; the matter had

191



1 been closed, so to speak, but it was open as a Family

2 Support case.

3 MR GARNHAM: You say that they told you they had discussed

4 it with a child protection advisor.

5 MS KOZINOS: They mentioned child -- and the doctors and

6 a hospital report.

7 MR GARNHAM: Did they say who the child protection advisor

8 was they discussed it with?

9 MS KOZINOS: No.

10 MR GARNHAM: I am sure it is just because I have missed it

11 Ms Kozinos, but where do you say in your statement they

12 say they discussed it with a child protection advisor?

13 MS KOZINOS: I do not, but it was said.

14 MR GARNHAM: You do not mention that in your statement but

15 you now recollect it?

16 MS KOZINOS: Yes. I think I have mentioned it somewhere.

17 MR GARNHAM: Well, your counsel will draw our attention to

18 it if we have both missed it.

19 When they told you that the case you now recollected

20 had been fully investigated, what evidence did they give

21 to you satisfy you that that was the case?

22 MS KOZINOS: They had just said they referred to the medical

23 report which had been fully investigated a while back.

24 MR GARNHAM: Did they say what medical investigation had

25 also taken place?

192



1 MS KOZINOS: Just that it showed that it was accidental

2 injury. I had no reason to disbelieve either of them or

3 not take what they had said at face value, at the time.

4 MR GARNHAM: How did it come about that some of your

5 recommendations in the second strategy meeting are

6 identical to the ones in the first strategy meeting?

7 MS KOZINOS: It is probably the way I work.

8 MR GARNHAM: You told them again to contact Immigration?

9 MS KOZINOS: Yes.

10 MR GARNHAM: Did they not tell you that they had already

11 done that?

12 MS KOZINOS: No.

13 MR GARNHAM: You had instructed/advised the social worker

14 who is allocated to the case in July to contact

15 Immigration?

16 MS KOZINOS: Yes.

17 MR GARNHAM: And they told you they had done all of the

18 things you had asked them to do?

19 MS KOZINOS: No, they said a Section 47 had been completed

20 and there was no concerns.

21 MR GARNHAM: So you did not enquire whether they had

22 completed the whole of the 18 tasks that had been set

23 them last time?

24 MS KOZINOS: No.

25 MR GARNHAM: You told them to complete checks in France?

193



1 MS KOZINOS: Yes.

2 MR GARNHAM: You had asked them to do that last time?

3 MS KOZINOS: Yes, but I think my concerns at this time --

4 I think it is for different reasons this time.

5 MR GARNHAM: Did you understand that they had completed the

6 checks in France on the previous occasion?

7 MS KOZINOS: No, and I would not have recollected the

8 previous suggestions.

9 MR GARNHAM: Since you did not have access to the file you

10 could not see it?

11 MS KOZINOS: That is right.

12 MR GARNHAM: And you had no more assurance from them than

13 that there was nothing more to worry about from the

14 previous strategy meeting, is that what you are saying?

15 MS KOZINOS: No, they did not refer -- they said that the

16 Section 47 had been fully completed and that they had no

17 further concerns.

18 MR GARNHAM: Did you ask what that Section 47 had involved

19 last time, so as to make sure that you were not

20 repeating work unnecessarily?

21 MS KOZINOS: No.

22 MR GARNHAM: Why not?

23 MS KOZINOS: Do not know. Did not occur to me. No.

24 MR GARNHAM: Because it might just be, might it not, that

25 some of the investigations that had been successfully

194



1 completed last time might not need to be done again?

2 MS KOZINOS: Possibly, but it is a different referral, it is

3 a new allocation. It still had to be completed fully.

4 MR GARNHAM: But immigration checks, for example, if checks

5 had been carried out on the immigration status of Kouao

6 and Victoria, you would not have needed to do them

7 again.

8 MS KOZINOS: It was more in links as to whether there were

9 concerns in France about her or the children.

10 MR GARNHAM: I do not understand how that helps. Was it not

11 worth saying, "What did I ask you to do last time? Oh,

12 I asked you to check immigration. Then I do not need to

13 ask to you do that again"?

14 MS KOZINOS: Yes, looking back at it, yes, but I did not at

15 the time.

16 MR GARNHAM: Is that because the advice you were giving on

17 this occasion was a matter simply of you listing what

18 was normally the steps that ought to be taken in such

19 a case?

20 MS KOZINOS: It was -- it was new investigation, a new

21 referral, so ...

22 MR GARNHAM: My point is really: was it not just a matter of

23 common sense to look back through the previous file, to

24 ensure that nothing had been forgotten and to find out

25 what had been done?

195



1 MS KOZINOS: But I trusted, at the time, the two officers

2 who were there, who I would have had no reason to be

3 concerned that they had not.

4 MR GARNHAM: Sir, there is no way I am going to finish this

5 witness this afternoon. We are supposed to rise at

6 3 o'clock and that is a fairly convenient moment for me,

7 if it is for you.

8 THE CHAIRMAN: I am grateful to you, Mr Garnham. Thank you

9 very much.

10 Ms Kozinos, you remain under oath and you have to

11 come back for 10 o'clock on Monday morning. I would

12 normally have said you are not allowed to discuss your

13 evidence with anyone but because of the late material we

14 received this morning you recall I made an exception and

15 you can discuss that with your advocate Mr Wilkinson at

16 your convenience.

17 Ladies and gentlemen we will adjourn until

18 10 o'clock on Monday morning. Thank you very much.

19 (3.00 pm )

20 (Hearing adjourned until 10.00 am

21 on Monday, 3rd November 2001)

22

23

24

25