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Archived Transcript for 9 October 2001: Pages
1 to 50
1
1 Tuesday, 9th October 2001
2 (10.00 am)
3 THE CHAIRMAN: Mr Garnham, just before you begin, I hope
4 this will help interested parties particularly if I say
5 that on Friday, 19th October, which is a week on Friday,
6 which is just before there is a break in the public
7 hearings, I propose that we should begin on that morning
8 at 9.00 am and finish at 1.00 pm, and similarly on
9 November 16th, we begin at 9.00 am on the Friday and
10 finish at 1.00 pm. If that causes any difficulties, do
11 please let me know, but that is what I intend.
12 Mr Garnham?
13 MR GARNHAM: Thank you, sir. Before we resume with
14 Mr Armstrong, just two or three matters of housekeeping.
15 First of all, sir, we do not propose calling
16 Dr Ajayi-Obe today. The list for today looked fairly
17 full, and I will be a little longer with Mr Armstrong
18 this morning, and it seemed to us likely that Dr Obe
19 would find herself waiting all day, with the substantial
20 risk of not being reached by the end of the day, so with
21 her consent, we have retimetabled her for first thing on
22 Thursday morning.
23 Secondly, sir, the daily list for witnesses for next
24 week should have been circulated yesterday, and
25 I apologise for the omission. It will be in people's

2
1 pigeonholes by lunchtime today.
2 Thirdly, sir, the daily list for the week commencing
3 5th November will be circulated to interested parties,
4 and we hope put on the website, before the end of this
5 week.
6 THE CHAIRMAN: Thank you, Mr Garnham.
7 MR EDWARD ARMSTRONG (continued)
8 MR GARNHAM: Mr Armstrong, good morning.
9 MR ARMSTRONG: Good morning.
10 MR GARNHAM: We ended yesterday afternoon with your telling
11 us something about the instructions you had received
12 from one of your managers about closing files.
13 MR ARMSTRONG: That is correct.
14 MR GARNHAM: And I want to start today by exploring that
15 a little more. You were kind enough to indicate that
16 you would give some more thought overnight to who it was
17 who gave you that instruction. You thought it might be
18 Cecelia Hitchen, Sylvan Hunt or someone else, and
19 I wondered if you have given it some more thought.
20 MR ARMSTRONG: I have given it some more thought, and
21 I cannot remember who gave the instruction in 1999, but
22 the instruction in 1999 was from senior management for
23 us to close cases, and I remember coming back from my
24 annual leave at the end of August, and within the first
25 week of September 1999 I closed 190 cases.

3
1 The same instruction was again given in 2000 by
2 Cecelia Hitchen, to close cases, and we did same --
3 followed the same process.
4 MR GARNHAM: And was that second instruction in similar
5 circumstances, where you were being instructed to close
6 files which would not ordinarily be fit for closure?
7 MR ARMSTRONG: That is correct.
8 MR GARNHAM: You said yesterday that there were two
9 candidates for managers who might have given you those
10 instructions, the two people I have mentioned. You
11 having thought about it overnight, does that remain your
12 view, that it was either Sylvan Hunt or Cecelia Hitchen?
13 MR ARMSTRONG: It is my view that in 2000, it was
14 Cecelia Hitchen.
15 MR GARNHAM: And in 1999?
16 MR ARMSTRONG: I cannot remember who was the person that
17 issued the instruction in 1999, but all I would say is
18 it was from senior management.
19 MR GARNHAM: I understand that, but yesterday you thought,
20 in respect of the 1999 instruction, it was one of those
21 two managers. Are you still of the view that it is one
22 of those two, or should we cast our net wider to
23 discover who it was?
24 MR ARMSTRONG: I am saying at this present time that
25 I cannot remember the name of the person that gave that

4
1 instruction.
2 MR GARNHAM: The inspection which you say these steps were
3 to be taken in preparation for was the inspection of
4 May 2000, was it not?
5 MR ARMSTRONG: It could have been.
6 MR GARNHAM: Is there any other inspection that it might
7 have been?
8 MR ARMSTRONG: I know the instruction for late 2000 was to
9 do with SSI coming at either the end of 2000 or in 2001.
10 MR GARNHAM: Right, but the detail you gave us yesterday,
11 about you being instructed to close files in preparation
12 for an SSI visit --
13 MR ARMSTRONG: That is correct.
14 MR GARNHAM: -- that was the visit, was it not, that
15 occurred in May 2000?
16 MR ARMSTRONG: I cannot remember.
17 MR GARNHAM: Is there anything else it might have been? You
18 were being instructed to close files in order to make
19 things look better for the SSI inspection.
20 MR ARMSTRONG: That was one of the reasons, yes.
21 MR GARNHAM: Is there any other SSI inspection other than
22 the one in May 2000 that it might have been?
23 MR ARMSTRONG: I cannot remember.
24 MR GARNHAM: Because it is right, is it not, that neither
25 Sylvan Hunt nor Cecelia Hitchen were your line managers

5
1 at that time, in 2000, in the period before the May
2 inspection?
3 MR ARMSTRONG: I am not quite sure when my line manager
4 David Charlett left, but senior managers give us
5 instructions regarding --
6 MR GARNHAM: Whether or not they are your line manager?
7 MR ARMSTRONG: Yes, they do.
8 MR GARNHAM: For the record though David Charlett was your
9 line manager from July 1999?
10 MR ARMSTRONG: David Charlett was my line manager shortly
11 after John Skinner left the department.
12 MR GARNHAM: And when was that?
13 MR ARMSTRONG: I cannot remember the exact time and date.
14 MR GARNHAM: Cases that are held on duty awaiting closure
15 would be entirely properly closed once somebody turned
16 their mind to it, would they not? If they were simply
17 being held awaiting closure, once you got round to
18 closing them, that would be a proper thing to do?
19 MR ARMSTRONG: Providing the cases are summarised for
20 closure, yes.
21 MR GARNHAM: And where there is no further child in need
22 work that had to be done on a file, closure would be
23 proper once the tasks indicated have been completed?
24 MR ARMSTRONG: If the tasks are completed, yes, the case
25 will be closed, or if the tasks are completed within the

6
1 duty team and the case needs to be transferred to the
2 long-term team, that would be the process of
3 transferring them out.
4 MR GARNHAM: But you are saying, are you, that the closures
5 you were instructed to carry out were not closures in
6 those circumstances but closures of files that ought to
7 have been left open?
8 MR ARMSTRONG: Some of them should have been left open, yes.
9 MR GARNHAM: No inappropriate closures were found by the
10 SSI, were they?
11 MR ARMSTRONG: I have not --
12 MR GARNHAM: That you are aware of?
13 MR ARMSTRONG: I have not got that information to hand.
14 MR GARNHAM: It is likely, is it not, that had there been
15 inappropriate closures of the sort you have described,
16 they would have been picked up in an SSI inspection?
17 MR ARMSTRONG: Not necessarily, because at one stage, we
18 were told that the cases that were going to be presented
19 to the SSI were cases that were chosen by management.
20 MR GARNHAM: Can you tell us who it was who carried out
21 these closures? You say you did; did anybody else?
22 MR ARMSTRONG: Myself and my staff.
23 MR GARNHAM: Namely?
24 MR ARMSTRONG: My staff would be Monica Bridgeman or
25 Pauline Phillips.

7
1 MR GARNHAM: Would those two women have appreciated that
2 they were closing files on the instruction of this
3 unidentified manager, rather than closing them in the
4 ordinary course?
5 MR ARMSTRONG: They would have been aware that
6 an instruction was given to close the files.
7 MR GARNHAM: So we can ask them and they will be able to
8 tell us the same sort of thing?
9 MR ARMSTRONG: They should be able to.
10 MR GARNHAM: Do you know how many were closed in this
11 inappropriate way?
12 MR ARMSTRONG: I could not tell you how many were closed in
13 an inappropriate way, but what I can say is that in the
14 first week in September 1999, I came back from annual
15 leave and closed 190 cases.
16 MR GARNHAM: And how many would you have expected to close
17 in the ordinary course, absent that instruction?
18 MR ARMSTRONG: It is hard for me to say now.
19 MR GARNHAM: You are making relatively serious allegations,
20 Mr Armstrong. Can I press you a little, please? Can
21 you give us some idea of how many extra files you were
22 closing because of this instruction? Is it one or two
23 or dozens or hundreds?
24 MR ARMSTRONG: It would have been dozens.
25 MR GARNHAM: That is you, and you say that your senior

8
1 social workers also carried out such closures?
2 MR ARMSTRONG: They would have assessed the information on
3 the file, and closed it if -- as I said yesterday, they
4 were also given the instruction that if there was no
5 contact within two weeks of the last contact, then we
6 should close.
7 MR GARNHAM: But the dozens you are talking about are the
8 ones you would have personally closed; they would have
9 closed others on top of that?
10 MR ARMSTRONG: No, what I am saying is collectively as
11 a team we closed 190 cases.
12 MR GARNHAM: But again, I am asking you about the ones that
13 were inappropriately closed, and you said there were
14 dozens of them. Is that an accurate description of the
15 totality of the closures?
16 MR ARMSTRONG: I cannot actually give you a figure.
17 MR GARNHAM: You were being instructed to do something that
18 was plainly wrong, were you not?
19 MR ARMSTRONG: Yes, it was.
20 MR GARNHAM: Contrary to all your professional training and
21 your professional standards.
22 MR ARMSTRONG: Yes, it was, but it was an instruction from
23 management.
24 MR GARNHAM: Did you protest?
25 MR ARMSTRONG: I protested about some cases.

9
1 MR GARNHAM: To whom did you direct those protests?
2 MR ARMSTRONG: To senior management.
3 MR GARNHAM: Who is that?
4 MR ARMSTRONG: I protested about one case that I can
5 remember of, as I said yesterday, an asylum seeker.
6 MR GARNHAM: Who did you protest to?
7 MR ARMSTRONG: I protested to Cecelia Hitchen.
8 MR GARNHAM: Thank you. Did you protest about the
9 instruction in general?
10 MR ARMSTRONG: No, because the climate was such that once
11 you were given an instruction, you just go ahead with
12 it.
13 MR GARNHAM: With the greatest of respect, Mr Armstrong,
14 that does seem extraordinary. Here you are, a manager,
15 being instructed to do something that you agree is
16 plainly wrong. Even if you had to do it because you
17 were instructed to do so, would you not have lodged
18 a fairly formal protest about it, given that it was
19 contrary to your professional ethics?
20 MR ARMSTRONG: I might have done, but at that time, when the
21 instructions were actually given, they were carried out,
22 and there were a number of instructions given on other
23 things that we have actually pursued.
24 MR GARNHAM: Why did you not protest? Was that not your
25 duty?

10
1 MR ARMSTRONG: It may have been my duty, but I did not see,
2 in the climate, that I had the right to protest when the
3 instruction was coming from senior management.
4 MR GARNHAM: Can I just ask you one question about the
5 missing files you told us about yesterday? Was it
6 a case of these files disappearing completely, or were
7 they simply misplaced?
8 MR ARMSTRONG: Some files were misplaced and some were never
9 found.
10 MR GARNHAM: So in respect of some, they appeared to have
11 disappeared off the face of the earth, or at least the
12 face of your office?
13 MR ARMSTRONG: Yes.
14 MR GARNHAM: What did you see to be your responsibility in
15 all the administrative difficulties you described
16 yesterday?
17 MR ARMSTRONG: My responsibility was to alert senior
18 management to what was happening, the chaos that was
19 taking place within the duty team, and for them to
20 rectify the situation.
21 MR GARNHAM: Was it not part of your job to rectify it as
22 well, so far as it was in your power?
23 MR ARMSTRONG: No, it was never in my power, because after
24 the restructuring, the responsibility for the
25 administrative staff was taken away from team managers.

11
1 MR GARNHAM: When was that?
2 MR ARMSTRONG: After the restructuring -- when the services
3 were centralised, and I cannot remember --
4 MR GARNHAM: Can you give us a year?
5 MR ARMSTRONG: It could have been 1995.
6 MR GARNHAM: Thank you. Can I turn now to the circumstances
7 of Victoria's case, and in your statement it is
8 paragraph 31. You might like to have that in front of
9 you. You say:
10 "A referral was received by one of the social
11 workers by telephone on 21st June 1999 concerning
12 a child named 'Anna' with an address of 8 Nicoll Road,
13 London (room 10), Harlesden ... and her family who were
14 residing in temporary accommodation in the London
15 Borough of Brent. The child was wetting herself."
16 That is right, is it?
17 MR ARMSTRONG: That is correct.
18 MR GARNHAM: You say you cannot identify who the social
19 worker was.
20 MR ARMSTRONG: No, I cannot at this present time.
21 MR GARNHAM: Was he or she a member of your team?
22 MR ARMSTRONG: Yes, they were.
23 MR GARNHAM: But you have no recollection as to their
24 identity?
25 MR ARMSTRONG: At this present time, I cannot remember who

12
1 the social worker was.
2 MR GARNHAM: Where was the call received from?
3 MR ARMSTRONG: The call was received on the duty desk by one
4 of the social workers.
5 MR GARNHAM: From where?
6 MR ARMSTRONG: I cannot remember at this present time where
7 it was received from, but I know it was received by one
8 of the duty workers.
9 MR GARNHAM: You were told the child's first name, and the
10 address, and that they were residing in temporary
11 accommodation. Were you told the child's age?
12 MR ARMSTRONG: I think we were told the child was about
13 eight years old.
14 MR GARNHAM: You were told the child was wetting herself;
15 that was the essence of the concern, was it?
16 MR ARMSTRONG: The essence of the concern from the
17 information on the referral was that the child was
18 wetting herself and they were residing in temporary
19 accommodation.
20 (10.15 am)
21 MR GARNHAM: Was there anything more specific about those
22 worries about the temporary accommodation?
23 MR ARMSTRONG: No, there was not.
24 MR GARNHAM: You say that the details were recorded by this
25 unidentified social worker, recorded in the Council's

13
1 records, but that that part of the file is missing, is
2 that right?
3 MR ARMSTRONG: All the case papers for the Intake Duty Team
4 are missing. I do not know how they are missing, but
5 they are missing.
6 MR GARNHAM: How do you know then that these details were
7 reported?
8 MR ARMSTRONG: Because I had access to those papers.
9 MR GARNHAM: At the time?
10 MR ARMSTRONG: Yes.
11 MR GARNHAM: So that they went missing since that occasion
12 when you looked at them originally?
13 MR ARMSTRONG: Well, I do not know when they went missing.
14 All I can remember is that the papers were actually
15 passed to the -- when the match was made by the admin
16 officer, and I think the next time that the papers came
17 back to us was when the case was retransferred back into
18 my duty team by the Child Protection Team.
19 MR GARNHAM: And at that stage, was the file complete?
20 MR ARMSTRONG: The file was complete.
21 MR GARNHAM: So it is some time after that that these pages
22 have gone missing?
23 MR ARMSTRONG: That is correct.
24 MR GARNHAM: Will you have a look at volume 5, please,
25 page 3? Tell us what that is, please, Mr Armstrong.

14
1 MR ARMSTRONG: This is what we call the pink copy, and this
2 is a form that is given -- it is attached to each
3 referral that comes into the department, and as you can
4 see, in action 1, it is written "please log in and
5 check", and that is for an administrative purpose, for
6 the admin to check, to see if the case is known
7 et cetera, and any other background information.
8 MR GARNHAM: And this form was completed by you?
9 MR ARMSTRONG: This form was completed by me.
10 MR GARNHAM: Is all of the handwriting on that page yours?
11 MR ARMSTRONG: No, it is not.
12 MR GARNHAM: What is yours and what is someone else's?
13 MR ARMSTRONG: The information about the child, the address
14 and the log-in are mine, and the name "Monica" on the
15 top and "183/6".
16 MR GARNHAM: That is all yours?
17 MR ARMSTRONG: That is mine.
18 MR GARNHAM: What did the "183/6 Monica" mean?
19 MR ARMSTRONG: 183/6 is, at the beginning of every month we
20 start from number 1 to log in each referral that comes
21 into the department, and that is an indication that it
22 is 183/6 when that was logged in.
23 MR GARNHAM: So it is the 183rd log-in in the month of June?
24 MR ARMSTRONG: That is correct.
25 MR GARNHAM: The words, "Home visit, Lori, 3pm, Wednesday,

15
1 14 July 1999". They are not yours?
2 MR ARMSTRONG: "Home visit" is mine, sorry.
3 MR GARNHAM: "Home visit" is yours.
4 MR ARMSTRONG: Yes. That is my writing.
5 MR GARNHAM: "Lori, 3pm, Wednesday, 14 July". Is that
6 yours?
7 MR ARMSTRONG: That is not my writing.
8 MR GARNHAM: To the casual observer, it looks fairly
9 similar, but that is not your writing?
10 MR ARMSTRONG: I can assure you it is not my writing.
11 MR GARNHAM: Do you know whose it is?
12 MR ARMSTRONG: I cannot say.
13 MR GARNHAM: Over the page to page 4, the only entry on that
14 page is a date by the words "Date of decision by duty
15 manager 21/6/99"; is that your handwriting?
16 MR ARMSTRONG: That is correct.
17 MR GARNHAM: And then a signature of the duty manager; is
18 that your signature?
19 MR ARMSTRONG: That is one of my signatures.
20 MR GARNHAM: You have a number of signatures, do you?
21 MR ARMSTRONG: There was a reason for my signature changing.
22 In 1999, we had employed an agency working to do some
23 work for us, and she actually copied my signature and
24 tried to defraud the department.
25 MR GARNHAM: I see. So you adopted a new signature?

16
1 MR ARMSTRONG: Yes.
2 MR GARNHAM: And that is it?
3 MR ARMSTRONG: Yes.
4 MR GARNHAM: What ought we to be able to find on these files
5 if they were complete? What is missing?
6 MR ARMSTRONG: What is missing would be my action sheet,
7 manager's action sheet, outlining the tasks that I have
8 asked to be completed on the case.
9 MR GARNHAM: Let me take it one by one. That document
10 first; that is a document that you complete on the same
11 day as you complete this sheet?
12 MR ARMSTRONG: Yes, I do.
13 MR GARNHAM: But it is a separate sheet of paper, is it, on
14 a preprinted form?
15 MR ARMSTRONG: Yes, a preprinted form that is separate from
16 the D5.
17 MR GARNHAM: That you fill?
18 MR ARMSTRONG: Yes.
19 MR GARNHAM: I interrupted you, I am sorry. What is the
20 next document?
21 MR ARMSTRONG: The next document should be all the
22 recordings of the social workers who have worked on the
23 case, including the two unannounced visits et cetera,
24 and any other work that was done by any worker or
25 seniors during that period of time.

17
1 MR GARNHAM: Was there any other work done other than the
2 two unannounced visits to which you have just referred?
3 MR ARMSTRONG: Well, there were two unannounced visits,
4 there were also faxes to the London Borough of Ealing,
5 my conversations with Mr Godfrey, my recordings, as well
6 as contact with Housing, General Medical Practitioners
7 Board and Ealing; all of that should have been in that
8 file.
9 MR GARNHAM: And all of that was originally in the file and
10 has gone missing since the matter was returned to you in
11 July?
12 MR ARMSTRONG: Well, it has gone missing and I cannot say
13 when it went missing.
14 MR GARNHAM: But it is some time between July 1999 and
15 today?
16 MR ARMSTRONG: Yes.
17 MR GARNHAM: You say that the details were passed to an
18 administrative worker and were logged?
19 MR ARMSTRONG: Yes.
20 MR GARNHAM: When was it passed to an administrative worker?
21 MR ARMSTRONG: As far as I can remember, on 21st June, once
22 this was completed and attached to the referral that
23 I received on 21st June, it all goes to the admin
24 section to be logged in.
25 MR GARNHAM: I am sorry, you received a referral on

18
1 21st June?
2 MR ARMSTRONG: Yes, I did.
3 MR GARNHAM: I ought to have asked you about that; was that
4 a document --
5 MR ARMSTRONG: No, that is a telephone referral.
6 MR GARNHAM: Does the recipient of the telephone referral
7 create a document, or is that your document that we are
8 looking at there?
9 MR ARMSTRONG: No, the referral -- when you get a telephone
10 referral, it comes over and you then enter it on
11 a double -- I would say a double A4 sized referral,
12 which is separated with a pink and a blue.
13 MR GARNHAM: So has that also gone missing?
14 MR ARMSTRONG: That is missing as well.
15 MR GARNHAM: So the details were passed to the
16 administrative worker and were logged?
17 MR ARMSTRONG: It should have been logged.
18 MR GARNHAM: Do you know whether it was?
19 MR ARMSTRONG: We would pass them to be logged and they come
20 back to the duty team, so we do not actually check to
21 see if they are logged, but we assume they are logged,
22 once it is returned to the main duty team.
23 MR GARNHAM: Where are they logged?
24 MR ARMSTRONG: It is normally logged by the admin.
25 MR GARNHAM: No, where; on what are they logged?

19
1 MR ARMSTRONG: On the computer.
2 MR GARNHAM: Do you know when it was logged, or when it
3 should have been logged?
4 MR ARMSTRONG: No, I cannot answer that question.
5 MR GARNHAM: When should it have been, then?
6 MR ARMSTRONG: It should have been logged on the 21st.
7 MR GARNHAM: Is there any evidence that we have now that
8 shows that it was logged?
9 MR ARMSTRONG: There is no evidence present to show that the
10 referral that I am talking about was logged.
11 MR GARNHAM: Paragraph 48 of your statement, Mr Armstrong;
12 you say there is absolutely no truth in any suggestion
13 that the referral you record at 5/03 and 5/04 refers to
14 a referral dated 18th June.
15 MR ARMSTRONG: Could you repeat that, please?
16 MR GARNHAM: In paragraph 48, you say that there is
17 absolutely no truth in any suggestion that the referral
18 recorded on this document we have just looked at, 5/03
19 and 5/04, is a referral made on 18th June.
20 MR ARMSTRONG: What I am saying is that the referral that
21 I logged, with this D5, is not here. That is what I am
22 saying.
23 MR GARNHAM: But you are also saying, I think, looking again
24 at page 3 in volume 5, you are saying that that is not
25 a reference to a referral received by your team on

20
1 18th June.
2 MR ARMSTRONG: Yes, it is not a reference to the referral
3 that I received on the 21st, because as I said, the
4 referral is missing, it is not here.
5 MR GARNHAM: This document at page 3 however, you say, is
6 one of the documents created as a result of the referral
7 on 21st June.
8 MR ARMSTRONG: That is correct.
9 MR GARNHAM: It is not, you also say, anything to do with
10 a referral received on 18th June.
11 MR ARMSTRONG: That is correct.
12 MR GARNHAM: You are aware, I think, that it is said that
13 a referral was made to your team on 18th June by
14 Samantha Hunt of the One Stop Shop.
15 MR ARMSTRONG: It was said that referral was made on
16 18th June, but what I am saying is I have never received
17 that referral of 18th June.
18 MR GARNHAM: I understand that, I am going to ask you
19 a little about that, because you know that some people,
20 including Miss Hunt, say they made such a referral on
21 18th June.
22 MR ARMSTRONG: She said she did, yes.
23 MR GARNHAM: Go to page 6, please, in volume 5. She says
24 this is the referral she made on 18th June; what do you
25 say that is?

21
1 MR ARMSTRONG: She said that is the referral she made on
2 18th June. I cannot dispute that. It is a referral
3 that I never received, that is what I am saying.
4 MR GARNHAM: Are you able to say whether or not it was
5 received in your office?
6 MR ARMSTRONG: I am able to say it was never received in my
7 office.
8 MR GARNHAM: How are you able to be sure about that?
9 MR ARMSTRONG: Because I have never seen it.
10 MR GARNHAM: You described yesterday the chaotic system of
11 receiving faxes in your office.
12 MR ARMSTRONG: That is correct.
13 MR GARNHAM: With faxes spilling out on the floor and nobody
14 assigned to distribute them. How do you know that this
15 referral was not one of those that arrived by that fax
16 machine and spilled out on to the floor with the others?
17 MR ARMSTRONG: I do not know -- it could be a referral that
18 was there, on whichever floor within the Children's
19 Social Work building.
20 MR GARNHAM: So Samantha Hunt may be right in saying that
21 she faxed this page, page 6, to your team.
22 MR ARMSTRONG: No, she could be right in saying that she
23 faxed that referral to Children's Social Work, but not
24 to my team.
25 MR GARNHAM: And if she had done that, it would have been

22
1 received where?
2 MR ARMSTRONG: Any part of the building, there are three
3 floors in Children's Social Work.
4 MR GARNHAM: But you say, do you, that that never reached
5 either you or anyone else in your team?
6 MR ARMSTRONG: That is correct.
7 MR GARNHAM: There is, is there not, some similarity between
8 that record and the referral you describe having
9 received on the 21st?
10 MR ARMSTRONG: No, there is not.
11 MR GARNHAM: The child's first name is the same.
12 MR ARMSTRONG: Oh, in terms of the -- sorry, in terms of the
13 information, yes.
14 MR GARNHAM: The child's first name is the same, the address
15 is the same.
16 MR ARMSTRONG: That is correct.
17 MR GARNHAM: There is a reference to the child wetting
18 herself, yes?
19 MR ARMSTRONG: Yes, on the referral.
20 MR GARNHAM: What is present in that referral, but absent in
21 yours, is any reference to cuts and bruises to Anna's
22 face, concerns expressed by neighbours, concerns
23 expressed by the caller, the child not attending school
24 and the child living in unsuitable accommodation. All
25 of those appear in this referral, but do not appear in

23
1 the one you record on 21st June.
2 MR ARMSTRONG: No, I did not record the referral, the
3 referral was taken by a social worker, presented to me,
4 and did not include this information.
5 MR GARNHAM: I am sorry, I was imprecise in my question.
6 None of that that I have just put to you do we find on
7 page 3 and 4 of the documents you completed.
8 MR ARMSTRONG: Because that was not the referral that
9 I received.
10 MR GARNHAM: Quite. And you say also, on the basis of your
11 memory, that the referral you received on the 21st did
12 not include any of that sort of detail.
13 MR ARMSTRONG: That is correct.
14 MR GARNHAM: Is it possible, Mr Armstrong, that the referral
15 you are referring to, in the document at page 3, is in
16 fact the same referral, but that you have got the date
17 wrong and your description of the details is incomplete?
18 MR ARMSTRONG: That is incorrect.
19 MR GARNHAM: Because I have to suggest to you that the
20 likelihood is that a referral was made on 18th June, at
21 about 4.20 in the afternoon, but was not picked up and
22 acted upon by anybody in your team until the 21st.
23 MR ARMSTRONG: That is incorrect.
24 MR GARNHAM: 18th June was a Friday; is that right?
25 MR ARMSTRONG: Yes, I think so.

24
1 MR GARNHAM: And 21st June is the following Monday.
2 MR ARMSTRONG: Yes.
3 MR GARNHAM: The referral was apparently sent, according to
4 Samantha Hunt, at 4.21 on the afternoon of the Friday.
5 When do you normally work to on a Friday?
6 MR ARMSTRONG: I start work at approximately about 8.30
7 every morning and finish about 8.00 every night,
8 continuously throughout the year.
9 MR GARNHAM: So on this Friday evening, you would have been
10 in the office for another three and a half hours after
11 the referral, according to Samantha Hunt, was sent to
12 your office?
13 MR ARMSTRONG: That is correct.
14 MR GARNHAM: The database, of which we have a print-out at
15 page 8 in that bundle, bundle 5, refers or includes
16 a note of a referral date of 18th June. That would
17 appear to pick up page 6 in this bundle, and refer to
18 the details that were faxed across to you by
19 Samantha Hunt on 18th June. Is that not right?
20 MR ARMSTRONG: It appears to be that way.
21 (10.30 am)
22 MR GARNHAM: So the referral by Samantha Hunt on the Friday
23 afternoon appears to have resulted in the completion of
24 the computer page at page 8 in that bundle.
25 MR ARMSTRONG: Yes, it seems to be.

25
1 MR GARNHAM: Who would have completed that?
2 MR ARMSTRONG: Completed?
3 MR GARNHAM: Page 8.
4 MR ARMSTRONG: It would not be the social worker, it would
5 be an administrative officer.
6 MR GARNHAM: In your team?
7 MR ARMSTRONG: Within the department, on the ground floor
8 duty team.
9 MR GARNHAM: So somebody in your department received
10 Samantha Hunt's referral on 18th June?
11 MR ARMSTRONG: It appears that way, that somebody had seen
12 that referral, but not my team.
13 MR GARNHAM: But not your team?
14 MR ARMSTRONG: That is correct.
15 MR GARNHAM: How can you tell that?
16 MR ARMSTRONG: Because my team -- had we seen a referral
17 that I have just seen there again, that referral would
18 never have waited until the Monday, because we have got
19 a policy of if a referral comes in late in the evening,
20 up to, I think, just after 5.00, we would refer that to
21 our Emergency Duty Team, who will then take all the
22 necessary information and actually go and visit the
23 family and the home.
24 MR GARNHAM: You say therefore that the page we see at
25 volume 5, page 8 was created by somebody not in your

26
1 team?
2 MR ARMSTRONG: What I am saying is that that was created by
3 an administrative officer.
4 MR GARNHAM: In your team?
5 MR ARMSTRONG: Within the duty team.
6 MR GARNHAM: Mr Robert Smith, is he in that duty team?
7 MR ARMSTRONG: Robert Smith is the line manager for the
8 admin -- the assistant admins in the duty team.
9 MR GARNHAM: So might he have completed page 8?
10 MR ARMSTRONG: There is that possibility, yes.
11 MR GARNHAM: If he has completed page 8, and I am going to
12 suggest to you that he did, what does that say about the
13 body that received this referral? Who does Mr Smith
14 work for?
15 MR ARMSTRONG: Mr Smith works for the London Borough of
16 Brent.
17 MR GARNHAM: And which department?
18 MR ARMSTRONG: Admin, Children's Social Work.
19 MR GARNHAM: And which team?
20 MR ARMSTRONG: He is not directly connected with the duty
21 team, but he line manages the staff within the duty
22 team.
23 MR GARNHAM: And the duty team is your team?
24 MR ARMSTRONG: My duty team is one of the two --
25 MR GARNHAM: One of the two duty teams. So if Mr Smith knew

27
1 of this referral, then the duty team knew of the
2 referral?
3 MR ARMSTRONG: Well, Mr Smith has never brought it to my
4 attention.
5 MR GARNHAM: No. I am trying to establish at the moment
6 whether the referral from Samantha Hunt reached your
7 team; we will come on to whether it reached you in
8 a moment. Do you accept, if it is the case that
9 Robert Smith created page 8, that the referral from
10 Samantha Hunt reached your team?
11 MR ARMSTRONG: I am denying that it reached my team, because
12 as I said earlier, I had not seen -- or my staff -- seen
13 that referral, so I cannot say it reached my team. It
14 may have reached the building, but not my team.
15 MR GARNHAM: Overnight, Brent made available to us a further
16 version of page 8 which includes details of who created
17 it. Can I ask if that could be distributed please, and
18 I wonder if a copy could be shown to you. (Handed).
19 Apparently, it is possible to interrogate the
20 computer to discover more information than appears on
21 the print-out we have at page 8, and the first page --
22 I think it is right, but you tell me -- is another
23 version of volume 5, page 8.
24 MR ARMSTRONG: It appears that way.
25 MR GARNHAM: But it has an additional line on the bottom

28
1 there which says:
2 "Created by Robert Smith on 6th July 1999, last
3 modified by Robert Smith on 6th July 1999."
4 MR ARMSTRONG: That is correct.
5 MR GARNHAM: So it appears as if Mr Smith created page 8,
6 and did so on 6th July.
7 MR ARMSTRONG: It appears that way.
8 MR GARNHAM: Can you tell us why it is that there was
9 a delay from 18th June, when the referral was received,
10 and 6th July, when it was logged?
11 MR ARMSTRONG: I cannot tell you why this referral took so
12 long to be logged on to the computer, but one of the
13 things that I can remember is that because of the volume
14 of work that was there, and the trays piling over, it
15 may have taken them a lot longer than they should have
16 done.
17 MR GARNHAM: Will you turn, please, to page 26 in volume 5?
18 What is that, please?
19 MR ARMSTRONG: That is a computer print-out for a logging,
20 I would think.
21 MR GARNHAM: It refers to somebody called "Anna Kouro",
22 K-O-U-R-O, does it not?
23 MR ARMSTRONG: Yes, it is.
24 MR GARNHAM: And there is a number, 1015867.
25 MR ARMSTRONG: That is correct.

29
1 MR GARNHAM: What is that number?
2 MR ARMSTRONG: I am not quite sure what number that is.
3 MR GARNHAM: Then on the next line, it says "URRN", which is
4 what?
5 MR ARMSTRONG: I could not tell you.
6 MR GARNHAM: It gives a number of 1010060, a reference date
7 of 14th July, a category "CP", which is presumably child
8 protection?
9 MR ARMSTRONG: That is correct.
10 MR GARNHAM: "Agency: Health. Decision: closed. DEC
11 date" -- what is that, decision date?
12 MR ARMSTRONG: I assume it is.
13 MR GARNHAM: -- "3rd September". Then if you go over the
14 page, can you tell us what that is? Is that the reverse
15 side of the same document, or is that a fresh document?
16 MR ARMSTRONG: This is a confidential sheet that is normally
17 within the front cover of a file.
18 MR GARNHAM: That refers to two people, a woman and a girl,
19 by the surname of Kouro, K-O-U-R-O, and it gives the
20 address of 8 Nicoll Road, and then the description,
21 halfway down the page, says:
22 "See also URRN 1009966."
23 It appears as if that is a linking document?
24 MR ARMSTRONG: I cannot answer that question, as the linking
25 of documents, unless it is done visibly by staff, is

30
1 done by the administrative officer on the computer, so
2 an administrative officer would know what those
3 terminologies are.
4 MR GARNHAM: This document appears to relate to the
5 admission of Victoria to the Central Middlesex Hospital
6 on 14th July, does it not?
7 MR ARMSTRONG: From the information on there, yes.
8 MR GARNHAM: And it looks likely, does it not, that a link
9 was made by the administrative worker to that referral
10 of 18th June?
11 MR ARMSTRONG: It appears that way.
12 MR GARNHAM: Is it right then that thus far we have
13 established that Samantha Hunt's referral on 18th June
14 must have been received in your office, but you say not
15 seen by you?
16 MR ARMSTRONG: It may have been received in the building,
17 but not in my office.
18 MR GARNHAM: That it was logged into the computer by
19 Robert Smith on 6th July?
20 MR ARMSTRONG: According to the information presented, yes.
21 MR GARNHAM: But you maintain that you were unaware of the
22 18th June referral.
23 MR ARMSTRONG: That is correct.
24 MR GARNHAM: Do you agree that the referral described by
25 Samantha Hunt is a much more serious one than the one

31
1 you describe in paragraph 31 of your statement as
2 occurring on 21st June?
3 MR ARMSTRONG: The referral which I have just seen in the
4 bundle, which was sent by Samantha Hunt, yes, would be
5 seen by me, if it had arrived, as a serious --
6 a referral to be dealt with immediately.
7 MR GARNHAM: So if you had received it, but I understand you
8 say you did not, but if you had received it, what would
9 you have done?
10 MR ARMSTRONG: Had I received that referral, the first thing
11 I would have done would be to approach the Child
12 Protection Team, discuss the issues and contents of the
13 referral with them, and get some agreement for it to be
14 transferred immediately to that team, so that they can
15 pursue what action that was necessary.
16 MR GARNHAM: If it proves to be the case that the referral
17 from Samantha Hunt was received by your team on
18 18th June, and I understand you dispute that, but if
19 that turns out to be the case, do you agree that your
20 team failed to deal with it properly?
21 MR ARMSTRONG: Could you repeat that?
22 MR GARNHAM: If it turns out to be the case that
23 Samantha Hunt's referral of 18th June was received by
24 your team, do you agree that your team failed to deal
25 with it properly?

32
1 MR ARMSTRONG: If it was received by my team, but it had
2 not.
3 MR GARNHAM: Because it would have been necessary to treat
4 it with a good deal greater seriousness and urgency than
5 appears to have happened.
6 MR ARMSTRONG: Had I received that referral on the 18th, it
7 would have been dealt with on the evening of the 18th.
8 MR GARNHAM: What do you say happened to the referral that
9 we have at page 6? What do you say happened to that?
10 MR ARMSTRONG: I cannot explain to you what happened to it.
11 All I can say to you is that the referral which is in
12 front of me was never received by my duty team.
13 MR GARNHAM: One of the steps you would have taken, had you
14 received that, would have been to arrange for Nicoll
15 Road to be visited, would you not?
16 MR ARMSTRONG: Had I received this referral, my team would
17 not have visited Nicoll Road. The case would have been
18 transferred out of the Intake Team to the Child
19 Protection Team, who would have carried out the
20 necessary visits.
21 MR GARNHAM: And they would have done the visit?
22 MR ARMSTRONG: Yes, they would have done.
23 MR GARNHAM: Can I take you to paragraph 31 of your
24 statement, please? At paragraph 31, you are discussing
25 the referral you did receive on 21st June, yes?

33
1 MR ARMSTRONG: Pardon?
2 MR GARNHAM: You are discussing in paragraph 31 the referral
3 you did receive on 21st June.
4 MR ARMSTRONG: That is correct.
5 MR GARNHAM: You say almost exactly halfway down:
6 "As it turned out, the administrative staff did not
7 actually log the details into the computer until 6th or
8 8th July."
9 Yes?
10 MR ARMSTRONG: Well yes, and that was when I was presented
11 with the papers at the internal investigation, that
12 I realised that the case was not logged.
13 MR GARNHAM: The only document we have got that was logged
14 on 6th or 8th July is the document I showed you a few
15 minutes ago, which is the new version of the computer
16 print-out.
17 MR ARMSTRONG: Yes.
18 MR GARNHAM: That refers to a referral dated 18th June.
19 MR ARMSTRONG: From the records, yes.
20 MR GARNHAM: So is it not the case that the referral you are
21 referring -- I am sorry about the repeated use of
22 "referral". The referral you are describing in the
23 second half of paragraph 31 is a referral received on
24 18th June?
25 MR ARMSTRONG: I disagree with that.

34
1 MR GARNHAM: Well, tell us how it is then that the computer
2 log created by Mr Smith on 6th July gives the referral
3 date of 18th June.
4 MR ARMSTRONG: I can only assume that he got that
5 information, and that referral, which we never received,
6 and that was logged in, and one of the things that
7 I would say is that if a referral like that was logged
8 in, given the information, it would have come back to
9 the duty team and we would have dealt with it
10 immediately on the 6th, had I seen it on 6th July.
11 MR GARNHAM: So you are saying that the sheet we have here,
12 the new sheet, created by Robert Smith on 6th July, does
13 refer to the 18th June referral and does not refer to
14 your 21st June referral?
15 MR ARMSTRONG: That is correct.
16 MR GARNHAM: So it is entirely coincidental, is it, that
17 your referral of 21st June was also not logged until
18 6th or 8th July?
19 MR ARMSTRONG: I cannot say, because the referral that
20 I completed on the 21st is not here, it is missing.
21 MR GARNHAM: What are you referring to then in paragraph 31,
22 when you say, "As it turned out, the administrative
23 staff did not actually log the details until 6th or
24 8th July"?
25 MR ARMSTRONG: As I said earlier, when I was presented at

35
1 the internal investigation, I realised that the referral
2 that was shown to me, plus the necessary D5, indicated
3 that it was not logged in until July.
4 MR GARNHAM: But what was logged in on 6th or 8th July was
5 the 18th June referral, not the 21st June referral.
6 MR ARMSTRONG: I cannot answer that question.
7 MR GARNHAM: But you must be able to, Mr Armstrong. You are
8 here in paragraph 31 described a referral you received
9 on 21st June.
10 MR ARMSTRONG: That is correct.
11 MR GARNHAM: You go on to say that that referral, 21st June,
12 was logged in on 6th or 8th July. The only referral of
13 which we have evidence logged in on 6th or 8th July is
14 the 18th June referral.
15 MR ARMSTRONG: I cannot answer that question.
16 MR GARNHAM: I do not understand why you cannot answer that
17 question.
18 MR ARMSTRONG: I cannot answer it because my records, which
19 would have shown whether it was logged in or not, are
20 not available, they are missing.
21 MR GARNHAM: How then do you know that your referral was
22 logged in on 6th or 8th July?
23 MR ARMSTRONG: Because I am assuming that my referral was
24 logged in with a number of other referrals that were
25 given on that date.

36
1 MR GARNHAM: On what possible basis are you making that
2 assumption?
3 MR ARMSTRONG: On the assumption that admin would have
4 logged in that referral. Or any other.
5 MR GARNHAM: But why 6th or 8th July?
6 MR ARMSTRONG: Not on 6th July; I am saying my referral of
7 21st June should have been logged in on 21st June.
8 I cannot answer why the referral took so long and was
9 logged in on 6th or 8th July.
10 MR GARNHAM: But you say that as it turned out, your
11 referral was logged in on 6th or 8th July. Are you
12 saying that is wrong now? Should we cross that out of
13 your statement?
14 MR ARMSTRONG: What I am saying is that information came
15 from when I saw the referral during the internal
16 investigation, so it may be the wording is totally
17 wrong.
18 MR GARNHAM: But that is a different referral. The one you
19 were shown during the course of the internal
20 investigation was the referral of 18th June.
21 MR ARMSTRONG: Yes.
22 MR GARNHAM: So you have made a mistake in your statement.
23 MR ARMSTRONG: I may have made a mistake, but what I am
24 saying is the referral of 21st June should have been
25 logged in on 21st June, and I assume it was logged in.

37
1 MR GARNHAM: And when are you saying it was in fact logged
2 in?
3 MR ARMSTRONG: I cannot say, because it is not here.
4 MR GARNHAM: So what we have in paragraph 31 is just
5 a guess?
6 MR ARMSTRONG: It is not a guess.
7 MR GARNHAM: What is it then?
8 MR ARMSTRONG: At the time when I made that statement, that
9 is how I felt, and that was the information that was
10 available to me.
11 MR GARNHAM: In the next paragraph, you say that the social
12 worker had found out that the family had moved from
13 Ealing to Brent; do you see that?
14 MR ARMSTRONG: Yes, I can.
15 MR GARNHAM: How? How, from the information you had
16 received, did they discover that?
17 MR ARMSTRONG: The social worker found out that the family
18 had moved from Ealing to Brent when we did our checks
19 with our Housing Department, who informed us that the
20 address at Nicoll Road was used by Ealing to place
21 temporary residents, i.e. asylum seekers et cetera, and
22 that is how we became aware of that information.
23 MR GARNHAM: But how did you know that this particular
24 family had been placed in that accommodation by Ealing?
25 MR ARMSTRONG: Brent did not use the property at the time.

38
1 MR GARNHAM: Does any London borough apart from Ealing use
2 it?
3 MR ARMSTRONG: I cannot say.
4 MR GARNHAM: If they do, how would you have discovered that
5 Ealing were the ones who placed this particular family?
6 MR ARMSTRONG: By contacting Ealing.
7 MR GARNHAM: So are you saying that you contacted Ealing in
8 response to the 21st June referral to ask whether they
9 had placed a child by the name of Anna at 8 Nicoll Road?
10 MR ARMSTRONG: That is correct.
11 MR GARNHAM: As a result of that contact, you presumably
12 found out Anna's surname?
13 MR ARMSTRONG: I do not think we found out her surname, up
14 to the time of the visit by my duty worker and the
15 senior -- I am quite sure that we did not find out her
16 surname by that time.
17 MR GARNHAM: So you contacted Ealing to try and discover
18 whether a child by the name of Anna had been placed by
19 them at 8 Nicoll Road; you were told that indeed they
20 had.
21 MR ARMSTRONG: That is correct.
22 MR GARNHAM: But you did not ask Ealing what the child's
23 surname was.
24 MR ARMSTRONG: I cannot remember.
25 MR GARNHAM: Is it not the most obvious question to have

39
1 asked Ealing?
2 MR ARMSTRONG: It may have been the most obvious, but when
3 you are working under stress and pressure, lots of
4 things could have happened.
5 MR GARNHAM: You describe in paragraph 33 the enquiries that
6 should have been made. You say:
7 "On receipt of this information [about the child
8 wetting herself], I decided that enquiries should be
9 made to the London Borough of Brent's Housing and Health
10 Departments and the General Medical Practitioners Board,
11 and also to the Social Services Department in the London
12 Borough of Ealing."
13 Yes?
14 MR ARMSTRONG: That is correct.
15 MR GARNHAM: And you put those instructions in a written
16 form, given to the social workers in your team?
17 MR ARMSTRONG: Attached to the case papers.
18 MR GARNHAM: And you classified the child as a child in
19 need; yes?
20 MR ARMSTRONG: That is correct.
21 MR GARNHAM: You did all of that because, you tell us, the
22 child was wetting herself.
23 MR ARMSTRONG: That was an initial assessment, based on the
24 information that was provided.
25 MR GARNHAM: Why would the fact that the child was wetting

40
1 herself have justified all those enquiries?
2 MR ARMSTRONG: One has to establish who had responsibility
3 for the child, whether the child had access to a doctor,
4 health visitor, school nurse, et cetera.
5 MR GARNHAM: Your team is up to its eyes with work, and you
6 have a report simply that a child is wetting herself,
7 an eight year old girl is wetting herself, and you are
8 saying that as a result of that single piece of
9 information, you made enquiries with Housing, Health,
10 GM Practitioners Board, Social Services in Ealing and
11 your own, all because a child is wetting herself?
12 MR ARMSTRONG: All because a child is wetting herself, and
13 secondly because the culture in Brent at the time is
14 that people who were in temporary accommodation, and
15 came to the borough, we tried to just get them out of
16 the borough for financial reasons.
17 MR GARNHAM: People in the borough who are housed in
18 temporary accommodation you try to get out for financial
19 reasons?
20 MR ARMSTRONG: Yes, because in lots of cases, we end up
21 taking over responsibility for rent, et cetera.
22 MR GARNHAM: But at the time Ealing were meeting the rent.
23 MR ARMSTRONG: I am not sure.
24 MR GARNHAM: Yes, you are, you just told us. Ealing had
25 placed them there.

41
1 MR ARMSTRONG: I did not say Ealing was paying the rent, I
2 said Ealing placed them there. I do not know who was
3 paying the rent.
4 MR GARNHAM: I see. Do you regard the fact that an eight
5 year old girl is wetting herself as, in itself,
6 justification for classifying her as a child in need?
7 MR ARMSTRONG: Yes, I do.
8 MR GARNHAM: And do you regard the fact that a child is
9 wetting herself as justifying two unannounced visits to
10 the child's home?
11 MR ARMSTRONG: Which was the policy we had in Brent, if we
12 get anonymous calls, et cetera -- and given the number
13 of referrals we had, and the number of work outstanding,
14 we would ask staff who were going out on visits, on the
15 way back, whether they can stop at an address
16 unannounced and try and get as much information as
17 possible, and that happened on a daily basis.
18 MR GARNHAM: So every time you get a report that there is
19 some child somewhere in your borough that has wet
20 herself, or is wetting herself, you arrange two
21 unannounced visits, spot checks, to her family's home,
22 do you?
23 MR ARMSTRONG: We arrange a number of unannounced visits,
24 depending on the information provided. We also do
25 unannounced visits on children who are not attending

42
1 school.
2 MR GARNHAM: Yes. What I have to suggest to you,
3 Mr Armstrong, is that the course of action you took,
4 including making enquiries with all these agencies and
5 arranging two spot visits, is much more consistent with
6 your having received the referral from Samantha Hunt on
7 18th June than with a referral on 21st June to the
8 effect that an eight year old child was wetting herself.
9 MR ARMSTRONG: That is incorrect.
10 MR GARNHAM: You say that Yolande Hurter contacted Ealing
11 Social Services.
12 MR ARMSTRONG: At some stage during the process, she did.
13 MR GARNHAM: Do you know when in the history of this matter?
14 MR ARMSTRONG: I cannot remember the exact date when she
15 did, but I remember that she did.
16 MR GARNHAM: How long after you received the referral on
17 21st June?
18 MR ARMSTRONG: I am not sure how long after, but she did
19 make contact with Ealing.
20 MR GARNHAM: You have described the way in which you
21 responded to this report of an eight year old girl
22 wetting herself. How promptly would you expect one of
23 your social workers to contact the other London borough
24 in those circumstances?
25 MR ARMSTRONG: If I have given written instructions on the

43
1 day, I would expect it to be completed on the day.
2 MR GARNHAM: And when would you have expected to give that
3 instruction? That same day, 21st June?
4 MR ARMSTRONG: Yes.
5 MR GARNHAM: Ms Hurter appears not to have any recollection
6 of your instructing her to do that, but you say
7 nonetheless that you did?
8 MR ARMSTRONG: I did.
9 MR GARNHAM: You say that she then spoke to Godfrey Victor
10 at Ealing.
11 MR ARMSTRONG: That is correct.
12 MR GARNHAM: He says that he never discussed the case with
13 her; on your version of events, he must be wrong.
14 MR ARMSTRONG: Not he must be wrong; Mr Godfrey is wrong.
15 He is being economical with the truth.
16 MR GARNHAM: Is that another way of your saying he is lying?
17 MR ARMSTRONG: Yes.
18 MR GARNHAM: You say that you twice discussed the case with
19 Mr Victor, paragraphs 35 and 38 in your statement.
20 MR ARMSTRONG: Yes, that is correct.
21 MR GARNHAM: He says he never discussed the case with you,
22 so he is lying again?
23 MR ARMSTRONG: He is lying.
24 MR GARNHAM: He also says he would have had no reason to
25 discuss the case with you.

44
1 MR ARMSTRONG: When Mr Victor was contacted, he informed me,
2 when I spoke to him, that he was a duty worker at the
3 Town Hall dealing with the case.
4 MR GARNHAM: You say that you spoke to Mr Skinner?
5 MR ARMSTRONG: Yes, I did.
6 MR GARNHAM: What was said between you?
7 MR ARMSTRONG: I spoke to Mr Skinner about who has
8 responsibility for a family who is residing in temporary
9 accommodation within our locality, and we clarified that
10 the responsibility for the case still remained with
11 Ealing, and as such, that message was relayed to
12 Godfrey Victor.
13 MR GARNHAM: And you say that conversation with Skinner was
14 confirmed by fax?
15 MR ARMSTRONG: It was confirmed by fax from me to Mr Victor
16 at Acton Town Hall.
17 MR GARNHAM: Where is that fax?
18 MR ARMSTRONG: It is not on this case file.
19 MR GARNHAM: It should be?
20 MR ARMSTRONG: It should be, and should also be within
21 Acton's unit.
22 MR GARNHAM: If it existed, you would expect to find it both
23 in your file and in Ealing's files?
24 MR ARMSTRONG: It did exist.
25 MR GARNHAM: He again says that he had no such conversation

45
1 with you.
2 MR ARMSTRONG: Who is that?
3 MR GARNHAM: Mr Skinner.
4 MR ARMSTRONG: I can only say Mr Skinner may be forgetful,
5 but I know -- I am 100 per cent sure that I have had
6 conversations with both Mr Godfrey Victor and
7 Mr John Skinner.
8 MR GARNHAM: I have to suggest to you, so that you can deal
9 with it, that you are not telling the truth,
10 Mr Armstrong.
11 MR ARMSTRONG: I can tell you that I am telling the truth
12 and I can also explain how my contact -- I did contact
13 Mr Victor.
14 MR GARNHAM: Please do.
15 MR ARMSTRONG: I said, I did contact him.
16 MR GARNHAM: You know --
17 MR ARMSTRONG: Sorry, I also find it strange that Mr Victor
18 is saying he had no contact with me, when it was I who
19 provided a reference for his job in Ealing.
20 MR GARNHAM: I do not think he is saying he has never had
21 any contact with you, I think he is saying that he had
22 no contact with you about this case at that time.
23 MR ARMSTRONG: But he did.
24 MR GARNHAM: You know, do you not, both Mr Victor and
25 Mr Skinner?

46
1 MR ARMSTRONG: Pardon?
2 MR GARNHAM: You knew before these events both Mr Victor and
3 Mr Skinner?
4 MR ARMSTRONG: Yes, I did.
5 MR GARNHAM: You have worked with both of them in the past?
6 MR ARMSTRONG: Yes, I did.
7 MR GARNHAM: Is it then simple coincidence, or is there some
8 other explanation for the fact that the only two people
9 at Ealing you happen to have spoken to about this are
10 two people whose names you would have known anyway?
11 MR ARMSTRONG: No.
12 MR GARNHAM: No, it is not coincidence.
13 MR ARMSTRONG: Well, it is a coincidence, but it is a fact
14 that I have spoken to both Mr Victor and Mr Skinner.
15 MR GARNHAM: And it is just coincidence that the two people
16 who you happened to speak to were people you already
17 knew and whose names, therefore, you knew?
18 MR ARMSTRONG: That happens within social work.
19 MR GARNHAM: There is no mention of any of this on the files
20 we have got, is there?
21 MR ARMSTRONG: Because the papers are missing. The fax that
22 I sent to Ealing, Acton Town Hall, they are also missing
23 with our case papers.
24 MR GARNHAM: In paragraph 36 of your statement,
25 Mr Armstrong, you say that you discussed the question as

47
1 to who had responsibility for this case, whether it was
2 Ealing or Brent, with Tina Roper or Chrissy Austin or
3 Michelle Hines.
4 MR ARMSTRONG: That is correct.
5 MR GARNHAM: Miss Austin gave evidence yesterday and
6 expressly denied that there was any such conversation
7 with you, and neither Roper nor Hines mention it in
8 their statements. Are they also being economical with
9 the truth?
10 MR ARMSTRONG: I am not saying that they are being
11 economical with the truth. What might have happened is
12 that they just cannot remember, but I did discuss
13 responsibility as to who, if families are residing
14 temporarily in the borough with one of --
15 MR GARNHAM: One of, but not all three, you just do not know
16 which one it was?
17 MR ARMSTRONG: No, but I did discuss it.
18 MR GARNHAM: If all three of them deny such a conversation,
19 then one of them is plainly wrong, on your account.
20 MR ARMSTRONG: Yes.
21 MR GARNHAM: Why did you discuss this question, namely which
22 borough has responsibility for children placed in the
23 circumstances you have described; why did you discuss
24 that with Austin, Roper or Hines? Would not the most
25 sensible person to discuss it with have been your line

48
1 manager, Mr Charlett?
2 MR ARMSTRONG: Not necessarily.
3 MR GARNHAM: Are any of those three women, Roper, Austin or
4 Hines, particular experts on that subject?
5 MR ARMSTRONG: You do not have to be an expert, you just
6 need to know what the agreement is between the boroughs.
7 MR GARNHAM: But you did not think that was a subject that
8 you ought to ask your line manager about?
9 MR ARMSTRONG: Not at the time.
10 MR GARNHAM: You say at paragraph 37 of your statement that
11 at that stage, Ealing did not accept responsibility for
12 the case.
13 MR ARMSTRONG: That is correct.
14 MR GARNHAM: And that accordingly, because they had not
15 accepted responsibility, you arranged these two
16 unannounced home visits.
17 MR ARMSTRONG: That is correct.
18 MR GARNHAM: Who carried them out, those unannounced home
19 visits?
20 MR ARMSTRONG: I cannot say. I cannot remember who carried
21 out those two unannounced visits, because it would have
22 been additional work given to a worker going out into
23 the field.
24 MR GARNHAM: Again, your memory fails you as to which social
25 worker or social workers it was.

49
1 MR ARMSTRONG: My memory has not failed me, it is just that
2 I cannot remember.
3 MR GARNHAM: Again, no record of this, presumably because
4 the papers have gone missing, would be your answer?
5 MR ARMSTRONG: Pardon?
6 MR GARNHAM: There is no record of these two unannounced
7 visits.
8 MR ARMSTRONG: There is no record.
9 MR GARNHAM: Is that because the relevant papers have gone
10 missing?
11 MR ARMSTRONG: Yes.
12 MR GARNHAM: Did they consult you about the results of their
13 visits when they returned?
14 MR ARMSTRONG: They may have consulted myself or my seniors.
15 MR GARNHAM: Presumably that is what you would have expected
16 them to do?
17 MR ARMSTRONG: It is an expectation to be consulted, once
18 a worker returns to the office from a visit.
19 MR GARNHAM: Did you ever find out, either from them or from
20 your seniors, what the results of those visits were?
21 MR ARMSTRONG: The results of the two unannounced visits, as
22 was recorded, was that there was no one at home.
23 MR GARNHAM: You cannot remember how you came by that piece
24 of information, whether direct from a social worker or
25 via one of your seniors?

50
1 MR ARMSTRONG: It may have come direct from the social
2 worker's recording, or from reading the file, speaking
3 to the social workers, and I cannot remember.
4 MR GARNHAM: What did you do once you had discovered that
5 there was no one at the address?
6 MR ARMSTRONG: I decided that we need to send out
7 an appointment letter, in case we were missing the
8 client, so that when the client gets a letter, they may
9 keep the appointment.
10 MR GARNHAM: As it happened, eventually Mr Skinner did
11 accept responsibility, you say, for this case; yes?
12 MR ARMSTRONG: Mr Skinner did indicate that it was Ealing's
13 responsibility.
14 MR GARNHAM: Paragraph 38:
15 "Between one and two weeks after the initial
16 referral, I contacted Mr John Skinner and discussed the
17 case with him as a 'child in need' case and which
18 borough had responsibility. He agreed that case
19 responsibility rested with Ealing ..."
20 So that is within one or two weeks of the initial
21 referral?
22 MR ARMSTRONG: It was during the time that case was within
23 my team.
24 MR GARNHAM: You say here, "Between one and two weeks after
25 the initial referral ..."

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