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   Pages 1 to 50 | Pages 51 to 100 | Pages101 to 150 | Pages 151 to 200 | Pages 201 to 276

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

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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.

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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

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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

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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

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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.

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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

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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.

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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?

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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.

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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

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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

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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.

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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,

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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?

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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.

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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

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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?

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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

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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?

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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

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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

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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.

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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.

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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

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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

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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

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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.

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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

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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

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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?

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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?

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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.

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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

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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.

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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.

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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.

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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

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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

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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.

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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

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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

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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.

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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

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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?

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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

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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

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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.

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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?

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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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