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   Pages 1 to 50 | Pages 51 to 100 | Pages101 to 150 | Pages 151 to 200 | Pages 201 to 250 | Pages 251 to 322

Archived Transcript for 30 January 2002: Pages 201 to 250


201



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?

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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

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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

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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

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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

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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

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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

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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

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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.

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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

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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.

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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

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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

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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

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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?

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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?

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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

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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

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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

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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

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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?

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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

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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.

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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?

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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?

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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

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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

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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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