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Archived Transcript for 30 January 2002: Pages
201 to 250
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1 neonates. The meetings are held on Monday afternoons
2 ... Wednesday afternoons on the neonatal unit. These
3 meetings provide a valuable forum to discuss specific
4 concerns ... in the past the hospital based social
5 workers attended ... social worker attendance was
6 discontinued due to the shortage of Social Workers and
7 the absence of any Social Worker on site to cover
8 Haringey children. I would be very grateful if you
9 could contact me as soon as possible to discuss this
10 issue and I look forward to hearing from you ..."
11 Did she hear from you?
12 MS BRISTOW: My recollection is that I asked the Assistant
13 Director to contact her.
14 MR GARNHAM: At that stage, which is May 2001, what was the
15 response; "yes" or "no"?
16 MS BRISTOW: I think at that stage we still did not have
17 a hospital social worker and I think we -- I believe and
18 I hesitate here because I have indistinct recall of
19 this -- that we said we would come as often as we could.
20 MR GARNHAM: Do you know whether that happened?
21 MS BRISTOW: It is not something I have checked.
22 MR GARNHAM: Now that there are Haringey social workers at
23 the NMH, are they attending?
24 MS BRISTOW: I believe so but I have not personally checked.
25 MR GARNHAM: Do you regard communications between NMH and

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1 Haringey Social Services now, over the last year or so,
2 as being satisfactory?
3 MS BRISTOW: I think they are reasonable, yes.
4 MR GARNHAM: It is a cornerstone of decent child protection
5 work, is it not, that you and the hospitals talk?
6 MS BRISTOW: Yes it is, and it is for that reason that
7 I have put a lot of personal effort into trying to
8 strengthen the Child Protection Area Committee and
9 making sure there are opportunities there to have those
10 kinds of discussions.
11 MR GARNHAM: Can I ask you to look at 45F, please. So
12 sorry, I have given you the wrong number. 45H/172.
13 A letter from Dr Rossiter of 12th December 2000, just
14 over a year ago, to Dawn Cardis. Dr Rossiter is
15 recording the decision to remove a child's name from the
16 CP register --
17 MISS LAWSON: Sir, I hesitate to interrupt but ...
18 (Discussion held).
19 MR GARNHAM: Sir, it seems to me this is a discussion that
20 ought to go on publicly. Miss Lawson has objections to
21 my putting these questions. I am not prepared to give
22 way unless you rule I should not, so she ought to make
23 those objections publicly.
24 MISS LAWSON: Sir, this is one of a series of documents
25 which is referred to in the statement of Dr Rossiter,

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1 the third statement of Dr Rossiter to which I have
2 referred, which I had understood the Inquiry was not
3 going to be looking at, because looking at the documents
4 raises the questions about whether or not the facts in
5 those documents are correct or not, and the Inquiry
6 decided, as I have understood it, that the investigation
7 of those matters at this stage was not appropriate.
8 I am extremely concerned if Mr Garnham is now going
9 to be pointing to bits of this when we have not put in
10 place anything to, as it were, put forward Haringey's
11 side of this, and with the difficulties that we thought
12 the Inquiry had recognised.
13 MR GARNHAM: Sir, what we have recognised and what in
14 consequence we have agreed to do has been made public
15 previously. Dr Rossiter provided a third statement that
16 referred to the cases of a large number of other
17 individuals. This Inquiry could not either within its
18 terms of reference or within a reasonable timescale
19 adequately investigate all those other cases and, as
20 a result, we have not done so. We have as a result
21 indicated that we would have no regard to the contents
22 of Dr Rossiter's third statement which details them.
23 What I have not said and what I do not think either
24 of my learned friends have said at any stage is that we
25 will not ask questions arising out of the correspondence

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1 which is exhibited to that third statement.
2 Now I propose, unless you indicate that I should
3 not, sir, to put to this witness two letters which
4 illustrate not differences of view about individual
5 cases, but an absence of proper communication. Now if
6 this witness says to me she knows nothing about the
7 individual case, then all I can ask her about is the
8 apparent absence of proper communication, which frankly
9 says nothing one way or the other about the merits of
10 the individual case. I have no interest in that.
11 THE CHAIRMAN: The position is that I am quite clear that
12 I am not prepared to consider in detail any other case,
13 and certainly none of the cases in Dr Rossiter's third
14 statement, for reasons with which I entirely agree with
15 the points that Miss Lawson has made.
16 If, however, in relation to the matters that are now
17 being put to this witness, it is not about the cases
18 concerned, and in this letter I assume that because it
19 is only the particular individual's name, it is not
20 about the case material at all, it is not about the
21 case, it is about the relationship between Haringey and
22 the hospital, then I think that is reasonable.
23 MR GARNHAM: Thank you, sir.
24 Would you then look at the letter at page 172. I do
25 not expect you to know anything about this particular

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1 case. Would I be right in thinking that is the
2 position?
3 MS BRISTOW: You are indeed right.
4 MR GARNHAM: And I am not asking you about who is right or
5 who is wrong about the way this unnamed person was
6 either treated by the hospital or dealt with by Haringey
7 Social Services.
8 What I want to ask you is this: it appears that
9 Dr Rossiter is in this letter recording that the
10 decision to remove a child's name from the CP register
11 did not have support, did not have her support. Now
12 what I want to understand is whether there is
13 a continuing problem between you and Dr Rossiter
14 specifically, or the NMH generally, about sitting down
15 and talking through differences of view about individual
16 cases?
17 MS BRISTOW: I do not believe so. I am at a disadvantage as
18 I do not know what reply if any was made to this letter.
19 So I find it difficult to comment on whether, you know,
20 on face value Dr Rossiter says there is a communication
21 problem but I do not know whether or not that is
22 a shared perception.
23 What I am very clear about is that there are
24 mechanisms through the Area Child Protection Committee
25 of which Dr Rossiter is a member which I attend

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1 regularly, as does my Assistant Director, and through
2 a panoply of subgroups that it has to raise these
3 matters. Indeed there is a case review sub-committee
4 that has been established this year that provides
5 exactly the forum where you would expect that kind of
6 discussion to go on.
7 In addition to that, I know that my Assistant
8 Director has met with her directly to discuss working
9 together and I have seen other correspondence from her
10 where she tells me that she has been meeting with the
11 District Manager from Tottenham. So given that, it
12 seems to me there are arrangements in place for any
13 difficulties to be resolved.
14 It is inevitable in dealing with a large number of
15 pieces of joint work that from time to time on either
16 side there may be problems on communication, people are
17 in and out, doctors have clinical sessions, you know.
18 But what I am more concerned to be certain is that there
19 are mechanisms in place, equally there are a number of
20 arenas where I and others of my managers meet managers
21 from the North Middlesex.
22 MR GARNHAM: So if we look at the other letter that I wanted
23 to ask you about I suspect your answer will be the same,
24 at page 173. This one is an in-patient case summary.
25 The note at the bottom is "Follow-ups":

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1 "Strategy meeting at NMH did not occur. Social
2 workers unwilling to come to the hospital even though it
3 has been pre-arranged the week previously ... clerical
4 misunderstanding in SSD ... family did not return to see
5 Dr Rossiter ... very worrying case." Expressions
6 familiar to us. "Long discussion with Dawn Cardis,
7 Child Protection Coordinator, who will take things
8 further."
9 Your answer would be, would it: you do not know the
10 details of that particular case but you assume it is
11 taken forward in the forum you have talked about?
12 MS BRISTOW: Yes, I do, and I presume it did not reach a
13 level of seriousness that either the Chief Executive at
14 the North Middlesex or Dr Rossiter chose to contact me
15 about it. What my concern has been, and it is a debate
16 that we have had locally, is that if people feel that
17 the response from my managers is not appropriate, then
18 please take it up the management line. I mean, I also
19 understand in my discussions with Carol Wilson that that
20 had previously been said at the Area Child Protection
21 Committee.
22 I would also have to say here I feel disadvantaged.
23 She asserts, and I am not trying to call into question
24 what she asserts, but I have no information whether or
25 not we agree with that assessment.

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1 MR GARNHAM: Well, that is entirely fair. Thank you for
2 dealing with it.
3 The next topic, and you will be sorry to know that
4 we are getting towards the end, the next topic is
5 management information. How reliable do you think
6 Haringey's management information database is?
7 MS BRISTOW: I have increasing confidence because the
8 district auditor is charged with looking at all our
9 performance data and in the last year we had no
10 qualified indicators.
11 MR GARNHAM: I see. And the absence of qualifications to an
12 indicator means that there is confidence in its
13 accuracy?
14 MS BRISTOW: It means that the district auditor who is our
15 external auditor has given us a clean bill of health
16 about the robustness of it.
17 MR GARNHAM: Because Mary Richardson was saying, and that of
18 course is now somewhat historical, that when she left
19 the system was difficult to use and could not deliver
20 what she wanted. Was that what it was like when you
21 started?
22 MS BRISTOW: I think what we have is an old computer system.
23 My understanding of it: Its functionality is fine but
24 its user friendliness, to use the jargon, is poor. And
25 as increasingly we all become used to web-enabled

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1 windows-based systems, ones that rely on you remembering
2 a sequence of key strokes become less and less friendly.
3 What we also have, as with any computer system, it is
4 only as good as what you tell it, and the assumption is
5 that if you do not enter the data accurately on the
6 computer then what will come out is undoubtedly rubbish.
7 MR GARNHAM: What prompted me to ask these questions is one
8 particular difficulty that is revealed in the documents.
9 Would you have 45F, please page 133. This takes a few
10 moments to work out. Let me see if I can explain what
11 the problem is so I can get your answer. This is
12 a report to the Policy and Strategy Committee,
13 31st July 2001.
14 At page 133, internal page 13, we see a graph that
15 sets out the proportion of weekly visits to children on
16 the Child Protection Register and we see the target is
17 to move from a position of about 95 per cent, is it?
18 You look as if you do not have the page.
19 MS BRISTOW: I do, I am just checking which month it is,
20 sorry. Okay, that is fine. Thank you.
21 MR GARNHAM: End of July 2001. It appears to show the most
22 disastrous fall off in performance, from about
23 95 per cent in April 2001 to fractionally over
24 50 per cent in June 2001. On the face of it that might
25 have prompted another series of questions for me, but

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1 I think we know the answer to that.
2 If you go to the same volume, page 227, this is
3 a working group report of September 2001 and we see the
4 discussion, the policy summary at the bottom of that
5 page, introducing the fact that the audit commission
6 introduced the requirement of a social worker seeing
7 a child every six weeks, then the explanation is sought
8 as to why this appears to fall to 53 per cent in 5.1.1.
9 MS BRISTOW: Yes.
10 MR GARNHAM: The answer appears to be, or at least this is
11 part of the answer, that 33 per cent of the children who
12 should have been visited and were not were accounted for
13 by poor data compliance. Either the visits had not been
14 done or were not recorded, or in the case of two
15 children they were reregistered and their entry was not
16 deregistered -- sorry and their entry was not withdrawn
17 from the CPR.
18 So it looks as if an apparently appalling set of
19 statistics is accounted for by defects in the
20 information management system. Is that right?
21 MS BRISTOW: I do not think it is a defect in the
22 information management system, rather than the way in
23 which people use it. I think I said to you earlier, the
24 functionality of the computer system as I understand it
25 is fine. However, like all computers, it is only as

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1 good as what you tell it and what you have reflected on
2 page 229 of this bundle is that staff had not entered
3 that data on.
4 I think, though, the fact that we know that is what
5 has happened and are therefore able to rectify it is
6 a demonstration of our increasing robustness about the
7 information management.
8 MR GARNHAM: Except it took three months.
9 MS BRISTOW: I do not think it took three months but you
10 will note that this happened to be when the reporting
11 cycle was. As opposed to it took us three months to
12 find it out.
13 MR GARNHAM: I see, so it is from one reporting cycle to the
14 next.
15 MS BRISTOW: The members raised a very specific question,
16 they were given an answer on the night. But as you will
17 be aware, my members are very clear about the need to
18 test out what their offices are telling them and had
19 asked for a detailed written report back as part of
20 their testing out what they are being told, and
21 therefore we brought back at the next -- I believe that
22 that would have been the next meeting on 12th September
23 because of the summer recess.
24 So it met on the 31st July, there was not a meeting
25 in August and it comes back to the September meeting.

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1 But the information would have been known ahead of that.
2 MR GARNHAM: Thank you. While I have been asking you
3 questions today, Mr Duncan has delivered his final
4 written submissions to the Inquiry. He has exhibited to
5 those final submissions a series of documents. I wonder
6 if a copy of that can be made available to the witness
7 and to anyone else here who wants to see it.
8 I do not pretend, since I have been a little busy
9 since these came in mid-morning, to have read all of
10 this material but we have looked through it. He says
11 first of all that the first batch of documents he found
12 in his loft, which is why we had not got them before;
13 the remainder are documents that he understood you,
14 Haringey, had supplied to us.
15 In the time we have had available thus far, we have
16 not been able to find any of them, except in one sense
17 one of them. These now have a number on the top
18 right-hand corner that we have added since this material
19 came in, and if I ask you to turn to --
20 MS BRISTOW: I will do my best Mr Garnham but you appreciate
21 this is the first time I have seen these.
22 MR GARNHAM: Yes, well, you and I both. Miss Lawson asks
23 for a break. I would like to finish since I am nearly
24 at the end, sir and I know there is a limited amount to
25 which you can deal with this. If it turns out you

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1 cannot answer these questions, then say so. Page 46 in
2 this little bundle.
3 MS BRISTOW: Of your numbers at the top, yes?
4 MR GARNHAM: Yes. Sir this may take more than a couple of
5 minutes. Perhaps in fairness we should take the
6 opportunity to break now.
7 THE CHAIRMAN: Thank you Mr Garnham. Ms Bristow you are in
8 very good company in saying you have only just seen
9 them. I suspect your chances of having not seen them
10 are rather greater than ours. I would be glad if we can
11 make this a short break. My reading of the clock is it
12 is 40 minutes past three. If could get back by 47. How
13 about that? Let us move quickly. 47 minutes past.
14 (3.40 pm)
15 (A short break)
16 (3.47 pm)
17 MR GARNHAM: I was asking Ms Bristow about the document we
18 have in this mini bundle.
19 MS BRISTOW: I have a problem Mr Garnham. The secretariat
20 removed the copy of the document. I no longer have it
21 in front of me.
22 MR GARNHAM: I think that is one problem we can probably
23 solve.
24 MS BRISTOW: It also means I could not look at it in the
25 break, you understand.

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1 MR GARNHAM: That is unfortunate.
2 MS BRISTOW: You wanted me to look at pages 45 and 46?
3 MR GARNHAM: I did, yes. I wonder if the secretariat could
4 give me a copy of the numbered version of this. If they
5 have all been distributed could they pinch them back?
6 Page 46. Could you also have in front of you volume 45E
7 and go in that to page 181. Do you have that?
8 MS BRISTOW: I do.
9 MR GARNHAM: It looks as if the document we have in our
10 bundles at 181 is a draft of this document that
11 Mr Duncan has produced but not the same draft.
12 MS BRISTOW: That would appear to be the case from the
13 dates.
14 MR GARNHAM: The one that we have been supplied by Haringey
15 is dated 8th May 2001, and the one that Mr Duncan has
16 given us is dated the 18th and called draft number 8.
17 Let me ask you first of all whether you have ever seen
18 this document before in either of its forms?
19 MS BRISTOW: I have seen the document. Which draft I have
20 seen, I really could not tell you at this point.
21 MR GARNHAM: The reason I am interested in this is because
22 of its dealing with team caseload targets. If you turn
23 to the appendix in this version --
24 MS BRISTOW: Are they the same?
25 MR GARNHAM: They are not, that is the point. The version,

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1 the latest version, the one with the 18th May date on
2 it, so the one in your right hand, in you turn in that
3 to the appendix you will see team caseload targets. In
4 the new version the target is said to be 13 to 15 cases;
5 in the old version it is said to be 10 to 15. For
6 social service officers the target is 20 to 25; in the
7 new version it is 18 to 20. In the old version we do
8 not have anything in the bottom box by way of a team
9 description; in the new version we do: it is practice
10 manager, and the number of cases has gone up from six to
11 six to eight.
12 MS BRISTOW: I do not --
13 MR GARNHAM: Are you with me?
14 MS BRISTOW: I think so now, yes.
15 MR GARNHAM: Go over the page to the worker caseload for
16 family placement for social worker. In the first
17 document it is 12 to 15, in the second document it is 15
18 to 17. Practice manager in the first document is six to
19 seven, and in the second document it is seven to nine.
20 Two points arise. First of all, can you tell us why
21 it was we were provided with an early draft and not the
22 latest one?
23 MS BRISTOW: I am not certain, put in front of me like this,
24 that is the only version we did provide. I do not know
25 Mr Garnham, I do not know my way around the bundles well

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1 enough.
2 MR GARNHAM: So it may be we find another one elsewhere?
3 MS BRISTOW: I think we might because it does not look to me
4 like the version I was looking at last night but that
5 does not mean -- sorry, I have not got a photographic
6 memory, so we could not be certain.
7 MR GARNHAM: We were given this material so perhaps
8 Miss Lawson has the answer.
9 MISS LAWSON: Sir there is a later version, it is not in the
10 same format as this which is at 45B, page 71, which is
11 the 11th July of last year, in which you find target
12 case numbers, starting at page 78.
13 MS BRISTOW: That looks more like the one I would have
14 expected.
15 MR GARNHAM: Thank you. That is called draft number 11 so
16 a reasonable bet is that that succeeds the one that
17 Mr Duncan has provided us with.
18 MS BRISTOW: Great.
19 MR GARNHAM: Thank you for that, that disposes of that
20 problem. Go on if you will in Mr Duncan's little bundle
21 three pages to a memorandum. It is a memorandum from
22 him to Anne Chan of the 21st June 2001. That is
23 a document you have seen before?
24 MS BRISTOW: I do not know.
25 MR GARNHAM: We have not been able to find it in our

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1 database in the time we have had but it may well be that
2 Miss Lawson's memory works faster than our database and
3 if it does -- no sarcasm intended -- and if it does then
4 doubtless she will tell us.
5 For the time being I wonder if you could help me
6 with this. He writes to Miss Chan at numbered
7 paragraph 1 there:
8 "For some time we had been waiting for the workload
9 waiting system that properly recognises ..."
10 And then four different factors.
11 "Anne says that the caseload monitoring policy is
12 not a recognition of workload waiting, merely a numbers
13 exercise."
14 This rather picks up what I was suggesting to you
15 earlier that the caseload monitoring policy was simply
16 a numbers game and was not looking at the quality of the
17 work that had to be done. What do you say to that?
18 MS BRISTOW: There have been considerable work, as
19 I understand it, in the department, trying to arrive at
20 the workload waiting system that could gain support and
21 it was proving impossible and we were getting nowhere
22 fast. We therefore had some inquiries about what other
23 people did, other authorities, other social work
24 agencies, and in reality we came to the conclusion that
25 what most people had was a monitoring tool, and that

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1 what it should be used as is as a tool, like other
2 tools, and not slavishly followed.
3 MR GARNHAM: I see. Over the page Mr Duncan describes the
4 caseload monitoring system, at the end of paragraph 3,
5 as:
6 "... a missed opportunity. A caseload monitoring
7 system ignores all of this [that is already said above]
8 and I think this was a missed opportunity."
9 You presumably disagree. It is the best that could
10 be devised. End of paragraph 3.
11 MS BRISTOW: I think we were faced with a choice of looking
12 at what other authorities found a workable way forward
13 and implementing it in the foreseeable future or chasing
14 a holy grail of the workload waiting system that, in
15 what I understood was some 15 months, no-one had
16 actually managed to finalise. I believe myself to be
17 pragmatic and I felt we should move forward with
18 something that would give my managers a tool to work
19 with.
20 MR GARNHAM: He asks in the last paragraph of that memo for
21 reconsideration of the system to include a proper
22 workload waiting system that recognises the new demands
23 made on social workers generally and the special demands
24 on Haringey social workers at such a difficult time
25 particularly. Was anything done about that?

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1 MS BRISTOW: I understand there were some discussions with
2 him.
3 MR GARNHAM: Which did not affect or did affect the
4 resulting system?
5 MS BRISTOW: As you can see from the papers we have had
6 here, there were a series of refinements and amendments
7 to the system as it went through the summer and what was
8 said as it was put in we would keep it under review, and
9 it if it was not proving to be a useful tool clearly we
10 would need to think again.
11 My understanding is it is proving to be a useful
12 tool to have some equity between teams, but as ever, and
13 I am sure you have seen in other statements I have made
14 elsewhere, I have always been of the view that it is
15 only a tool and if you get into a numbers game -- now
16 I do not believe that the embryonic work that had been
17 done about the workload waiting system as I think it was
18 described was any less problematic, but because you have
19 to exercise judgment.
20 MR GARNHAM: Can I just ask you in that context what the
21 position is now? What is the average caseload of social
22 workers in the children's team at Haringey now?
23 MS BRISTOW: That is set out in the letter we looked at
24 early today that I wrote to Mr Lewington.
25 MR GARNHAM: Do you remember offhand what it is?

220
1 MS BRISTOW: I have to say I am getting a little tired and
2 things I could remember first thing this morning
3 I cannot remember, sorry.
4 MR GARNHAM: Then you must have the letter. Is it no longer
5 in front of you?
6 MS BRISTOW: No.
7 MR GARNHAM: It has been brought to you. Look at that and
8 see if you can give me an answer.
9 MS BRISTOW: On the second page, what we are saying there
10 is -- which is what I checked -- sorry, perhaps if
11 I find the right page.
12 I do not think from the information that I have
13 written in the letter it gives what I would accurately
14 describe as an average, which obviously has a specific
15 definition, either a median or mean, and that is not
16 what I have put in the letter, I have put examples. It
17 is information I could supply the Inquiry with, but I do
18 not have with me.
19 MR GARNHAM: It would be helpful and perhaps I could get you
20 to do that before we finish.
21 Last matter please Ms Bristow. Were you present at
22 a meeting called to discuss how you and other agencies
23 were going to deal with this Inquiry?
24 MS BRISTOW: I was present at some meetings that took place,
25 yes.

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1 MR GARNHAM: Could you be shown 45H, please.
2 MS BRISTOW: I am not sure that is how I would describe the
3 meetings but no doubt we can explore that in a moment.
4 MR GARNHAM: 45H, a letter addressed to Mr Meehan and
5 Mr Warwick, Leader and Chief Executive of your Council,
6 signed by six NHS managers, including --
7 THE CHAIRMAN: The page, please?
8 MR GARNHAM: So sorry, sir, 208.303. My apologies. These
9 officers write in this letter, 2nd October this year, in
10 the first paragraph:
11 "We are writing to raise with you our early concerns
12 about the handling of the opening days of the Victoria
13 Climbie Inquiry.
14 "Our understanding in detailed discussions had
15 always been that we would take a joint and positive
16 approach to the Inquiry, which would be based on all of
17 us being willing to learn lessons from our experience of
18 the Victoria Climbie case. It would not in any way
19 involve us attacking or blaming each other for mistakes
20 made."
21 That appears to refer to discussions that had taken
22 place. Were you party to those discussions?
23 MS BRISTOW: It refers to discussions but the discussions
24 were not in my view about those matters and I would be
25 happy to explain to you what discussions I have taken

222
1 place in.
2 MR GARNHAM: Yes, please.
3 MS BRISTOW: Prior to the end of the murder trial I met with
4 colleagues in both the NHS and the police about how we
5 would handle the likely media interest at the end of the
6 trial. In particular we dealt with practical
7 arrangements such as the fact that the Metropolitan
8 Police would host it with the assistance of City London
9 police at Snow Hill Police Station, because of its
10 proximity to the Central Criminal Court, and how we
11 would deal with that. There were some discussions prior
12 to that, whether or not we would issue a joint press
13 statement between all the agencies --
14 MR GARNHAM: I am going to interrupt you only because of
15 time going on. What I am interested in is were there
16 any discussions in relation to this?
17 MS BRISTOW: I think it is germane, which is why I say this,
18 but I will be quicker if you like. There were
19 discussions at the end of the trial. After that there
20 were other discussions and I believe we have supplied
21 the Inquiry with the minutes of that meeting because
22 there were two things that seemed to us important. One,
23 we needed -- as senior managers in those organisations,
24 we needed to be satisfied that we were moving forward
25 and making the necessary improvements and not simply

223
1 leave it to more junior staff. Secondly, that it was
2 apparent to us at that stage that there would be
3 inevitable tensions arising from the evidence likely to
4 be put before the Inquiry.
5 I say that because having looked at the information
6 emerging on the Part 8, it was clear that staff both
7 within agencies and across agencies were contradicting
8 each other about their -- and I think that has been
9 borne out in the evidence given to you.
10 MR GARNHAM: So what was the tenor of the discussions?
11 MS BRISTOW: So the tenor of the discussion was that in the
12 hearing now we are charged with delivering services both
13 for children and adults and older people and we must
14 work in partnership across the agencies and irrespective
15 of the tensions, irrespective of the difficulties, we
16 have to maintain those working relationships and build
17 on them and that it would at times get sticky, we
18 thought. I think that has been borne out in the case.
19 So that was the tenor of it. Not about --
20 MR GARNHAM: What was the agreement?
21 MS BRISTOW: That we would try not to, for example, issue
22 press releases without another party knowing it or if we
23 did have to respond to a press inquiry we had during the
24 inquiry, as a very minimum we would put on the other
25 agencies' press offices' faxes at the same time we sent

224
1 it out to the media, that we would keep in touch with
2 one another and try and make sure that it was not
3 affecting service delivery on the ground.
4 At no time were we saying it would compromise the
5 information that was given by anybody to this Inquiry.
6 That was in no-one's interest. So I thought that what
7 we were seeking to do was have that.
8 Now there was some discussions, for example the week
9 before the Inquiry opened, about whether people were
10 making opening statements or not. For example, I think
11 an example of how it was an information sharing rather
12 than an influencing discussion earlier that week, I was
13 told by a representative for the NHS the NHS would not
14 make an opening statement, but as we know, they chose to
15 do so, as is their right.
16 So that is what I thought we were doing, which was
17 to try and drive forward the improvement agenda and
18 maintain good working relationships in what was
19 undoubtedly going to be a very public and difficult
20 period in our history.
21 MR GARNHAM: One thing that matters in this is: was there
22 ever any attempt by anyone to influence the evidence
23 that was adduced to this Inquiry?
24 MS BRISTOW: No.
25 MR GARNHAM: Was there any attempt to influence the way in

225
1 which either or any of the parties put their "case" to
2 this Inquiry?
3 MS BRISTOW: I was not party to any such.
4 MR GARNHAM: Sir, thank you. That is all the questions
5 I have of this witness. It is now 4.04. We had
6 indicated that we would play the Manning video at
7 4 o'clock. I know that you, sir, and we too, wish to do
8 that. I am conscious of the fact that that is going to
9 inconvenience Ms Bristow a little but I am going to beg
10 her indulgence and to impose that inconvenience and
11 invite her to come back on Friday.
12 I understand she is due to be in an employment
13 tribunal for an unrelated matter, and it is clearly
14 going to be awkward for her to manage the two. In those
15 circumstances sir, I invite you to direct that she
16 returns here on Friday and then the Solicitor to the
17 Inquiry can write a letter which can be sent to the
18 Chairman of the employment tribunal indicating that it
19 is not Miss Bristow's fault that she is unable to be
20 there on Friday morning but that she is complying with
21 an instruction from you.
22 THE CHAIRMAN: Thank you. Miss Lawson?
23 MISS LAWSON: Sir, if it will help Ms Bristow I am not
24 trying to prevent you from doing that but I am
25 wondering, as I understand it on Friday we have

226
1 Mr Wheeler who is coming back to complete his evidence,
2 we also have Mr Duncan coming back who I know has to be
3 in Cambridge in the afternoon. I am therefore just
4 wondering whether it is sensible to arrange for
5 Ms Bristow to come back at 12 o'clock or whatever rather
6 than having them all here at 10.30.
7 THE CHAIRMAN: I do not want to be unreasonable, but I am
8 interested in what is best for the Inquiry. I was not
9 meaning to imply you were doing anything other than
10 being helpful Miss Lawson. Never would I.
11 MR GARNHAM: I have now finished with this witness. You
12 will have some questions and so will Miss Lawson but
13 I would invite you sir to direct that this happens in
14 the ordinary course, that we continue with Ms Bristow at
15 9.30 on Friday morning, we then take Mr Duncan who
16 I anticipate will not be very long and then we move on
17 to finish Mr Wheeler. I think we would get through all
18 of those in the day.
19 THE CHAIRMAN: Miss Lawson, I think in fairness to you, and
20 I believe in fairness to Ms Bristow and certainly in
21 fairness to me, if I may say so, I would prefer to carry
22 on where we are leaving off and so I think I am content
23 to take the responsibility, Ms Bristow, and it would be
24 my decision, and if there are any criticisms of your not
25 being available elsewhere, it is down to me and we will

227
1 continue your evidence at 9.30 on Friday morning.
2 MISS LAWSON: Sir, there is another complication and that is
3 this. We have a pre-arranged meeting tomorrow evening
4 with a number of members of Haringey Council to consider
5 what we might say in our closing submissions of which it
6 was originally planned Ms Bristow would be part. I am
7 not sure whether that is something which -- whether she
8 should continue to be part of that or what --
9 MR GARNHAM: Sir, I see no difficulty with that. I am
10 confident we can trust that Ms Bristow and Miss Lawson
11 will not include in their conference any discussion of
12 Ms Bristow's evidence, but she could take part in the
13 rest of the meeting.
14 THE CHAIRMAN: I have every confidence in that. Thank you
15 for mentioning it, Miss Lawson.
16 Now, ladies and gentlemen, we will be moving on to
17 hear the evidence from Mr Manning. But before we hear
18 that evidence, there is something that I need to say.
19 I have not seen the tape that we are all going to
20 see now, but I have been advised that the quality of the
21 recording is not up to the high standard that the
22 Inquiry expects. In particular, the picture on the tape
23 is a good deal less than perfect. Manning's evidence
24 was recorded from Leeds Combined Court by the
25 international IT company ICL. Regretfully, they did not

228
1 ensure that the tape recording was faultless. Earlier
2 this week the secretary to the Inquiry invited ICL's
3 project manager into our offices so that we could
4 express our displeasure. The company -- which I have to
5 say successfully conducted the video conferencing from
6 other witnesses who gave evidence via videolink and some
7 from considerable distances in South Africa and
8 New Zealand -- has subsequently given us a full and
9 frank apology, which I have with me from ICL.
10 (Indicates)
11 To ensure that everyone is able to follow Manning's
12 evidence without any difficulty, I have directed that
13 a transcript of his testimony be prepared and as soon as
14 we start to play the tape, it will be made available to
15 all of those who want it. This transcript will be
16 treated as a working draft. Smith Bernal, who have been
17 very helpful, will produce a final version, having
18 listened to the tape as it is played today and it is
19 that final version which will be published on our
20 website in the usual way. I can only say that I am
21 sorry that the quality is not as I would have expected
22 and has been the case in all the other ones that we have
23 done, but I am sure that the transcript will be
24 enormously helpful to us all. Thank you. I think, in
25 fairness that should be distributed.

229
1 (4.10 pm)
2 (Video evidence of CARL MANNING)
3 THE CHAIRMAN: -- in public, and so the video will be shown
4 in due course in public.
5 MR MANNING: I am about to see my ugly mug on television, am
6 I?
7 THE CHAIRMAN: Not necessarily. What we are committed to is
8 to have all of the evidence that whoever gives the
9 evidence to be actually given in the public hearing
10 room, and when I say public it means that the written
11 press and members of the public can be there. I will
12 deal with the television issue at the end of this
13 hearing but the purpose of this video is for your
14 evidence to be given in the public room, all right?
15 As we have got a moment, Mr Manning, and want to be
16 as fair as possible to you, I have received an
17 application from a broadcasting organisation to have the
18 tape of this made available after it is given as
19 evidence to the Inquiry, not today, but when it is given
20 to the Inquiry in a few days' time. I have not made up
21 my mind about that because I have not actually heard the
22 application but at the end of this hearing today -- at
23 the end of this recording rather, I will ask you whether
24 you have any views on this subject but I ought to let
25 you know that somebody has made an application for that

230
1 but that is a separate issue from the evidence you are
2 giving to the Inquiry. Do you understand that?
3 MR MANNING: I do understand but do I have a final say or is
4 it taken off my hands by you?
5 THE CHAIRMAN: No, I have the final say but I will only have
6 the final say as it were after I have heard your opinion
7 on the subject and I would attach significance to your
8 opinion, but let me deal with the issue of that
9 separately at the end of -- when you have finished
10 answering Mr Sheldon's questions, is that all right?
11 MR MANNING: Okay, yes.
12 THE CHAIRMAN: Just so that you are clear, at the present
13 time this video will be presented in the hearing room of
14 the Inquiry in a few days' time as if you were
15 personally sitting in the hearing room and the process
16 that we are going through now is the process that we
17 would be going through if you were sitting in the
18 hearing room and not where you are today. So that will
19 be shown and then it will become evidence to the Inquiry
20 in a technical sense.
21 The issue about whether or not the tape of it could
22 be shown more widely is a matter that I will discuss
23 with you when you have finished giving your evidence.
24 MR MANNING: Can I ask you something again my Lord?
25 THE CHAIRMAN: Of course.

231
1 MR MANNING: My evidence is being recorded or has everyone
2 who has given evidence in the room, has their evidence
3 been recorded as well?
4 THE CHAIRMAN: Yes, everyone else has had their evidence
5 recorded and all of the evidence that we have had so far
6 has been put upon the Internet on our website if you
7 know what I mean, so that everybody could follow the
8 evidence, because it is a public Inquiry, so your
9 evidence is going to be treated in exactly the same way
10 as everybody else, other than this application that
11 I will discuss with you at the end.
12 MR MANNING: Fair enough.
13 THE CHAIRMAN: Are you okay about that? Are you clear about
14 that?
15 MR MANNING: I am clear. It makes more sense, yes.
16 THE CHAIRMAN: Okay. Right, Mr Manning, just so that I am
17 absolutely clear and you are absolutely clear, most of
18 the people who have come to give evidence to the Inquiry
19 have come in person. You know, they have come into the
20 room where the public are and where the media are free
21 to come and they have sat down and they have answered
22 the questions in the room. But I think for four people
23 or maybe you are the fifth person, if my memory serves
24 me right, we have recorded the evidence and then what we
25 have done is shown the tape at a later day and then when

232
1 the tape is shown that is when their evidence is
2 evidence to the Inquiry. Do you understand that? Have
3 I made it clear?
4 MR MANNING: It is clear enough, yes, thank you.
5 THE CHAIRMAN: Thank you very much. When we get to the end
6 I will talk about the other issue with you. I will go
7 through what the implications might be with you. All
8 right?
9 Can I just ask, are we okay now? Did we get the
10 beginning all right? Do you want to start again?
11 Mr Manning I am terribly sorry to have to ask you
12 this but there was a slight technical problem at the
13 beginning of the tape so I think in fairness to you and
14 everybody else we will actually begin again and so it
15 will mean Mr Sheldon repeating the questions that you
16 have already had. If you want a pencil to write
17 anything down, and if you need anything else just let us
18 know. All right?
19 MR MANNING: Okay sir, thank you.
20 THE CHAIRMAN: So Mr Manning we will begin again. Can
21 I remind you that you have already taken the oath so
22 that you have sworn to tell the truth and nothing but
23 the truth, all right?
24 MR MANNING: Okay.
25 THE CHAIRMAN: Thank you very much. I will ask Mr Sheldon

233
1 to begin again so there will be a repetition of the
2 earlier questions.
3 MR SHELDON: Mr Manning can I get you first of all to turn
4 back to the last page of your statement that we looked
5 at earlier and just confirm that it is still your
6 signature at the bottom of that page?
7 MR MANNING: It is, yes.
8 MR SHELDON: And you are happy, are you, that the facts and
9 matters in that statement are true to the best of your
10 knowledge and belief?
11 MR MANNING: I am, yes.
12 MR SHELDON: Thank you. I will explain again for your
13 benefit and for the benefit of the tape the purpose of
14 today's questions. The matters with which the Inquiry
15 is concerned are the services which Victoria and those
16 caring for her were provided by health authorities,
17 social services departments and the police. We are not
18 concerned with whether or not you committed the crimes
19 for which you are convicted, nor are we concerned with
20 your private life or your relationship with
21 Marie-Therese except insofar as it is relevant to those
22 issues, namely the services provided; is that clear?
23 MR MANNING: Yes, it is.
24 MR SHELDON: I should also remind you that Lord Laming has
25 powers given to him by Parliament to require anybody to

234
1 come and give evidence before him to this Inquiry and
2 that a refusal to give evidence as required is
3 a criminal offence for which he or she can be
4 prosecuted. Do you understand that?
5 MR MANNING: I understand that but I did not have that
6 right, I was told that I had to come in.
7 MR SHELDON: Well, that is right, you are legally obliged to
8 do so.
9 MR MANNING: It is different what you said to my
10 understanding, but carry on.
11 MR SHELDON: Throughout the time that you were in contact
12 with Victoria and that you knew Victoria you were living
13 at 267 Somerset Gardens, is that right?
14 MR MANNING: Yes.
15 MR SHELDON: And that was your own flat that you bought
16 in November 1998, is that right?
17 MR MANNING: Yes.
18 MR SHELDON: It was a studio flat and it had a separate
19 bathroom, correct?
20 MR MANNING: That is right and separate kitchen, yes.
21 MR SHELDON: I see and that you took some care to make sure
22 that the flat was neat and tidy and clean?
23 MR MANNING: That is right, I done my best, yes.
24 MR SHELDON: And in that sense you were reasonably house
25 proud it is fair to say, is that right?

235
1 MR MANNING: Yes.
2 MR SHELDON: I would like you to comment now on the state of
3 the accommodation that Victoria and Kouao were living in
4 in Nicoll Road. You went along to the hostel they were
5 living in on more than one occasion, is that right?
6 MR MANNING: Yes.
7 MR SHELDON: I would like first of all for you to comment on
8 how clean you found that building to be.
9 MR MANNING: The room was liveable, yes, it was not like
10 there was rubbish all over the place and Marie did her
11 best to keep it as clean as possible, so it was
12 liveable, yes.
13 MR SHELDON: What were the washing facilities like?
14 MR MANNING: They were WC and bathroom were shared and the
15 room was just a normal room with a washing facility,
16 a sink and that was it.
17 MR SHELDON: I see. Did you think that it was suitable for
18 a woman and a young girl to live in?
19 MR MANNING: It was small and her hope was eventually to
20 move out, so no, it was not suitable.
21 MR SHELDON: Did you come into contact with any of the other
22 people that lived in that particular hostel?
23 MR MANNING: Only in passing along the public stairway when
24 I was going up to Marie's room.
25 MR SHELDON: I see. What sort of people lived there?

236
1 MR MANNING: Just, you know, walking past, did not really
2 get to talk.
3 MR SHELDON: There came a time when it was suggested that
4 Marie-Therese and Victoria came to live with you in
5 Somerset Gardens, is that right?
6 MR MANNING: It was suggested, yes.
7 MR SHELDON: Did you make that suggestion?
8 MR MANNING: I did, yes.
9 MR SHELDON: And was that because you thought that their
10 present accommodation was unsuitable and they needed to
11 go somewhere better?
12 MR MANNING: Yes, yes.
13 MR SHELDON: And is it right that the two of them moved in
14 with you on the 6th July 1999? That was the date you
15 gave at the trial.
16 MR MANNING: Yes, about then, yes, it was proven at the
17 trial it was that date.
18 MR SHELDON: I realise that it is going to be difficult to
19 be precise about this question but I need to get your
20 help with when Victoria started to soil herself as
21 opposed to just wet herself, do you understand what
22 I mean?
23 MR MANNING: I do, yes.
24 MR SHELDON: Now, as I understand your evidence at the trial
25 and what you said at interview, Victoria used to wet

237
1 herself fairly regularly, pretty much from the start of
2 the time she lived with you at Somerset Gardens, is that
3 right?
4 MR MANNING: Yes.
5 MR SHELDON: But there came a point when she started to soil
6 herself as well, is that right?
7 MR MANNING: From memory, yes.
8 MR SHELDON: Can you remember when that was?
9 MR MANNING: The exact date offhand, no, I cannot. I cannot
10 remember if it was by the end of July or early August
11 but in between that -- I know she was in hospital as
12 well over that period, but I would say definitely by the
13 end of August.
14 MR SHELDON: You said in your evidence at trial that you
15 started to put Victoria in the bath in about October of
16 1999, is that right?
17 MR MANNING: Yes, can I ask you something please?
18 MR SHELDON: Yes, certainly.
19 MR MANNING: I can understand you asking the questions but
20 you are looking specifically at my relationship with the
21 health service, with the police and with social
22 services.
23 MR SHELDON: Yes.
24 MR MANNING: And now we are going over the horrible
25 situation in which everything was happening and the

238
1 conditions --
2 MR SHELDON: I will explain the purpose of the question in
3 that case Mr Manning.
4 MR MANNING: Please do.
5 MR SHELDON: One of the things that the Inquiry is concerned
6 to know is what people like doctors and nurses and
7 social workers should have been aware of when they came
8 into contact with Victoria.
9 MR MANNING: The tell-tale signs?
10 MR SHELDON: Exactly, things like tell-tale signs. Now, in
11 order to be able to make an assessment of that it will
12 be necessary for the Inquiry to form a view of the
13 condition that Victoria was in at the various stages she
14 came into contact with those people, social workers,
15 doctors and so on. Now, as I said at the outset, I am
16 not interested in rehearsing what you did to Victoria or
17 the crimes of which you were accused. All I am trying
18 to do is to understand when Victoria started to become
19 incontinent so that the Inquiry knows what state she was
20 in at the various stages that people came into contact
21 with her. Is that clear?
22 MR MANNING: That is true, but Mr Sheldon in all fairness
23 you have access to the trial notes, you have access to
24 my police interviews, you even have the statement I have
25 given to the Inquiry. You have all these facts on you

239
1 already. I do not have these facts at my disposal so
2 I can only go on what you have -- what you have got
3 already, so I am not in a position to contradict what
4 I have said already, am I?
5 MR SHELDON: No, but in none of those --
6 MR MANNING: You know the answers already, do you not, sir?
7 MR SHELDON: In none of that material Mr Manning do you say,
8 and this is the point that I am concerned with at the
9 moment, when Victoria started to soil herself.
10 MR MANNING: I did not say that at the trial at all.
11 MR SHELDON: No you did not.
12 MR MANNING: I was not asked at all. This is not --
13 MR SHELDON: I realise it is difficult to be precise about
14 that so I am wondering if we can work it out by some of
15 the other information that you have given. Now, for
16 example, you said in your interview to the police that
17 you threw the sofabed away that Victoria was sleeping on
18 in October 1999. Now, is that because the sofabed had
19 become unusable because Victoria had been soiling
20 herself on it?
21 MR MANNING: That was the reason, yes. It was ridden
22 through with urine, it was ridden through with her
23 faeces as well. We tried to clean it every day but it
24 was very unbearable so it was thrown away in October.
25 MR SHELDON: We know for example from that that she must

240
1 have started to soil herself at night at least
2 before October, because that is when the bed was thrown
3 away; is that right?
4 MR MANNING: Yes.
5 MR SHELDON: Did you ever tell social services that Victoria
6 was soiling herself?
7 MR MANNING: Me personally, no, because I did not have much
8 involvement with social services myself. All the times
9 I was there was with Marie and Victoria and Marie did
10 all the talking, so me personally I did not say, no.
11 MR SHELDON: Do you remember Marie telling social services
12 that Victoria had that problem?
13 MR MANNING: She probably did because she told everybody.
14 MR SHELDON: Did you ever think that that might be a medical
15 problem for which Victoria might need some help?
16 MR MANNING: At the time or now?
17 MR SHELDON: At the time.
18 MR MANNING: (Pause). Can I -- sorry about the delay.
19 MR SHELDON: That is all right.
20 MR MANNING: It is just my actions at the time do not seem
21 ones of a person thinking logically and it is hard to
22 recall my state of mind at the time.
23 MR SHELDON: I am sure it must be. Did you ever suggest for
24 example to Marie that she should take Victoria to see
25 a doctor?

241
1 MR MANNING: I did not suggest to Marie personally, no.
2 Marie did all her thinking for herself.
3 MR SHELDON: As I understand it there is a health centre
4 just a few yards away from your flat in Somerset
5 Gardens.
6 MR MANNING: That is right, family clinic.
7 MR SHELDON: You were registered there, were you not?
8 MR MANNING: I was, yes.
9 MR SHELDON: Was Marie registered there too?
10 MR MANNING: She was, yes.
11 MR SHELDON: But Victoria was never taken there as far as
12 you are aware, was she?
13 MR MANNING: She was registered there as well but she was
14 not taken there to see a doctor to my memory, no.
15 MR SHELDON: I see. I want to turn now, Mr Manning, to the
16 home visits that were carried out by social services to
17 your flat. Now, at paragraph 13 and 14 of your
18 statement, which I think you have in front of you, you
19 record your recollection of a home visit carried out on
20 28th October 1999. Do you see that?
21 MR MANNING: Yes.
22 MR SHELDON: You say at paragraph 14 that that was the only
23 time that social services or the police visited your
24 flat. Is that the best of your recollection?
25 MR MANNING: That might have been correct. It was another

242
1 occasion as well.
2 MR SHELDON: Yes, because Lisa Arthurworrey --
3 MR MANNING: The first time -- I was only present at two.
4 The first time was in August and this one I referred to
5 was the second and last one.
6 MR SHELDON: Thank you very much, I was wondering about that
7 because Lisa Arthurworrey -- sir for your note it is
8 volume 6, page 156 -- has a note of a visit she made to
9 you on 16th August 1999 and she has you down as being
10 present; so that would be right, would it not?
11 MR MANNING: Yes, she is correct there, yes, so yes.
12 MR SHELDON: If we deal with that visit first of all, before
13 the one you deal with in your statement,
14 Lisa Arthurworrey made some notes of what she was told
15 at that visit and one of the things she notes is that
16 you were described by Marie as an old friend of hers who
17 she met in France. Now, that is not true, is it?
18 MR MANNING: No, it is not true. It was proved at the trial
19 to be not true.
20 MR SHELDON: You met her on the number 18 bus in June 1999,
21 is that right?
22 MR MANNING: That is correct, that is right, yes.
23 MR SHELDON: Do you remember Marie giving that information
24 to Lisa Arthurworrey, that false information?
25 MR MANNING: I would say yes.

243
1 MR SHELDON: Lisa Arthurworrey also says that she was told
2 that you had a fiancee who used to live with you at
3 Somerset Gardens until Marie and Victoria came and then
4 she had moved out and that that was causing problems in
5 your relationship. That is not true either, is it?
6 MR MANNING: No, that was proven at the trial it is not
7 true, no.
8 MR SHELDON: You have never been engaged and the only lady
9 you were seeing at the time was Marie, was it not?
10 MR MANNING: That is correct, yes.
11 MR SHELDON: Do you remember Lisa Arthurworrey being told
12 that, the story about the fiancee?
13 MR MANNING: She was told that, yes.
14 MR SHELDON: What was the point of the story about the
15 fiancee?
16 MR MANNING: At the same time -- as I said at the trial
17 I believe, at the same time as moving in, I believe
18 applications were made for housing with Haringey and the
19 whole purpose of moving in, it was seen as a situation
20 to help and get away from Nicoll Road, was to make
21 application for housing, so that was used as a means of
22 proving that the accommodation at Somerset Gardens was
23 too small and to help her application for housing.
24 MR SHELDON: I see. It was too small because there was
25 a fiancee that wanted to live there as well?

244
1 MR MANNING: Yes, she was trying to use that as a means of
2 helping her application for housing.
3 MR SHELDON: I see. Can I show you a document now
4 Mr Manning which is a letter dated 29th July 1999. It
5 will be put up on the screen.
6 MR MANNING: Okay.
7 MR SHELDON: Can you see that?
8 MR MANNING: Can you make it a bit clearer?
9 MR SHELDON: We will have a go.
10 MR MANNING: I can see the gist of it but I cannot read it
11 clearly.
12 MR SHELDON: No.
13 MR MANNING: I can see -- I recognise the handwriting, it is
14 my handwriting.
15 MR SHELDON: Is it your handwriting?
16 MR MANNING: Yes.
17 MR SHELDON: In that letter, and we do not need to go
18 through it in detail especially if you cannot read it
19 clearly, you mention again that you have a fiancee who
20 is not happy about the fact that Marie and Victoria are
21 living in your flat. Do you remember writing that
22 letter?
23 MR MANNING: I remember it, yes, it is my handwriting, so
24 I do not dispute it is my handwriting.
25 MR SHELDON: Was it ever sent, do you know?

245
1 MR MANNING: From memory, yes, it was.
2 MR SHELDON: And the purpose of it again was to help speed
3 up Marie's housing application, was it?
4 MR MANNING: Yes, the letter was sent, it was particularly
5 made to the housing officers in Haringey.
6 MR SHELDON: Do you remember filling out some two housing
7 registration forms, two applications for housing to
8 social services on Marie's behalf?
9 MR MANNING: Yes.
10 MR SHELDON: One to Haringey and one to Brent, is that
11 right?
12 MR MANNING: That is right, yes.
13 MR SHELDON: Given that you remember, I will not put them up
14 on the screen but you were aware then presumably that
15 Marie was pursuing housing applications with two
16 different local authorities at the same time?
17 MR MANNING: That is to help her case, yes. The reason,
18 Brent was -- that is where she lived -- was in the
19 borough which was at Nicoll Road and Haringey is because
20 that is where I lived obviously.
21 MR SHELDON: You helped her with that presumably because
22 your English was better than hers, is that right?
23 MR MANNING: She wanted me to make the application so I made
24 it on her behalf, yes.
25 MR SHELDON: I see. In Lisa Arthurworrey's note of her

246
1 visit on 16th August, 1999, there is no record of you
2 saying anything during that visit. Do you remember
3 whether you had any conversation with Lisa Arthurworrey
4 or not?
5 MR MANNING: Not directly, no, nothing on my own basis, no.
6 Marie done all the talking I would say.
7 MR SHELDON: But you would have known, would you not,
8 because you were sitting there, that Lisa Arthurworrey
9 was being given misleading information, particularly
10 relevant to the housing application, by Marie?
11 MR MANNING: Fair enough, yes.
12 MR SHELDON: Do you remember whether your flat -- and
13 remember this is about a month after Victoria moved
14 in -- do you remember whether your flat smelt of either
15 urine or faeces or even bleach at that time when
16 Lisa~Arthurworrey came to visit in August?
17 MR MANNING: Offhand, now -- I imagine so, because bleach
18 was being used for cleaning with bleach, so there
19 probably would have been maybe a linger.
20 MR SHELDON: I see. There came a time, did there not, when
21 the problem with Victoria's incontinence meant that your
22 flat started to smell, is that right?
23 MR MANNING: Like I said, it was -- she was wetting herself
24 and faeces was being done, but it was being cleaned up,
25 so there would be the smell lingering around, yes. Does

247
1 that make sense?
2 MR SHELDON: It does but as you understand from the
3 explanation I gave earlier, what we are trying to
4 understand is what Lisa Arthurworrey in this instance
5 may have been aware of when she came to visit and do you
6 remember there being a particularly overpowering or
7 strong smell of bleach in your flat around about this
8 time?
9 MR MANNING: It was not overpowering. If it was
10 overpowering it would be pretty hard to live in but
11 things were being cleaned. I would not say it was
12 overpowering in the sense you go in there and it is
13 right up your nose, you know, you can actually let air
14 out, but you do your best to clean it up anyway.
15 MR SHELDON: I see, thank you.
16 MR MANNING: Okay.
17 MR SHELDON: Do you recall whether Victoria was given any
18 coaching on how to behave during that visit?
19 MR MANNING: Coaching, yes.
20 MR SHELDON: Did Marie say, "We have got a social worker
21 coming round and this is how you must behave when she is
22 here"?
23 MR MANNING: Marie, yes.
24 MR SHELDON: How was she told to behave?
25 MR MANNING: I do not know. I mean I imagine Lisa probably

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1 said what was said. There was nothing outstanding in
2 her behaviour, like, you know, like I said Marie done
3 most of the talking, I just sat there and just let it
4 carry on. I would not say it was anything like
5 particularly you got to say do this, do that, but you
6 know ...
7 MR SHELDON: Did Victoria behave herself well during the
8 visit?
9 MR MANNING: She behaved herself, yes, she did.
10 MR SHELDON: Would it be fair to say that the picture that
11 the social worker Lisa Arthurworrey would have got of
12 your household during the course of that visit in August
13 was that you were a respectable chap with a steady job
14 with your own home, your own fiancee and that you were
15 just helping Marie and Victoria out in the short-term
16 until they could get themselves sorted out? That was
17 the impression that was given?
18 MR MANNING: That is what I would say.
19 MR SHELDON: It is also fair to say you and Marie were
20 prepared to mislead Lisa Arthurworrey on this occasion
21 in the interests of helping Marie's housing application
22 along?
23 MR MANNING: That is fair enough to say, yes.
24 MR SHELDON: And you were happy to go along with the
25 pretence that you had a fiancee?

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1 MR MANNING: At that time, yes.
2 MR SHELDON: You were happy to pretend that you were going
3 to, or you were considering throwing Marie and Victoria
4 out because of the difficulties that their presence was
5 causing with your fiancee?
6 MR MANNING: That was the impression given, yes, but it did
7 not happen.
8 MR SHELDON: And the impression that was being given to
9 Lisa Arthurworrey during the course of that visit was
10 that Marie was a good and caring mother and Victoria was
11 a happy child?
12 MR MANNING: Yes, that is a fair enough assessment.
13 MR SHELDON: Let us move on now, Mr Manning, please, to the
14 second visit, the one you deal with in your statement,
15 which is in October. It is paragraph 13 and 14. Now,
16 that was a visit that was arranged by appointment, was
17 it not?
18 MR MANNING: Yes, they both were, yes.
19 MR SHELDON: Lisa Arthurworrey did not just turn up on your
20 doorstep as a surprise, she called ahead and said she
21 was coming?
22 MR MANNING: Prearranged, yes, that is right.
23 MR SHELDON: Now, at the trial you said that this visit,
24 looking back on it, and these are your words, was
25 a "put-up job". Do you remember saying that?

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1 MR MANNING: Words to that effect, yes.
2 MR SHELDON: What did you mean by that?
3 MR MANNING: It would have been similar to the first one in
4 the sense of they knew Lisa was coming around and Marie
5 was going to -- the point she was going to raise
6 basically regarding the application for housing. So not
7 a put-up job in the sense there was a call made for Lisa
8 to come round, I do not know how the booking was made
9 but it was, but in the sense of she was coming round and
10 what was going to be said.
11 MR SHELDON: I see. Was Victoria again told that she had to
12 behave herself when Lisa Arthurworrey came round?
13 MR MANNING: Yes, she always did, yes.
14 MR SHELDON: Was she told that she should say anything in
15 particular or behave in a certain way when Lisa was
16 there?
17 MR MANNING: All the time Lisa was there she was playing
18 contently with her doll. It was just at the end
19 something was said out of context but I could not say if
20 that was a put-up job to say it was said. It just
21 seemed strange at the time but it was said anyway.
22 MR SHELDON: I see. I cannot remember the exact words but
23 it was something like Victoria saying, "You don't
24 respect me, you don't respect my mum, you should give us
25 a house", is that right?

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