A marathon directions hearing where the Chairman hears extension applications from dozens of non-police core participants seeking more time for witness statements and privacy redactions. The hearing reveals systemic issues with Epic disclosure system, unrealistic deadlines, and tensions between the inquiry's schedule and core participants' capacity to engage meaningfully.
00:21:27 e e
00:22:27 thank you Miss
00:22:37 Johnson so yes I addressed you in closed on certain matters relating to Helen steel which I don't propose to repeat but as part of that I made an
00:22:51 but as part of that I made an application for you to consider in her case extending the um deadline for privacy redactions from the 11th of April I'm instructed to make the same application on behalf of the core
00:23:10 application on behalf of the core participant known as Donna for the same reasons um I don't I don't think there is anything I can helpfully add in a closed session so I don't propose to go into one um but I I formally make that application for those reasons the final
00:23:27 application for those reasons the final matter upon which I wish to address you in open um was on the potential for um more than one statement in respect of Helen's deel and more than one deadline
00:23:41 Helen's deel and more than one deadline in respect of those statements I've been able to take um detailed instructions and discuss the matter in some depth with Miss steel over the short adment the risk of such a um such a
00:23:52 a um such a course is that the the in as the inquiry knows and and as Miss steel has been quite candid about short deadlines in her case can be counterproductive presenting a stressor that prevents her from effectively
00:24:03 that prevents her from effectively engaging her proposal um if I can put it as such but um I certainly don't want to be appearing to to barter but but a
00:24:18 be appearing to to barter but but a suggestion that that might um assist is for one deadline and and the deadline she seeks is the um 6th of June for all of her statements but with this um important and sincere assurance
00:24:33 important and sincere assurance that as soon as the first statement is complete it will be served and Mel wishes me to emphasize on her behalf that there is of course also a benefit to her of getting statements as it were off her plate um and out of her mind so
00:24:47 off her plate um and out of her mind so she no longer has to think about it but because there is so much um cross-pollination of material it it feels like it would be counterproductive to work on one and then another and then another and and because of the the
00:25:00 another and and because of the the reason that I've given regarding the counterproductivity in her particular case of the imposition of of shorter deadlines so in short so what I ask is
00:25:14 deadlines so in short so what I ask is is one deadline for misal of the sixth of June um with the assurance that as soon as anything is ready it it can be served it's hoped much much sooner than that
00:25:31 the deadline that you propose is both for privacy applications and witness statements is that right so yes so that um both matters can be worked on simultaneously preventing the
00:25:44 simultaneously preventing the duplicative reading of documents then um May I explain the position of the inquiry because I'm afraid that is not a workable
00:25:55 workable proposal um she has already had uh the uh documents in relation to uh relationship with dyes during his deployment and privacy redactions have already been applied uh to those documents by the inquiry there is no
00:26:10 documents by the inquiry there is no need to repeat the exercise she does not have anything to do about that the Privacy applications that the inquiry seeks and must have promptly is over the um operation muskat documents those
00:26:22 um operation muskat documents those which relate to her attempt to find dines after the relationship and his deployment ended um and uh I'm afraid to say that
00:26:34 um and uh I'm afraid to say that uh the from the point of view of the inquiry it is far more important that uh she makes her privacy applications in relation to the operation muskat
00:26:46 relation to the operation muskat documents if she wishes to rather than leave it to the inquiry by the 11th of April so um this is an option which you
00:27:03 April so um this is an option which you may need to talk to her about before we wrap things up for good today but um the that is a deadline which for reasons of running the inquiry um simply cannot be shifted
00:27:18 shifted um as far as the uh uh suggestion about witness statements go um I will need to go back and uh speak to my team about the uh dates that you have proposed but it
00:27:34 but it would I suspect be easier for her and it would certainly resist the inquiry more if we were to have her witness statement about her relationship with dyes
00:27:46 dyes um separately if she wants to do it separately from the witness statement relation relating to operation Muscat um
00:28:11 what I think however you need to speak to her about and um I need to speak to my team about are the uh uh the the Privacy
00:28:20 Privacy deadlines um and so I will um rise from a short while to both of us to do that um what you said about Donna mlan requires me to go back to my team as well because the same difficulties AR as there and um I I need to know what
00:28:40 I I need to know what the the informed answer is thank you sir I'm grateful so I will rise then for a short time and we'll resume uh with these issues when I've done
00:28:57 setting
00:37:26 e e
00:38:24 say Yes
00:38:29 Yes um now first of all deal with uh Helen Steel's position um the inquiry I'm afraid is inflexible about the deadline for making uh applications for privacy
00:38:41 for making uh applications for privacy over documents disclosed to her by the inquiry the alternative to her not putting in her applications by the 11th of April is of course that the inquiry will do the job itself but uh it
00:38:58 will do the job itself but uh it must the position must be that either we receive her privacy applications uh by the 11th of April or uh the inquiry will do it uh
00:39:12 April or uh the inquiry will do it uh itself as far as the time for witness statements is concerned uh what You' said is welcomed and accepted as constructive uh we I agree that she
00:39:23 constructive uh we I agree that she should have until the 6th of June to provide uh Witness statements uh if she can provide them in succession so that there's an earlier one earlier well and good but
00:39:38 earlier one earlier well and good but the inquiry could if it came to a push live with getting them all on one day but it obviously it would assist as I'm sure she would appreciate if if she is going to produce two if we had them
00:39:55 going to produce two if we had them successively one earlier than thank you sir uh as far as Don mlan goes uh I'm afraid the position about privacy applications is the same namely that they must be made if they're going to be made by her by the 11th of April the
00:40:06 made by her by the 11th of April the alternative is that the inquiry will do it itself if she wants the inquiry to do the Privacy applications uh uh rather than put her to the trouble of um uh attempting to do it
00:40:24 the trouble of um uh attempting to do it uh then if she lets us know soon um then we can put her mind at rest and the inquiry will be able to to get on with the
00:40:34 the task the same goes for both of course if Helen steel wants to do that as well as far as the um time for her witness statement goes uh I acknowledge that the factors which you of which you spoke in
00:40:47 factors which you of which you spoke in the private session are powerful and uh uh I will extend the time for her witness statement until the 16th of May thank you sir
00:41:21 now I think that leaves um your three other uh submissions ises it not um I and forgive me if I've if I've overlooked the fact that you've made them and and uh Mass are now determined but if you want the opportunity to make further open
00:41:34 opportunity to make further open submissions about them you can that's uh Wadsworth Ruth and Rosa uh sir no um I have no further
00:41:48 Rosa uh sir no um I have no further submissions to make about Ruth and Rosa in open yes I made submissions about woodsworth in open before the short adjournment yes you did missions to make
00:42:19 I thought there was a problem which I had not understood about uh Wadsworth um I I know that that there's I'm well aware of what you've told me in in private but I'm far from sure I have
00:42:31 in private but I'm far from sure I have understood the um the open issues there and if he would be kind enough to remind me of what they are I'd be grateful of course that um and I think I perhaps
00:42:43 course that um and I think I perhaps have been of as much assistance as I might ordinarily be I I was briefed very lately for for today's hearing as you know the um his witness D is currently
00:42:56 know the um his witness D is currently due by the 31st of March the sort is to the 7th of May um the situation with Mr woodsworth as I understand it is that he
00:43:12 woodsworth as I understand it is that he has only been provided with documents in which he is specifically named yes um he has not been provided with documents that name his organization that is to say the anti-racist alliance which he believes are relevant to him
00:43:25 which he believes are relevant to him and of course I understand that the the the position of the inquiry is that um such documents as are disclosed are all of those that are deemed disclosable but in his case he has been seeking assurances since the 5th of February
00:43:37 assurances since the 5th of February that those documents that pertain to the anti-racist alliance are not relevant to him um he's he's had no such assurances the the last letter sent by those who
00:43:48 the the last letter sent by those who instruct me received no response so the matter remains unresolved there was also a secondary smaller issue that he sought legible copies of three pages of of
00:44:00 legible copies of three pages of of particular documents that have been provided to him and that that repeated request has also um gone
00:44:10 unanswered then I'm afraid I'm going to have to rise to deal very briefly with those with my team because I hadn't got them fully in mind when I spoke about the other matters as far as um Rosa is
00:44:22 the other matters as far as um Rosa is concerned um by reason of the matters of which you've uh submitted made submissions in private there is no deadline of any kind for uh her witness statement if she wishes to provide one
00:44:33 statement if she wishes to provide one the inquiry will gratefully receive it uh whenever it arrives um as far as Ruth goes uh the uh time for uh her to
00:44:47 goes uh the uh time for uh her to provide um uh a witness statement is extended until uh the 2nd of May thank you sir and I will rise again very briefly to deal with the uh the
00:45:02 very briefly to deal with the uh the question which I fear this is my fault I didn't have properly and fully in mind give me a moment or
00:45:25 two
00:47:55 e e
00:48:32 thank you again Miss Johnson thank you sir um wodsworth uh the documents that have been provided do include those that are illegible I agree um we have not got a more legible
00:48:48 agree um we have not got a more legible Copy Printing them out I'm told does not make any difference so I'm afraid that uh Mr wodsworth has got um what we can
00:48:59 uh Mr wodsworth has got um what we can provide him with as far as AR documents it's not intended to serve any AR documents on him
00:49:08 um if and when the issue arises he can put in a supplemental statement about that but from our for our part I don't think we anticipate there' be any need for that I would extend the time for production of the statement requested to
00:49:25 production of the statement requested to Thursday the 17th of April that's Easter Thursday thank you sir
00:49:33 does that now conclude uh all of uh your plants almost hesitant to jinx it by saying so but I believe it does so yes um just let me check a
00:50:02 moment so do we wish to confirm the position with n Douglas n Douglas is the one I was just looking by notes Mr Johson n Douglas
00:50:03 Douglas um as I understand the position is he's um asked for and the inquiry
00:50:19 is he's um asked for and the inquiry have agreed an extension of time but you haven't addressed it and is it for that reason um so I don't have any instructions I'm I'm receiving some as we speak if you a moment
00:50:36 um So the instructions that are coming to me are that um I I don't have instructions um so um I I I hesitate to ask again but in the event that I received some during
00:50:48 the event that I received some during the course of this hearing um may I ask to address you on that um that matter then uh of course you may and it's more important we get things finally settled than that we do it in a particularly
00:50:59 than that we do it in a particularly meticulous order I'm grateful thank you sir thank you but unless I hear from you uh again then what has been agreed uh is agreed and no further extension is
00:51:14 agreed and no further extension is sought so yes that's that's the position as I currently understand it but I I my instructions so it good right now um we are now
00:51:24 are now back I think with um uh Mr greenall and Miss Lewis unless I'm mistaken thank you Seth um in fact um
00:51:37 mistaken thank you Seth um in fact um the remaining clients from hos Jones and Allen are all ones which I will be dealing with yes um so I and and I appreciate there there appears to have been some miscommunication as to what
00:51:49 been some miscommunication as to what misunderstanding as to what was expected on on this hearing but in relation to outstanding clients um I have that there are 50
00:52:01 are 50 clients outstanding yeah all of whom I ask for an extension until the end of April the deadlines they currently have all vary mostly are 31st of March some a
00:52:21 all vary mostly are 31st of March some a few days sooner some a few days later um the details for their uh applications are as set out they have all made previous applications for extension of time time and the details on relating to
00:52:33 time time and the details on relating to their personal circumstances are set out in those
00:52:34 in those applications um so sir shall I proceed to go through them one by one is that um yes it is I think it's important because I don't want to find that when we've
00:52:47 I don't want to find that when we've finished today it is asserted that there have been misunderstandings or oversights I'm determined to do this once and once only understood sir um so if I might start please with um Alex Hodson
00:52:57 Hodson um he his uh current uh deadline is until the end of March the extension sort until the end of April um the basis for the extension
00:53:11 for the extension um given that this is an open hearing I'll say simply that there is a a medical matter relating to a a close family member uh which has impacted on
00:53:23 family member uh which has impacted on him um and his capacity to work on this um there is also a considerable amount of documentation in relation to reclaim the streets uh which has an overlap with
00:53:34 the streets uh which has an overlap with his own personal statement um there have been issues in relation to the Epic system um he also um has a connection to 56a and this is um the matter which was
00:53:52 56a and this is um the matter which was raised in by Miss dagostino in relation to Miss Wilson um it impacts on him as well um disclosure for 56 say in previous tranches was made I understand to miss dagostino and that she was uh
00:54:03 to miss dagostino and that she was uh coordinating uh that matter for those persons to who were affected by that um and it was therefore um anticipated that there was a continuation of that um
00:54:17 there was a continuation of that um leadership if I might put it that way um and therefore she had had some um dealings in relation to tr 3 and it was unclear whether the material which had been disclosed to miss dagostino had
00:54:36 been disclosed to miss dagostino had also been provided to hja solicitors in relation to those individuals affected um my understanding is that um the material has been disclosed some of it
00:54:50 material has been disclosed some of it quite recently uh and some of it quite recently to Miss Wilson in fact Mr Hodson would be in a much better position than Miss Wilson to deal with those issues arising and this is one of the the sort of
00:55:03 the the sort of um uh one of the the discrepancies which has caused some difficulties in in replying to responding to the rule n request because M Mr Hudson is is in the position to deal with those 568 issues
00:55:14 position to deal with those 568 issues he is asked questions about about it in his personal statement um and therefore would like to deal with that all in one
00:55:26 would like to deal with that all in one go and that supports his application to to extend until the end of
00:55:34 April and let say you require further details those are some my submissions in relation to Mr
00:55:48 Hodson next on my uh list I have Brendan Delaney his current um deadline is the 24th of
00:55:50 24th of March um the difficulties that he has had is that he's had difficult is access
00:56:06 had is that he's had difficult is access accessing epic um there has been um some some of uh a needs to obtain documents which were held at uh bindman solicitors um by Mr Schwarz when he previously worked there uh which relates
00:56:18 previously worked there uh which relates to I believe the good Easter hunt saur's uh case and get seeking access to that
00:56:29 uh case and get seeking access to that has taken some time also in relation to uh good Easter the disclosure has come through in phases um to different individuals at different times and there's been a bit some some delay uh in getting the the material together for that um and
00:56:47 material together for that um and therefore for those reasons I I seek an extension for Mr Delaney until the end of
00:56:54 April Mr the next on my list is Brendan me his the reasons in his case are similar to Mr Delany in terms of Ban's documentation epic issues good e
00:57:06 Ban's documentation epic issues good e to hunb issues um he also has had work commitments uh which have affected his ability to work on his statements and um issues in relation to his family which
00:57:20 issues in relation to his family which have been um identified I believe in in correspondence seeking extensions of time and so for those reasons in his case um I seek a an extension until the end of
00:57:35 April Brian Healey
00:57:36 Healey is the next um next cor participant Uh current deadline end of March Mr Healey has unfortunately
00:57:48 March Mr Healey has unfortunately suffered a bereavement in his close family and that has had a significant impact on his ability to work on his
00:58:00 impact on his ability to work on his statement and for that reason I asked for an extension until the end of
00:58:10 April um next is Miss Wilson who of course was was mentioned by Miss dagostino earlier today um my understanding is that she has a current
00:58:23 understanding is that she has a current deadline of the end of March for uh her original statement but then she has recently been provided with further um disclosure and a further supplementary rule 9 request um which was received on the
00:58:37 request um which was received on the 13th of March and an extension of the deadline until the 3rd of April um again um on her in her p position um
00:58:49 um again um on her in her p position um because of um the short um dis deadline for the disclosure of the new uh statement um also uh there is um she has had difficulties accessing her own personal documents um due to building
00:59:05 personal documents um due to building work taking place in um the the location that they're they're stored at um so that's added to the delays in her her case and also um she has um an interesting reclaim the streets and
00:59:16 interesting reclaim the streets and there is a lot of documentation provided for for reclaim the streets which overlaps with with her uh document um so again in her her case um I asked for the end of April I can indicate that um
00:59:28 end of April I can indicate that um everyone I'm speaking on behalf of is working hard on their statements and and you know if people are in a position to submit earlier then then they may be
00:59:43 submit earlier then then they may be able to do so but the request on behalf of M Wilson is until the end of April
00:59:48 April um the next I have is the genetic engineering Network um again uh current dis uh deadline is second of
01:00:02 April request until the end of April um there's been a delay in in accessing the documents uh for some of the uh persons involved and also there are a number of
01:00:14 involved and also there are a number of of individuals needing to coordinate in relation to uh that
01:00:24 statement you said that the current deadline is the 2nd of April that was an extension that was requested which the inquiry legal team agreed to yes sir I I accept that um and I am making a a further ex request for an
01:00:39 making a a further ex request for an extension until the end of April on what basis on the basis that um there have been difficulties in accessing material for some of those uh persons involved and the needs for for the um because
01:00:50 and the needs for for the um because there's more than one person involved uh coordination and and the like um adds to the difficulties in in preparing the
01:01:05 statement um good e to hun saers is the uh next
01:01:12 uh next um next next group um current deadline is 31st of March um the the reason for seeking a further extension until the end of April um is as has been indicated for some of
01:01:24 um is as has been indicated for some of the earlier clients some of the material was held by bindman solicitors and there was a delay in getting access to that um the disclosure in relation to goodies the hunt sabors has come through in
01:01:35 the hunt sabors has come through in various uh stages um and uh there is also my understanding that um some of the material that's been provided to the hunt
01:01:46 hunt sabur uh
01:01:54 sabur uh Association uh is relevant to the good Easter hunt sabs assoc um statement there's a crossover of issues there um and there are a significant number of different persons involved in producing that statement again need to
01:02:07 producing that statement again need to to coordinate between the individuals so that a a group position is is put forward uh so for those reasons I seek an extension till the end of
01:02:22 April um grd has the current deadline of the 24th of
01:02:26 of March again I seek an extension to the end of April um he had difficulties accessing epic there was difficulties getting documents from bindman he had delays in getting access
01:02:38 bindman he had delays in getting access to the goodies to hunt sabotage material he's had work commitments he's also been uh traveling outside of U um outside of
01:02:51 uh traveling outside of U um outside of the country uh which is made uh delayed U work on the statement and um I don't wish to go into details but there's been some medical issues as well which are set out in personal correspondence so
01:03:03 set out in personal correspondence so for those reasons I seek an extension to the end of
01:03:09 April um the next client this is number nine on my list of 15 just so so you know where I'm going next client is Jane
01:03:24 leaport um current deadline I understand is the end of March
01:03:33 she had issues with epic including um documents which were not restored um after the Epic system came down uh and that delayed work for her and she also
01:03:49 that delayed work for her and she also has um work commitments and limited time to work on this statement um and for that reason I seek an
01:03:56 extension um Jay
01:04:10 Jay Jordan um who is um has a connection to reclaim the streets um he has the same similar issues as Jane leaport uh he also um suffered a a bement in his immediate family um which of course has um meant that he's had other issues to
01:04:26 um meant that he's had other issues to to deal with um he has also um he works often abroad and traveling commitments for work um have um limited his his capacity to to work on his statement um and also as I think have been has been outlined in personal correspondence um
01:04:39 outlined in personal correspondence um there are some personal medical issues um which have been affecting him and for those reasons in his case I seek an extension till the end of April yeah
01:04:53 April yeah um Martin Shaw is the next client I have current deadline 31st of
01:05:08 deadline 31st of March um he had um there were issues arising in relation to disclosure relating to the genetic engineering Network um he is in a position to provide a
01:05:21 provide a um significant information in relation to that um there have also been um um some significant issues that have Arisen
01:05:32 some significant issues that have Arisen in relation to um Intimate Relationships um and um that is another matter which has um required some further work on his statement um and for those reasons I I seek an extension until the end of
01:05:53 April um next on my list is uh Matt Salsbury
01:05:56 Salsbury um the issues in relation to him uh his current sorry current uh deadline is the 28th of
01:06:11 28th of March um he has he is another client who has connections to reclaim the streets significant amount of documentation there um and work on the reclaim the street um statements obviously has an
01:06:22 street um statements obviously has an overlap with his own personal statement um he has had the similar issues in relation to uh access to documents on on Epic um and uh and other personal
01:06:42 Epic um and uh and other personal commitments um similar to uh some of the other clients such as Jane Le Port um and for those reasons I seek an extension until the end of April um number 13 is Robert bamry um
01:07:03 again current deadline at 27th of March another client has connection to reclaim the streets he's had difficulties accessing epic um he's had also uh required access to material that was held by bindman
01:07:20 was held by bindman solicitors um in in relation to um some quite significant um matters in his uh rule N9
01:07:28 rule N9 request uh and for those reasons I see C an extension until the end of April Roger geffin Uh current deadline 31st of of March um he has been um away out of the country um for some time during the the
01:07:42 country um for some time during the the period when he would have been required to work on his statement um there's been a large amount of material um in relation to reclaim the streets um and uh he has personal Comm commitments
01:07:56 uh he has personal Comm commitments which have limited his ability to work on the statement and again for for those reasons I seek an application until the end of
01:08:03 end of April and then the final um uh client in this category is Simon
01:08:16 um uh client in this category is Simon Taylor he um is a good Easter um has um is connected to the good Easter hunt Sabers um current deadline is uh end of uh March um he has um pre-booked um
01:08:28 uh March um he has um pre-booked um holidays uh in this period he also has very significant work commitments um and he didn't uh get access until uh the
01:08:41 he didn't uh get access until uh the goodies to hunt sabur disclosure until I understand the 19th of February so so there was delay in in him getting access to some of the relevant material he now has it um again in his POS for the
01:08:52 has it um again in his POS for the reasons given I seek an extension of time until the end of April
01:09:02 so I I think that um covers the outstanding clients from odds Jones and Allan I addressed you already on reclaim the streets and pull grabit um and in relation to uh Ben Lei um so you you
01:09:18 relation to uh Ben Lei um so you you mentioned that there was an issue in terms of um the downloading of of documents um I don't want to go too much into um this matter in in an open public
01:09:30 into um this matter in in an open public forum but Mr Li's position is is that um he told the do the inqu he was given permission to download documents and he told the inquiry what down documents he had downloaded and if there was an any
01:09:44 had downloaded and if there was an any issue over exceeding the scope of what he was permitted to download um that came to light because he had been open with the inquiry and told them what he had downloaded um he has been out of the country um and that that is um maybe
01:09:58 country um and that that is um maybe there may be some issues arising from that because I understand the inquiry wish um hod Jones and Alan solicitors to to see him um in relation to some of those issues um but but his position is
01:10:12 those issues um but but his position is that he told the inquiry what have been downloaded and it can um ensure that
01:10:23 downloaded and it can um ensure that there is compliance going forward um he he he has had very significant difficulties in working with the material on the Epic system uh he says that when when he was able to download
01:10:43 that when when he was able to download it it made it much more easy for him um he was able to to know search and sort documents um in a much more efficient manner than than than he was able to using using epic that has all been paused because he's been asked to to
01:10:54 paused because he's been asked to to delete the material he's downloaded Etc so um that is what I would wish to say at this point point on that matter if there are other matters arising then I would ask to to address you in in a private session um but on his behalf um I seek an extension for those reasons
01:11:07 I seek an extension for those reasons and the reasons outlined earlier until the end of April
01:11:18 April um forgive me if I've um misunderstood or overlooked something but is AA win Stanley on your list
01:11:27 list um not immed medely sir I can if might I just take instructions very
01:11:49 briefly might I just take this opportunity to say that from our point of view tracking these applications the question on our mind is whether there is an application going to be made on
01:12:03 an application going to be made on behalf of mea we were anticipating that next one on my
01:12:10 list Mr ative chry uh and then there is a question we know there's an application on behalf of Dr Lawrence and the question is whether that's going to be dealt with on paper or
01:12:24 orally I I think one of the issues may be that I I've been making submissions on behalf of cor participants represented by Mike Schwarz at H Jones I think there may be some other cor
01:12:35 think there may be some other cor participants from others um I don't want to delay matters right now if there are others to make um submissions perhaps I could have a short amount of time to get instructions as best I can on those
01:12:51 instructions as best I can on those um on those individual it was wi Stanley um Mayer
01:12:53 um Mayer and was it Mr chry and Dr lawren Dr lawr okay um so might I just
01:13:07 might I just have sometimes just to take instructions on on on those because those weren't on my
01:13:17 list yes as far as Dr Lawrence goes I know a good deal about his circumstances um uh at present um uh the inquiry cannot accept the uh uh suggestion that he's made
01:13:29 the uh uh suggestion that he's made uh and his circumstances need to be
01:13:42 addressed um so that that that's heard I will I'll make inquiries then um I will rise now to deal with the uh submissions that you have made with my team and you will um let me know when you're ready to
01:13:55 will um let me know when you're ready to resume with those that we haven't Del is thank you sir thank
01:14:24 you
01:34:52 e e
01:35:43 we're ready to resume sir thank you Mr greenall thank you sir um I uh I have managed to take some very brief instructions in relation to the four um outstanding clients those are um persons
01:35:54 outstanding clients those are um persons who are represented by others list is at hod Jones and Allen and that is the the reason why I didn't have that is what I thought can we pause there for a moment um because uh I am going to make uh to
01:36:13 um because uh I am going to make uh to announce decisions made in relation to um all but three of those who whose cases you have addressed and we'll invite you uh if you wish to to make further submissions privately about three
01:36:33 three others um as as far as those that uh uh you have addressed in open and where I uh have made decisions uh in the following
01:36:35 following order Brendan Delany must produce the time for his witness statement is extended to the
01:36:48 witness statement is extended to the 11th of April Brendan me extended to the 11th of
01:36:53 11th of April Carolyn Wilson extended to the 4th of April
01:37:00 r g
01:37:09 n to the 4th of April good Easter hunt saors to the 11th of April grd to the 11th of April Jane leaport to the 4th of
01:37:25 April Martin Shaw to the 4th of a April Matt Salsbury Robert Banbury and Mr geffin to the 2nd of May Simon Taylor to the 11th of
01:37:37 Simon Taylor to the 11th of April Brian Lei to the 11th of April Paul grait to the 2nd of May there are three that uh I invite you to make uh
01:37:52 three that uh I invite you to make uh private submissions about if you wish Alex son Brian Healey and John
01:38:08 Jordan thank you sir if I might may make those um submissions in in private certainly now um would you prefer it would suit me better if you were to deal with the open submissions that you're going to make for the
01:38:20 going to make for the um three or four other uh of your
01:38:31 um three or four other uh of your uh instructing listers um clients uh and then go into private um yes um the uh submissions I I can certainly do that sir um dealing first with um doc Dr
01:38:44 first with um doc Dr Lawrence um uh so as I I hope you're aware from written correspondence and he is he's resident in Jamaica I know that he's obviously um of some
01:39:00 I know that he's obviously um of some age he has difficulties accessing using computer um and also there is difficulties getting reliable internet um access and um in terms of people to
01:39:11 um access and um in terms of people to assist him um they they are limited and they have their own um commitments in terms of work um in Practical terms um the by the only feasible way for him to produce a statement is for
01:39:26 produce a statement is for him to meet with those instructing me for them to go through the documents with him um and to help him prepare his
01:39:37 with him um and to help him prepare his statement um he is because of um matters arising from the the hurricane in Jamaica and things he has to take care of he's not returning to the UK until um late April um an extension of time was
01:39:53 late April um an extension of time was sought um until the 13th of June and I understand was not granted by the inquiry legal team um the position is that for um you know he wishes to to to
01:40:05 that for um you know he wishes to to to participate in the inquiry to assist the inquiry he obviously has important evidence to give um but until he is in the United Kingdom it will won't be possible to make progress and therefore
01:40:20 possible to make progress and therefore I would ask that for an extension um if the 13th of June is is is not not possible then then at least to the end of
01:40:33 May now because of his unusual circumstances I will need to consider with my team whether or not uh in his case I make a decision today or alternatively um deal with it on the
01:40:44 alternatively um deal with it on the papers when we know more about his um uh ability once he's returned to the United Kingdom but I do appreciate the difficulties of which you've spoken you
01:40:55 difficulties of which you've spoken you rightly point out that he is a person of great interest and importance to the inquiry has an important part to play and uh I wish to ensure that he is able to do it but um would you allow me and
01:41:10 to do it but um would you allow me and my team to reflect briefly on that uh uh before either making a decision or saying we will deal with this on the papers of course there now that then leaves uh the three from uh the ism
01:41:32 three from uh the ism um yes so uh in relation to um Mr charry um I understand that
01:41:45 um I understand that um an application was um made in writing setting out um the the position that he is in um there have been um emotional difficulties in um addressing they have been set out in in the document and there's no need to go into them unless
01:42:03 there's no need to go into them unless you wish to uh in in public um I'm B say I'm was was surprised when I read the document
01:42:07 document about difficulties other than the normal ones um but put that to one side I I know what they are yeah well it's it's
01:42:18 know what they are yeah well it's it's on that on those basis that that I seek an extension of time till the end of April
01:42:30 um and I am receiving instructions as I as I speak sir yes um
01:42:48 the um in relation to the other two clients um the it is the
01:42:58 um the the process of of um going through relatively numerous documents including um documents they themselves have in terms of um their own material
01:43:11 have in terms of um their own material which which is taking taking uh time and again for those reasons I seek an extension until the end of April um beyond that I don't have anything I can add to the um emails written submissions which were submitted in email to to the
01:43:27 which were submitted in email to to the inquiry yeah those I should say that th those instructing me in Rel now in relation to the four these four clients um hadn't realized that it was um necessary to have have an advocate here and they apologized to to the inquiry
01:43:40 and they apologized to to the inquiry and and have um cooperated as best they can in they don't need to apologize at
01:43:54 can in they don't need to apologize at all the these difficulties arise but uh what is important is decisions not how we how we get there procedurally um Maya
01:43:56 Maya um
01:43:58 um I'm I'm afraid I don't have any additional um instructions in relation to Maya so I'm not in a position to um make any submission
01:44:14 sir um I my understanding is that there was an application was sought for all all clients until the end of April yes yes okay
01:44:23 yes okay well I understand what the position is uh I want uh briefly to speak to my team about that but before I do that I want
01:44:37 about that but before I do that I want to give you the opportunity of making uh submissions in private uh please if I could very
01:44:46 yes Jo she check sir we'll need um five minutes just to confirm there attend of those private hearing so I'll pop you in your breakout rooms and I wait further confirmation thank you okay
02:08:50 e e
02:09:28 Mr greenle thank you sir I I've got no further representations to make other than those in the uh private session thank you very much which case I will announce the decisions I deal first of all with Dr Lawrence
02:09:40 all with Dr Lawrence um I cannot extend the time for submitting privacy applications beyond the 11th of April but I appreciate that he has certain logist itical
02:09:56 he has certain logist itical difficulties uh in Jamaica and could you uh tell him that the inquiry is perfectly happy to do the Privacy applications there are several obvious
02:10:10 applications there are several obvious egregious applications that must um be uh made uh and um but it would assist the inquiry if he is unable to do it himself uh while in Jamaica if he could
02:10:21 himself uh while in Jamaica if he could um let us through those who instruct you know that that is the case and the inquiry can then said about it immediately rather than waiting until the 11th of April understood sir um as far as uh the provision of his statement
02:10:37 far as uh the provision of his statement is concerned uh uh he uh will have until the date that he has requested the 13th of June in which to provide
02:10:44 it can I now turn to Maya
02:10:47 to Maya uh and um uh Jay Jordan and Mr Hudson Mr Healey um for reasons uh that uh I I understand
02:11:01 for reasons uh that uh I I understand and which you have explained to me in closed session uh Mr Hudson Mr Healey and J Jordan uh will all require until the 2nd of May to produce their witness
02:11:20 the 2nd of May to produce their witness statements and I extend time for them to do that uh I understand from what I I know that Maya has a large number of documents which she has uh to um examine and to uh exhibit to her witness statement uh which will take her time uh
02:11:44 statement uh which will take her time uh to sort out and in her case too I extend the time for uh service of her witness statement until uh the 2nd of May um as uh far as um
02:11:55 uh Mr chowri uh Mr wi Stanley uh and MCD are concerned the time for their uh witness statements
02:12:07 time for their uh witness statements will also be extended until the 2nd of May great sir thank you I think that deals with all of your clients now does it including those that you acquired uh during the hearing I think so sir I think so thank you good thank you
02:12:22 think so thank you good thank you I understand that um IM and Khan and partners are now available to uh make
02:12:36 partners are now available to uh make submissions uh if that is right um could I ask please that uh they speak up and come on the
02:12:44 screen good afternoon thank you sir thank you very much for coming at short notice and maybe that you didn't appreciate that this was the day for um deciding questions but now that you do appreciate that I'm grateful to you for coming so may I forgive me for
02:12:56 coming so may I forgive me for interrupting um but uh I understand there are good practical reasons why it
02:13:15 there are good practical reasons why it would be better to allow Miss Johnson to make her sole outstanding submission if if we might interpose her of of course then my apologies to yes M Johnson my my apologies not all
02:13:27 to yes M Johnson my my apologies not all all I I'm grateful to my L friend Mr bar at at some point I will run out of backup child care options we're not quite there yet but at some point I may need to um beg you to forgive my discourtesy and release me early of
02:13:40 discourtesy and release me early of course we're not there you do not need to ask um please please leave when you must I'm grateful sir um of course I would wish to stay um to hear all submissions but
02:13:51 submissions but when the time comes I I so to clarify there are no outstanding applications to be made in respect of n Douglas but there is one if I may very
02:14:06 Douglas but there is one if I may very short application I'm now instructed to make on behalf of guy Taylor who is a category k core participant yes so his current deadline is the 28th of March the extension sorted until the
02:14:17 of March the extension sorted until the 18th of April and the reason um which I can give more detail on en closed if if required but I hope that won't be necessary is that he has suffered a an extremely close personal family
02:14:28 extremely close personal family bereavement yeah the funeral for um for that person will be on the 7th of April um Mr Taylor's confident he'll be able
02:14:39 um Mr Taylor's confident he'll be able to complete his statement by the 18th of April deadline he now suggests um but asks that he be granted that extra time to allow him to grief uh I do not even
02:14:51 to allow him to grief uh I do not even intend to rise to consult with the team the answer is yes I'm
02:14:58 grateful and thank you for your assistance today and as I say please feel free to leave whenever you wish I'm grateful thank you sir
02:15:09 sir right apologies for mispronouncing your name
02:15:11 name Miss
02:15:15 Miss ALS I got it right Al thank you sir Elsa key I do apologize I did mispronounce it thank you sir um I'm appearing I'm making these submissions on behalf of our co-participants baroness Doran
02:15:31 our co-participants baroness Doran Lawrence Mr Dave Smith Mr Dan Gilman Mr Frank Smith Mr Steve Hedley Lisa T and
02:15:42 Frank Smith Mr Steve Hedley Lisa T and Mr ainson of The Blacklist support group and Mr sover of the monitoring group uh together our co- participants I do not intend to repeat the written submissions we uh provided to the inquiry team on Friday um however I wish to make additional uh further
02:15:57 I wish to make additional uh further submissions uh in relation to a few of our
02:16:04 our co-participants uh I um to assist I will follow the same order of uh we have listed and included in our written submissions so the starting first is our co-participant baroness Doren Lawrence
02:16:12 Lawrence um I do not wish to repeat the reasons why we are uh seeking further extension of time for Baron
02:16:29 of time for Baron but uh to bring to um um um attention uh sir that we um we email the inquiry so there's a there's a further there's an outstanding point in relation to the disclosure released U for our co-and
02:16:44 disclosure released U for our co-and Baron dorren Lawrence she we imil the inquiry team on the 4th of March explaining that only a small percentage of the disclosure if any relates to the SDS reports or information prior to 1998 in the Years immediately following uh
02:16:58 in the Years immediately following uh baroness lawren son's U Steve Lawrence death in
02:17:03 death in 1998 uh we have yet to hear back from the inquiry team so this remains unanswered and of course it's imperative today to to understand the queries team position in determining uh whether the
02:17:15 position in determining uh whether the deadline we saw at the end of April is actually a workable deadline yes the so that I understand the point you uh have been told by the
02:17:26 the point you uh have been told by the inquiry team that there are additional documents relating to what precisely we haven't been told we haven't received any response from the inquiry team but we've raised the
02:17:38 the inquiry team but we've raised the point that as far as we can see all the documents relate are uh uh after the
02:17:49 documents relate are uh uh after the 1998 so there's no documents to Prior uh prior to 1998 and immediately after the years following Miss uh D baroness Lawrence some Stu
02:18:03 198 so this is the first outstanding query sir uh the second I should um move to uh it's in relation to our cor participant Mr Dave Smith um and I don't wish to repeat the point um in paragraph
02:18:19 wish to repeat the point um in paragraph 10 of our submissions on page page three uh but um in summary it is um we've identified that uh he um he has a there's a reference to an SDS file in his name from 1986 uh and we've asked the inquiry to
02:18:34 1986 uh and we've asked the inquiry to investigate whether we are uh we will be provided with additional and FAL disclosure again this is imperative today because it will determine whether the deadline of the end of April is a workable
02:18:52 deadline um thirdly I wish to move to our
02:19:02 our co-participant um uh Mr SES Grover for Mr SES Grover we um we wrote to the inquiry team we've sent them a
02:19:12 letter on the 25th of February 2025 we understand that uh as far as I understand we we were told that we will hear back from them but we've yet to to receive a response and in our in our
02:19:30 receive a response and in our in our letter of the 25th of February 2025 we outlined why uh our Corman Mr Grover believes that um he is uh required
02:19:42 believes that um he is uh required additional disclosure in particular uh it is uh in relation to uh his um surrounding um apologies um
02:19:55 uh for for Mr SES it's um we we require the uh inquiries and explanation why disclosure made in respect of him and a Related Group the monitoring group is largely admitted to events surrounding the Steve Lawrence
02:20:14 inquiry y thank you sir and um the two additional so again on um just to
02:20:26 additional so again on um just to conclude on aot Mr um um Sur graa again it is imperative we understand the position if we will be uh provided with additional disclosure to help us and and uh determine whether the deadline of the end of April is workable deadline the
02:20:41 end of April is workable deadline the two further submissions I wish to make um are in relation to the group statements uh uh required on behalf of the first group are uh uh or it's the
02:20:55 the first group are uh uh or it's the black support group um um uh which is uh and the second statement on behalf of the monitoring group for the first one uh the black support group the uh disclosure was provided
02:21:07 disclosure was provided um in sometime in February with six weeks time the deadline for the group statement is on um the 7th of April in
02:21:19 statement is on um the 7th of April in relation to the monitoring group their deadline is on the thir of April to provide the group statement however um I wish to draw to to draw your attention and to ask the inquiry team to refer to
02:21:37 and to ask the inquiry team to refer to our letter dated the 24th of May of last year where we've made a specific disclosure request for specific disclosure and listed out uh different groups that um are our our clients for
02:21:48 groups that um are our our clients for example the monitor group have played an active part in in in a number of campaigns from 93 to 2007 and the same goes to our uh to the black support group uh they uh have played an active
02:22:02 group uh they uh have played an active part in a number of campaigns from 93 to 2007 but yet only provided with a disclosure related to their group which was formed in 2009 um I will have to uh consult my
02:22:23 2009 um I will have to uh consult my team about uh additional disclosure the um usual starting position is that the inquiry has disclosed say I know it hasn't in the case of um baroness Lawrence all of the documents that it
02:22:34 Lawrence all of the documents that it has in its possession which it considers relevant and if that were to be the position then what would the applications
02:22:42 be uh the application be I mean if that's the position we will get a confirmation today um um and we will agree deadline the deadline will be the end what we sought which is um the end of
02:22:56 of April but we sought we we we're seeking your um your confirmation that this is the position because we've not hi back from the
02:23:10 imparity then I will have to um rise to uh discuss that with them um
02:23:22 there I think ah other Imran Khan um
02:23:28 Khan um clouds uh that you haven't mentioned that's right I've not mentioned because I I do not intend to make oral submissions we we've given unless you
02:23:42 submissions we we've given unless you want me to repeat the points in relation to each co- participant I'm happy to do so if you
02:23:53 wish I better just for the avoidance of doubt Ure that um I have got them in mind um uh the Dan Gilman are they not so firstly
02:24:07 the Dan Gilman are they not so firstly par yeah the ones we've not talked about uh Dan Gilman co- D Mr Dan Gilman who participant Mr Frank
02:24:11 Smith Mr Steve
02:24:16 Hedley Miss Lisa tiosa
02:24:21 Mr Steve
02:24:33 a very well forgive me while I am going and discuss these matters with the inquiry legal team
02:24:49 right
02:55:47 e e
02:56:42 alili hope I've got the name right sh yes sir K thank you um
02:56:51 I I I will announce the dates in a moment um but I would like to clear up what maybe a misapprehension among some of your clients um in the case of
02:57:03 of your clients um in the case of baroness Lawrence there are 20 or 30 documents
02:57:05 documents um they
02:57:07 um they um they either have been disclosed or are about to be disclosed to her um but there
02:57:15 there are not at the moment any other documents of which the inquiry is aware which might affect her ability to produce a witness statement um the
02:57:26 produce a witness statement um the inquiry is always on the lookout for additional documents from within uh the police service and I cannot promise that none will turn up but they have been
02:57:37 none will turn up but they have been carefully looked for and I'm told that there is no reason to believe that there are any
02:57:49 are any um but that does not PR entirely the possibility that there will be some um but that cannot hold up uh the
02:58:02 some um but that cannot hold up uh the conduct of the inquiry otherwise we will never finish and therefore uh although uh some of those uh who who represent may feel that there are documents to be disclosed to them um I'm afraid I cannot allow that to delay the production of
02:58:20 allow that to delay the production of witness statements by them um it is as I say inevitable that when the hearing bundle is produced that uh some of your clients uh will see in it documents relate to activities and groups that they
02:58:34 activities and groups that they recognize and may well have participated in and they may at that stage wish to say something further about it they'll be afforded the opportunity of doing so but it must not hold up the uh
02:58:46 but it must not hold up the uh submission of the uh Rule n witness statement uh at this day understood uh as far as baroness Lawrence is concerned the time for the submission of her rule 9 statement is extended to the 2nd of
02:58:58 extended to the 2nd of May as it will be in the case of Dave Smith sures Grover the monitoring group and Steve
02:59:13 Hedley as far as uh Mr Gilman is concerned uh and Frank Smith is concerned their time for service of a
02:59:26 concerned their time for service of a statement will be extended until the 4th of April um but not Beyond then um they have had the request and the documents for a long time now likewise in the case of Steve hon that his time is extended to the 4th of April but not Beyond he's
02:59:37 to the 4th of April but not Beyond he's had no documents because we haven't got
02:59:47 any uh liisa toer or tusher uh I understand the personal um uh difficulties that she is in and her the
02:59:58 difficulties that she is in and her the time for service of her rule N9 witness statement will be extended to the 25th of
03:00:05 April I think that deals with um all of those that you represent on who we're missing the black support group group
03:00:16 missing the black support group group statement the black support group uh was not has been merely been requested as I understand it to provide impact statement there are no um there is no request for a rule 9 statement from The
03:00:30 request for a rule 9 statement from The Blacklist support group um Dave Smith uh I think has been asked to um uh say something about them but if he wants to but that is all um the black support group Blacklist support group I'm sorry um has not as I
03:00:49 support group I'm sorry um has not as I understand it had a rule n request made to them and nor as I understand it are they core participants
03:00:55 but they feature I'm afraid a very long way down the chain of those that the inquiry must investigate to produce a report thank you sir I just to to go
03:01:11 report thank you sir I just to to go back please to Mr a Mr Frank Smith I not what you say but he had enough time but just want to uh reiterate the point we included in our um written submissions he we asked the inquiry team to we
03:01:22 he we asked the inquiry team to we applied to the inquiry team to Grant him permission to print and download documents on Epic and ear last week Thursday on the 13th of March he when he visited our offices he successfully collected physical copies of his
03:01:40 collected physical copies of his documents so we I'm afraid we uh I'll be grateful for to to request additional time in his
03:01:46 circumstances how many documents um were
03:01:55 there I want to say roughly about uh in the circle of 500 pages ah I had not appreciated that there were that many documents
03:02:10 um in that event I don't uh need I think to consult again with um uh my team I
03:02:21 to consult again with um uh my team I would extend his time for producing uh uh a n witness statement until Monday Thursday the 17th of April
03:02:36 1th Thursday the 17th of April yes yes thank you sir don't set it on Good Friday because that is is
03:02:49 known thank you very much thank you now um now is the time when um
03:03:01 um now is the time when um uh Miss steel and Mr Morris uh should make uh submissions on behalf of the mlal support campaign if they wish uh thank you um in relation to mlal um I wanted to say that um while I'm
03:03:13 um I wanted to say that um while I'm glad that we now have the opportunity to be
03:03:14 be heard this hearing with all the stresses and time up wouldn't have been necessary if there had been earlier and proper engagement with core participant non-state core parti core participant
03:03:30 non-state core parti core participant concerns um and I wanted to urge a more collaborative approach going forwards um and you know non-state cor participants have waited years for
03:03:45 participants have waited years for disclosure yet we were then only given a matter of weeks to respond to that disclosure um and with both statements and privacy any privacy
03:03:54 privacy applications many of us are impacted by the trauma of the deception by the undercover officers and the abuse um some of us were subjected to it's
03:04:05 some of us were subjected to it's already stressful engaging with the inquiry and the impact of short deadlines causes intense additional and unnecessary stress and it also feels
03:04:17 unnecessary stress and it also feels extremely disrespectful of of our own lives
03:04:20 lives um particularly bearing in mind how long we've already waited um we want to assist the inquiry but some quite often it doesn't actually it doesn't actually
03:04:37 it doesn't actually it doesn't actually feel like the inquiry wants us to assist the inquiry um I you know I have to ask why the inquiry didn't consult with us prior to the deadlines being Set uh and as I say I urge a more constructive approach from now um the specific
03:04:55 approach from now um the specific situation with mlal support campaign um I made an application for us to be granted core participant status that was
03:05:08 granted core participant status that was um granted uh we haven't had a rule nine as a group um but I do wish to make a statement for M liable um there were uh in in tranch to um I have had uh a personal Ru nine that had more than
03:05:24 a personal Ru nine that had more than 400 questions of of which about 75 were about M
03:05:31 about M liel um in trch to M liel there were 112 documents
03:05:32 documents 2,286 Pages they were disclosed over a period of 10 months um more than half of them coming long after my personal rule nine was served on me um I haven't had
03:05:47 nine was served on me um I haven't had the time to go through those documents um I I I know that it may seem like there's been a long time since that
03:06:02 there's been a long time since that disclosure was made now but in reality I have been engaged with following the hearings in tranch 2 uh many of the witnesses who gave evidence gave evidence relating to me they talked about me and Andor they talked about issues that are very relevant to me such as other women being deceived into
03:06:17 as other women being deceived into relationships so it's not the case that I was able to work on this um you know during the last per the last year when well that sorry the last how many months when the inquiry was running obviously
03:06:43 um sorry the while the inquir is aware of the impact of um the procedures on me that also prevented me from um working on the
03:06:44 on the statement um so uh now in tranch 3 um we've had another 51 documents served for
03:07:03 another 51 documents served for Mel um on the 28th of February that's on top of my personal disclosure that was made on the 21st of February and that for reclaim the streets my personal disclosure being 164 documents with 800 approx pages and RCS disclosure being
03:07:20 approx pages and RCS disclosure being 690 documents nearly 2,000 Pages um it's a very tall order to get on top of that amount of
03:07:25 amount of disclosure um and it's made even worse by the fact that it's not it doesn't appear to be standard practice for the inquiry to serve a an index of the disclosure that is
03:07:46 a an index of the disclosure that is that can be sorted as a spreadsheet that can be sorted by date or by Officer to facilitate being able to work through the documents into some kind of systematic way I requested that index um and it was another two weeks after the disclosure was made before it was
03:07:57 disclosure was made before it was provided um and I've still had to work on it in order to I don't know I don't know what was up but there was considerable formatting problems that meant that it couldn't actually be
03:08:09 meant that it couldn't actually be sorted into date order that I had to work on to correct that um I still have several thousand pages from tranch 2 to
03:08:21 several thousand pages from tranch 2 to deal with um including the 2,000 from M liel um and I also on top of that have my own contemporaneous documents that I
03:08:33 my own contemporaneous documents that I want to assemble some of which I believe are actually really quite important for the
03:08:34 the inquiry
03:08:44 um the I understand the concerns of the inquiry relating to privacy and the bundle but but um the consequence of requiring privacy applications by the 11th of April is that it will
03:08:55 11th of April is that it will effectively mean that I will have to stop work on the statement and it will also impact on my ability to do um a m
03:09:06 also impact on my ability to do um a m liable statement as well as the personal um statement relating to Muscat um I wanted to say that there's a very real problem with the inquiry
03:09:21 very real problem with the inquiry approach to privacy in that there's no transparency about the process and no discussion or negotiation around our concerns to give you an example um in terms of egregious privacy um I've
03:09:32 terms of egregious privacy um I've recently had a whole lot of documents disclosed which were disclosed to other people despite the fact that it included names and photographs and
03:09:45 included names and photographs and addresses and phone numbers of members of my family um and the only uh privacy redactions that were made were in relation to my National Insurance number which frankly I
03:09:58 Insurance number which frankly I couldn't care to Hoots about yet there was no there was no dis there was no privacy redactions over all my family's personal details and
03:10:09 personal details and photographs there there has to be some kind of
03:10:14 kind of workable uh there seem to be no written guidelines that are adhered to in relation to what the inquiry considers to be um matters that need to be
03:10:26 to be um matters that need to be redacted to protect people's privacy and I I would urge the inquiry to bear in mind that the whole reason this inquiry exists is because we have already had
03:10:39 exists is because we have already had our privacy massively interfered with and so it's particularly distressing that the inquiry appears not to take seriously our need for privacy now our need for
03:10:52 our need for privacy now our need for time to be able to deal with that and to to deal with it in a constructive way rather
03:10:54 rather than um
03:10:57 than um just as I just setting arbitrary deadlines and what feels like a threat what did what what
03:11:10 feels like a threat what did what what basically amounted to a threat last week last year me having
03:11:21 last year me having waited an additional sort of nine or 10 months on top of the already delay the already long delays um for any disclosure and additional nine or 10 months in my disclosure to to have it
03:11:42 months in my disclosure to to have it completed Beyond when it was supposed to be completed and yet I was required to make privacy applications during the month that I was supposed to be on holiday with my mom for her 90th birthday
03:11:44 birthday and then the inquiry because I said said look it's impossible for me to deal with this the inquiry then said we'll do it for you but the approach that the
03:11:55 for you but the approach that the inquiry took was to not consult with me about how that was done and while we are
03:12:06 about how that was done and while we are expected to individually list every word that we want to have redacted what the inquiry team did was send me a new copy of each document and tell me I had to compare line by line
03:12:19 compare line by line the original version they disclosed with the nude version like if it couldn't have been a more impossible task even if there had only been you know a 100 pages in reality
03:12:34 been you know a 100 pages in reality there were thousands of pages and it just wasn't possible it felt utterly disrespectful and distressing and I do urge the inquiry to take this
03:12:51 urge the inquiry to take this the the the the privacy concerns of non-state core core participants seriously and afford US sufficient time to do it properly it will be more
03:13:03 to do it properly it will be more efficient in the end I understand the inquiry
03:13:04 inquiry um wants to get the bundle done by a certain time and I agree that that's important but I don't actually understand why this why this wasn't
03:13:15 understand why this why this wasn't discussed with us and fact Ed in before the hearing date was set if that was the case um but secondly also in reality the inquiry cannot
03:13:27 also in reality the inquiry cannot actually deal with everybody's privacy
03:13:38 actually deal with everybody's privacy redactions at exactly the same time and for that reason I would ask that um if there are specific documents that the inquiry wants to deal with early on then the inquiry makes us aware of that makes me aware of that and I will do my best to attempt to do those specific
03:13:51 to attempt to do those specific documents perhaps statements early on but to expect me to be able to deal with thousands of pages just means that I have to read everything twice when in
03:14:05 have to read everything twice when in fact I think that those applications for privacy will just be sitting on someone's desk for quite a long time after the 11th of April simply because
03:14:21 after the 11th of April simply because they can't all be processed at once so I would urge that that is um Revisited
03:14:30 um I I just wanted to say as well because I I know that other people have struggled
03:14:36 struggled with um epic to a huge degree and the one key thing that would make the process much simpler and easier for everybody is that like where Co
03:14:50 everybody is that like where Co participants have more than for for example 30 documents the inquiry provided as standard an Excel spreadsheet of the disclosure to them that gave the control number and the date of the document and as they did in
03:15:09 date of the document and as they did in tranch 2 for me also included the um the relevant officer number um alongside it because that means that we can sort the disclosure list into a an order that actually makes it possible to work on the documents in some kind of
03:15:27 on the documents in some kind of coherent way rather than as present just getting them in completely random order and it just wastes so much time us having to construct lists and cut and P
03:15:39 having to construct lists and cut and P well we can't even cut and paste type in individually all the control numbers in order to be able to look at the documents and make notes about them anyway um I think that's I I do want to make a statement on behalf of the mlal
03:15:51 make a statement on behalf of the mlal support campaign even though we haven't had a specific Rule n request um you know we were granted that status there is clear serious
03:16:04 clear serious um an unnecessary intrusion into the mlal support campaign and interference with the mlal case
03:16:19 with the mlal case um breach of of privacy sorry breach of um um Legal Professional privilege uh and so on and and I think that needs to be addressed properly um
03:16:32 that needs to be addressed properly um in a statement from the M liable support campaign um I'm sure Dave's got more to add anyway thank you thank you Mr Morris yes I'll try and be brief obviously I agree with everything that Helen said uh obviously we also appreciate this hearing um and
03:16:47 we also appreciate this hearing um and it's something that we did call for with the statement by 92 individual core participants we called for you know proper dialogue over these issues so we're pleased that this is happening uh
03:17:00 we're pleased that this is happening uh and pleased with the chance to speak and we do want to continue to collaborate constructively as we have done from the beginning of the inquiry um and um we
03:17:13 beginning of the inquiry um and um we have been raising for many months the need to have T3 um joint meetings with the T3 team um to iron out some of the issues
03:17:24 team um to iron out some of the issues that are now raised their ugly head uh over the last few weeks um and those meetings have been put off and put off and put off or refused um and as a result of our
03:17:35 result of our concerns we and our lawyers have been calling for um had been calling for T3 to be put back so we were very pleased when it was announced on the 7th of
03:17:50 when it was announced on the 7th of February that the next round of hearings will be postponed from April to October uh and it said on the ucpi website quote to allow adequate time for Witnesses core
03:18:01 Witnesses core participants recognized legal representatives and the inquiry team to prepare their evidence so we were very pleased when we read that there was
03:18:15 pleased when we read that there was going to be six months for that purpose additional six months for Preparation time and then we were told well our
03:18:28 time and then we were told well our actual preparation time wasn't going to be increased uh it was still just six weeks um and I just want to emphasize you can
03:18:39 emphasize you can imagine how angry everybody must have been when they read that absolutely livid and there was no other mechanism having communicated by email and through the lawyers trying to get uh T3
03:18:49 T3 meetings um organized there was no other mechanism except to do an open letter um and uh we're glad that at least this
03:19:02 and uh we're glad that at least this hearing was scheduled and at least we've been able to address some of these issues about the mainly about the arbitrary six week dead deadline that was uh previously being imposed um just want to say f uh a few other bits and
03:19:18 want to say f uh a few other bits and pieces yes I I think I'm not not sure if um if you are aware of just how much chaos we believe um is happening inside the uh inquiry legal team um and um
03:19:35 the uh inquiry legal team um and um there's a whole range of issues from as you've heard about epique um lack of responses to emails you've heard of some of those issues that's
03:19:43 that's widespread um contradictory replies um the the indexes not having the dates
03:19:58 um the the indexes not having the dates on which is um a deterioration from the previous T2 organization of of the material um and the disclosure to groups um disclosure is clearly a fundamental legal
03:20:13 fundamental legal obligation um and um the fact that um it's very arbitrary which groups are getting
03:20:17 getting disclosure um as we've heard from Mark about Mark wodsworth not getting the disclosure despite being the chair of the anti-racist alliance um so I think there's some issues that need to be sorted out uh with respect uh behind the
03:20:35 sorted out uh with respect uh behind the scenes uh because we believe the corners are being cut and there's pretty much a lot of chaos uh as far as we can see from our side I might be wrong but I think it needs to be investigated and
03:20:47 think it needs to be investigated and improved um and all of these individual applications that we've been asked to make over the last few weeks have been a colossal waste of time to everybody to ourselves our lawyers to the ilt and so on so at least now we've you
03:21:00 ilt and so on so at least now we've you know at least we've addressed it in one day um and um and so on we feel that the 2nd of may we we called for a 30th of April minimum
03:21:11 April minimum deadline um and we feel that second of May is a reasonable um dead line and we feel that's a sensible one to apply um you know as a minimum to everybody I
03:21:23 you know as a minimum to everybody I understand that some people have been given earlier deadlines and some people have offered earlier deadlines um and where we where we can try and get material in earlier I'm sure we will do so because we are committed to a
03:21:38 so because we are committed to a successful inquiry um so finally I just want to say that um we want to work collaboratively together I think it's really important to
03:21:50 really important to uh resume the regular T3 meetings as we had throughout T2 where a lot of these issues were addressed throughout T2 we had very constructive weekly or fortnightly meetings with the
03:22:01 fortnightly meetings with the team and we were able obviously as a litigant in person I was part of those meetings with the lawyers and I could bring matters forward that I'd been asked to do so from other core
03:22:15 asked to do so from other core participants so I feel like let's get the T3 meetings going as soon as possible let's learn from T2 uh and and
03:22:28 possible let's learn from T2 uh and and let's um get the show on the road thank you if I respond to your last Point uh the meetings will be resumed uh the meeting uh the latest one fixed was
03:22:45 meeting uh the latest one fixed was cancelled because today's hearing was fixed at the Urgent request of uh a large number of uh signatures 92 individuals and groups and um I will have something to say about that in a moment but that is the reason why that meeting was cancelled um today has
03:22:59 meeting was cancelled um today has proved a useful exercise as I'm glad you've acknowledged um I make it clear I repeat what I've already said that the time for dealing with uh applications
03:23:11 time for dealing with uh applications for privacy uh redactions over documents disclosed by the inquiry is not going to
03:23:24 disclosed by the inquiry is not going to be extended beyond the 11th of April I'm glad to hear from you that the 2nd of May is an acceptable date for the provision of witness statements in the case of Helen steel that has been extended at her request to the 6th of June thank you both and um uh that I
03:23:40 June thank you both and um uh that I think apart from uh gusen Heaven perhaps being offered the opportunity of making a a short statement at the end concludes today's proceedings so I I wonder whether I could come back to you about
03:23:52 whether I could come back to you about the issue of cutting and pasting in Epic it seems rather small technical detail after everything we've heard but it is an
03:24:02 an important unsurprisingly I got it wrong I am not the person to deal with the technical
03:24:10 technical issues so so so you got it wrong but you you are capable of making what you said right and I'd ask you if you could arrange for epic to enable us to cut and paste all the documents um I will certainly ask but I cannot from my own knowledge as is
03:24:23 cannot from my own knowledge as is obvious give you the answer and I don't know what it may be but I will certainly ask sir I can perhaps I can interject yes my understanding is uh that you can
03:24:48 yes my understanding is uh that you can cut and paste from the index you can cut and paste from the rule n request you cannot cut and paste from from the documents and uh I understand that changing that
03:25:03 I understand that changing that is best I understand it's something that cannot be done because of the way the documents have been and I think the technical term is flattened so that is my understanding of course we can double check that and confirm it but that is my present understanding I would be very grateful
03:25:18 understanding I would be very grateful if you could maybe they could they would know how to unflatten a document I am not going to intervene further in this
03:25:30 further in this discussion thank you um Miss Heaven thank you sir good afternoon um I appreciate it's late in the day so I'll keep it short just some short points so you clearly have my written submissions yes and they were very helpful I read them with interest and they were
03:25:41 them with interest and they were constructive and I'm grateful for you so today's hearing was prompted by the open letter that was published by over 90
03:25:52 letter that was published by over 90 non-p police non-state cor participants who were facing intolerable pressure some of which you've heard about today and stress arising from the unrealistic deadline that was unilaterally imposed
03:26:04 deadline that was unilaterally imposed by the inquiry for the provision of rule 9 witness statements and as as you know and you've just heard from a moment ago from Mr Morris this led to multiple timec consuming requests for extensions of time now the general position of all
03:26:20 of time now the general position of all all non-p police stakehold participants is that they want to be asked to do things within a realistic an affair deadline and in a way that does not lead to individual core participants being singled out or required to make
03:26:33 singled out or required to make individual applications for more time often in Reliance on difficult personal circumstances now of course there clearly may be circumstances where this is unavoidable but as a general rule it
03:26:46 is unavoidable but as a general rule it is the position of the nonp police state core participants and their request that they ought to be subject to the same fair and reasonable deadline ultimately this will reduce delay and unnecessary
03:27:04 this will reduce delay and unnecessary stress and unnecessary applications at a time when serious work clearly needs to be
03:27:05 be undertaken now as Mr bar rightly acknowledged at the start of this
03:27:16 acknowledged at the start of this hearing it is of critical importance to this inquiry that it receives the best evidence it can from the non police state Corp participants the nonp police state Corp participants wish to make the point that whilst there is clearly pressure on the inquiry to report as soon as possible
03:27:27 inquiry to report as soon as possible obtaining the best evidence means that everybody engaged in this inquiry needs adequate preparation time and not just the inquiry itself the nonp police state Corp
03:27:39 itself the nonp police state Corp participants ask that lessons are learned from what has preceded today's hearing so that unrealistic deadlines are avoided future and for this to
03:27:53 are avoided future and for this to happen it is critical that the inquiry continues to adequately and regularly communicate with a nonp police state core participants and I know that they will be heartened by your comments a moment ago about the meetings um
03:28:10 moment ago about the meetings um resuming the regular meetings resuming because as you know that is something that it did assist in trch to albeit there were some disagreements But ultimately it did assist so the nonp police state cor participants wish to emphasize and you've heard heard this from a number of Representatives today that they do
03:28:21 Representatives today that they do remain committed to engaging with the inquiry but this also requires the inquiry to adopt a fair approach in its treatment of nonp police state core participants and one of uh these approaches is being consistent with a
03:28:38 approaches is being consistent with a trauma informed approach so it's noted today that you have granted some realistic extensions of time for service of Rule n
03:28:44 of Rule n statements now so I've addressed in the written submission some of the Practical issues being caused by epic as well as the way in which disclosure has been
03:28:58 the way in which disclosure has been clustered and indexed by the inquiry and how this is causing delay and you heard some more examples this morning from Miss Dion um and again just a moment ago and helpfully some matters were clarified but if I can just make a few more short points to see if Improvement
03:29:16 more short points to see if Improvement can be made so that work can be sped up um so if you can just bear with me I'm I'll only be a few moments um and I might get a little bit technical but this is obviously not just for your benefit but for also for the benefit of those
03:29:25 those listening so so the functionality of Epic is poor particularly when compared to Opus that as we know was used in
03:29:36 to Opus that as we know was used in tranch one this is not an overstatement of the position but it is the reality but this difficulty is combined with how the inquiry has documented and described the disclosure on
03:29:48 described the disclosure on Epic so for example each document on Epic has a properties section which we understand is manually
03:30:01 understand is manually populated this section includes things like the control number and a description of the document however when the property section was populated the date of the
03:30:13 section was populated the date of the document and the nominal of the officer who the reporting related to was not inputed on into Epic now as we understand that the index is Created from this property section on Epic and so when the index is automatically
03:30:25 so when the index is automatically generated it does not contain a date or a nominal um for the undercover officer by reference to each specific report now this is a significant
03:30:39 report now this is a significant departure from trch one where of course we had hard indices that did contain dates and it's also somewhat a departure from the indices that some of us or some of the nonp police state cor
03:30:51 of the nonp police state cor participants had in tranch 2 which again did contain dates I mean the reality is not having a document dated on an index
03:31:02 not having a document dated on an index or even on Epic makes understanding the disclosure virtually impossible um particularly where those documents can't just be sorted chronologically on Epic and essentially on Opus that's what we did as well as
03:31:13 on Opus that's what we did as well as having the index we just clicked on the DAT icon and everything was instantly in chronological
03:31:26 chronological order so we asked the inquiry to focus on trying to resolve this issue um in particular by reference to the date because it is considered that this will significantly assist with speeding at work on the rule n statements um now but hopefully as well in the
03:31:40 hopefully as well in the future another related issue is that the disclosure on Epic often not not necessarily always but often from what I heard Bears no relation to the order by which documents appear on the index so
03:31:51 which documents appear on the index so so I undertook earlier a spot check of Miss Steel's disclosure as this is the only T3 disclosure that I can currently see so this is not all Miss Steel's T3
03:32:05 see so this is not all Miss Steel's T3 disclosure just a very small proportion of it but what is immediately apparent is the order of documents on Epic in the folder there's no relation to the uh
03:32:18 folder there's no relation to the uh ordering of the documents on the index essentially the documents on Epic are simply a mass of documents jumbled
03:32:29 simply a mass of documents jumbled together and as indicated by m steel a moment ago the obvious solution aside from a master index is essentially a spreadsheet of the disclosure which would be a k to a Master index um at the very least having the um control number on it the document description uh the officer's nominal and
03:32:44 description uh the officer's nominal and crucially the date of the document which can then obviously be sorted through the spreadsheet very easily on Excel technology and then analysis can either
03:33:01 technology and then analysis can either be put into that Excel document or that Excel document can simply be used to sort the
03:33:05 sort the material so this this work clearly needs to be done so that's dating and clustering of documents with nominals control
03:33:10 control references previously this work was undertaken by the inquiry at it as it clearly the inquiry's job to do this work it's critical that this work continues to be done by the inquiry
03:33:27 continues to be done by the inquiry before disclosure otherwise the burden of doing this work is simply shifted onto the nonp police state core participants and that this is clearly what's happened in tranch 3 and and what's contributed to some of the problems and delays that have
03:33:38 problems and delays that have Arisen this cuts into time for preparation of the statements but as you've heard and I've made the point many times it just makes analysis
03:33:49 many times it just makes analysis virtually impossible particularly where you can't print but hopefully that that's been fixed now now in terms of deadlines you'll know sir that there is that General request in my written submissions referencing the 30th of April or 12
03:34:05 referencing the 30th of April or 12 weeks whichever is later from receipt of the rule n request clearly matters have moved on in today's hearing um I understand that there may be some nonp police state core participants who not withstanding any general extension May in fact be in a position um to submit
03:34:17 in fact be in a position um to submit their statements within their deadline and obviously if they can they should as that would clearly assist the inquiry I think that all that I can ask at this stage is that you consider any extended
03:34:31 stage is that you consider any extended deadline um to be afforded to any other non-p police state cor participants who may require it to the 2nd of May but clearly I'm not in a position to make
03:34:43 clearly I'm not in a position to make detailed representations on behalf of individual core participants so I'm really making this request as a general request reflecting on the higher level points that I have raised so I don't
03:34:54 points that I have raised so I don't think I can really say anything more about
03:34:59 about that moving on to a separate um discret issue so can I ask for um urgent clarification from the inquiry on the date for submitting reporting restriction order
03:35:10 restriction order applications by way of background a letter was received from the inquiry of the six of um March 2025 suggesting the deadline was the
03:35:24 2025 suggesting the deadline was the 11th of April 2025 I.E the same date as applies for privacy um redaction applications rro applications are not required for preparation of the bundle and actually they can't be sensely
03:35:38 and actually they can't be sensely sensibly submitted before statements have been finalized and before full instructions can be taken in light of said fully completed witness statements there is the real risk that if Ros are
03:35:54 there is the real risk that if Ros are sought too early in the process then the inquiry will face similar difficulties that arose very recently in tranch 2 around needing to finesse the wording in light of full reflection on all of the disclosure so so can I because there
03:36:08 disclosure so so can I because there isn't those bundle implications for the inquiry can I ask you to make an order today sir that applications for Ros are to be made when witness statements are served or by or by a later date with
03:36:24 served or by or by a later date with prior agreement uh from the inquiry I'm I'm hoping that's not controversial because it's as I say there are no uh implications for the bundle but Clarity is is required
03:36:36 is is required there and then I was finally going to move on to the issue of communication it's clearly been touched on already at length by lots of different individuals and co-participants
03:36:50 co-participants you know that there was supposed to be a meeting today but it was postponed it's again just a plea to to ensure that those regular meetings are recomened I
03:37:04 those regular meetings are recomened I know you've indicated that there will be they did entr two albeit there were disagreements head off and diffuse difficult matters and avoid miscommunication before there became a crisis so I think that's you know ultimately why those meetings are in the end important important just finally
03:37:17 end important important just finally there's another issue that I'm asked to raise a general issue and this is just a flag to you sir that um I am informed by lots of nonp police state cor
03:37:29 lots of nonp police state cor participants that sadly the inquiry team is at this point now not responding to emails at all um for quite significant periods of time or not doing so promptly in the required time that the inquiry it's set for itself and I understand
03:37:45 it's set for itself and I understand there's potentially quite a significant backlog obviously a lot of issues have been resolved today but I understand that that is still an ongoing issue so I'm just asked to raise that today as we
03:37:56 I'm just asked to raise that today as we have an opportunity to raise things with you so so those are my submissions unless I can assist you further thank you yeah I'm grateful to you for those submissions I am not going to respond to
03:38:09 submissions I am not going to respond to your two specific request requests today uh that needs input from the inquiry team uh and those who are assisting them with technical issues which I cannot get
03:38:21 with technical issues which I cannot get instantly and I doubt would be useful if I were to attempt to do so but uh what you've said has been noted and uh will be acted
03:38:28 be acted upon understood thank you sir um I'm afraid I must end with one uh Point uh we're now only 5 minutes after we've got to conclude completely uh and that is this the cops
03:38:51 completely uh and that is this the cops uh statement which requested uh today's hearing uh purported to be signed on behalf of 92 individuals um I have reason to think that uh not all of the individuals upon whose behalf the letter was purported to
03:39:10 whose behalf the letter was purported to have been sent uh could conceivably have signed it uh it included for example uh seven people who have already provided
03:39:24 seven people who have already provided evidence to the inquiry uh and I find it difficult to believe uh that they would have um wished to make submissions uh about um a stage of the inquiries hearings in which they are not being requested to participate so for th those reasons uh
03:39:44 participate so for th those reasons uh in Future No letter of uh this kind will be considered by the inquiry unless it is uh
03:39:47 is uh produced by the recognized legal Representatives so could I just um jump
03:40:01 Representatives so could I just um jump in there just to clarify everybody that signed that letter did indeed say that they supported that letter it's true that some people had already or weren't um yeah had already submitted statements or whatever as you said but they wanted to sign in
03:40:16 to sign in solidarity as far as I understand and um every single name is verifiable uh as someone who came forward to sign that statement voluntarily well um you know the you
03:40:33 voluntarily well um you know the you will know better the uh authors of the document than I do all I'm saying is that um I have reason to think my thought may not be justified but I have reason to think that um not
03:40:44 but I have reason to think that um not everybody who uh who uh who whose name was given as a signatory not necessarily a supporter but as a signatory of the letter uh did in fact sign it or
03:41:00 letter uh did in fact sign it or indicate their Ascent to it in it in the form in which it was sent and for the avoidance of doubt and difficulty in the future all I'm saying is that any such Collective letter must come through uh the recognized legal
03:41:13 the recognized legal Representatives letters from individual will of course be um treated as from the individuals who've signed them or attested them in a manner that uh makes
03:41:27 attested them in a manner that uh makes it clear that it comes from them uh all I'm pointing out is that corporate statements of that kind uh will not uh I anticipate in the future be responded
03:41:44 anticipate in the future be responded to that concludes today's proceedings um thank you all we have made progress uh the progress I hope satisfies some of the difficulties uh in which people have
03:41:55 the difficulties uh in which people have found themselves uh it is as I indicated at the
03:41:56 at the start uh
03:42:06 start uh not a discussion exercise but a decision exercise decisions have been made they will not be departed from Save in circumstances that could not now be anticipated and where exceptional circumstan ances in addition
03:42:22 circumstan ances in addition rise this is the final say not a step towards the final say thank
03:42:30 say thank you that concludes today's hearing thank you
03:42:44 all e