A directions hearing where the Chair considers multiple applications from non-state core participants seeking extensions of time to respond to Rule 9 witness statement requests for Tranche 3. The hearing addresses tensions between the inquiry's need to proceed expeditiously and participants' trauma-informed needs, with discussions of Epic platform issues, privacy deadlines, and individual circumstances.
00:37:37 James, you might need to put yourself on mute.
00:37:39 mute. Uh, okay.
00:37:41 Uh, okay. [Music]
00:37:51 Are we ready to
00:38:02 start? Right. Good morning everybody and uh welcome to today's rather important directions hearing. The uh hearing is going to be livereamed subject to a 10-minute delay.
00:38:13 10-minute delay. uh anybody who uh wishes to apply to have the live stream cut uh has that 10-minute gap in which to do so. Uh proceedings will also be uh not
00:38:33 proceedings will also be uh not livereamed where applications are made that parts of them should be heard privately. Mr. Bar. Sir, I appear today on behalf of the inquiry with Miss Hemingway and Mr.
00:38:46 inquiry with Miss Hemingway and Mr. Ssbury. Uh, Ms. Heaven appears on behalf of the non-state core participants. As you know, she has provided a clear and helpful note setting out the NAT core
00:38:58 helpful note setting out the NAT core participants general position and that will be published uh on the inquiries website. Miss Johnson appears on behalf of clients represented by Burberg
00:39:13 of clients represented by Burberg Pierce. Miss Dayton on behalf of client represented by Dayton, Pierce, Glenn. Mr. Greenol and Ms. Lewis on behalf of clients represented by Hodgej Jones and Allen. Uh I understand that Ms. Al-
00:39:33 Allen. Uh I understand that Ms. Al- Shaili is attending in a non-speaking capacity in respect of those clients represented by Imran Khn and partners who rely on their written submissions. Miss Dagustinino
00:39:51 written submissions. Miss Dagustinino appears on behalf of clients represented by Kelly's. Mr. Scobby Kings Council on behalf of clients represented by the public interest law center. Mr. Morris
00:40:02 public interest law center. Mr. Morris and Miss Steel appear as participants in person. The purpose of today's hearing is to consider a number of applications for extensions of time in which to respond to the inquiries rule nine
00:40:14 respond to the inquiries rule nine requests for witness statements from non-state non-p police core participants in tranch 3.
00:40:26 in tranch 3. You will also wish to clarify with the relevant advocates or participants in person as the case may be the positions of those who have received a rule nine
00:40:41 of those who have received a rule nine request for a Trunch 3 witness statement and whose names appeared on an open letter sent to the inquiry by the campaign opposing police surveillance before deciding how to respond in each
00:40:55 before deciding how to respond in each case, noting that only those signitaries who have not subsequently regularized their position by agreeing an achievable deadline with the inquiry legal team
00:41:08 deadline with the inquiry legal team will need to be heard. On its face, that letter threatens the deliberate withholding of evidence from the inquiry by named individuals and groups.
00:41:24 by named individuals and groups. I should make clear that our starting point is that the inquiry wants the evidence that we have requested. The voice of civilian witnesses is important in our mission to get to the truth. No one who listened to their
00:41:37 truth. No one who listened to their evidence in our evidential hearings to date could be in any doubt about that. However, the inquiry's terms of
00:41:50 However, the inquiry's terms of reference require you to report as soon as
00:41:51 as practicable. You also have a duty to act
00:42:03 practicable. You also have a duty to act fairly. In practice, this means that the inquiry must afford the recipient of a rule nine request for a witness statement a reasonable time in which to respond. A period which may vary
00:42:16 respond. A period which may vary according to the circumstances of each individual concerned. But no more time than that. This is because delays in the provision of witness statements will delay
00:42:32 of witness statements will delay preparation of the T3 hearing bundle and if great enough threaten the T3 start date and the date by which the inquiry can report.
00:42:44 can report. unjustified delay on the part of one participant is not fair to others. The October 2025 start date for TR 3 may seem far away. It is not. We
00:43:00 TR 3 may seem far away. It is not. We will need to release the hearing bundle or at least substantial coherent parts of it in early July, 3 months before the start date. If people are going to have
00:43:14 start date. If people are going to have the time they need properly to consider what will be a very large quantity of evidence, privacy restrictions need to
00:43:26 evidence, privacy restrictions need to be applied and final checks conducted in relation to many thousands of documents before they can be added to the hearing bundle and released to core participants.
00:43:41 participants. This takes time, especially because it is important that privacy rights are properly
00:43:45 properly respected. Determining what should be redacted is not always straightforward, especially where very private evidence is also of great
00:43:58 private evidence is also of great evidential value. Witness statements and privacy
00:43:59 privacy applications provided as soon as they reasonably can be are essential for this
00:44:19 reasonably can be are essential for this process. Sir, I understand that you wish to hear from the advocates sequentially hearing in each case their submissions in respect of each of their clients outstanding applications. Miss Johnson for Burberg Pierce's clients will be first. Thank
00:44:41 you. Today we are concerned with two dates. Uh the first is the date by which applications for privacy redactions uh on those documents that have been produced by the inquiry uh must be uh
00:44:57 uh must be uh determined. That date is fixed. It is the 11th of April. Any applications for of that nature which are not received by the
00:45:09 nature which are not received by the 11th of April will mean that privacy redactions over those documents in relation to the relevant individual will be determined by the inquiry. The second date and that which is uh
00:45:30 The second date and that which is uh going to be the subject of submissions today is the date upon which witness statements requested by the inquiry from individuals are to be provided uh together with any exhibits or other documents that the individual may wish to
00:45:47 individual may wish to produce. Uh like Mr. are I welcome the participation of individuals in the inquiry. I acknowledge as he does that
00:46:00 inquiry. I acknowledge as he does that it is an essential part of our process but as he points out uh time is not unlimited and to enable the inquiry to be conducted and for me to produce a
00:46:15 be conducted and for me to produce a report based upon the evidence which I will have by then have considered uh things must be done on time. Today dates are going to be fixed. This is not an occasion for a general
00:46:28 is not an occasion for a general discussion uh about time limits or other issues. It is a date upon which decisions are going to be made and subject of course to uh those
00:46:42 subject of course to uh those circumstances which are exceptional and I emphasize and which cannot now be foreseen. The dates fixed today will be the dates upon which events must
00:47:01 occur. As Mr. Bar indicated, uh we're going to hear applications in the order uh of the firms uh who have made them and then uh the two litigants sorry the two participants in person at the end. I invite Harriet
00:47:16 person at the end. I invite Harriet Johnson to make the first submission.
00:47:25 Uh um I'm perfectly happy to begin my submissions, but my understanding was that Miss Heaven had some general submissions she wished to make first. I just wanted to clarify whether you wish to hear from her before me. Um as I'm as I've indicated dealing with dates, I
00:47:37 I've indicated dealing with dates, I will hear Miss Heaven when she makes submissions on behalf of Kenny's. Um but
00:47:51 uh I I I I I do want to hear uh the submissions of those
00:48:00 who apply to have specific dates set and I wish to do so in the order in which they're um set out and so I invite you to start. I'm grateful sir. So I can begin by talking about specific dates
00:48:11 begin by talking about specific dates and then I can give um some reasons in
00:48:22 and then I can give um some reasons in support of my application if I can do it in that way it may assist. Yes. So the deadline currently in place for the statement of Helen Steele and forgive me I ought to say um Miss Steele will address you uh separately in relation to her submissions on midel. Yes. Um so I
00:48:39 her submissions on midel. Yes. Um so I won't deal with those. Um the deadline currently in place for M steel is the 4th of April. The extension sort and I ought to say at the outset sir all of these extensions all of these dates have been carefully considered and are in the
00:48:59 been carefully considered and are in the view of those who instruct me and of our lay clients the earliest realistic date by which these statements could be provided. The state miss the date Miss Steel seeks is the 6th of
00:49:18 June. For Ellie, the current deadline is the 24th of March and the extension sort is until the 28th of
00:49:28 April. For Lindsay, the current deadline is the 19th of March, so tomorrow. And the extension sort is until the 14th of May.
00:49:43 So you will have seen that although other um category H core participants are mentioned in our um submissions, no formal application has made has been
00:49:54 formal application has made has been made yet by those women who continue to work towards their statements and and make no application at this date. Well, um, give me dates are going to be fixed today for everybody.
00:50:14 So, may I um await instructions from um from my solicitors on on those points then and and continue to address you generally as to reasons.
00:50:27 uh I am bluntly less interested in general reasons than I am in practicalities relating to individuals. So yes, when I say general reasons, I mean that there are some circumstances of course that apply to all of these um participants rather than repeating them
00:50:41 participants rather than repeating them for each each woman. Forgive me. What I am interested in doing is in setting dates for each individual. It is not helpful to have general applications uh without the end date being in mind.
00:50:55 without the end date being in mind. So then um my instructing solicister informs me that she'll provide those dates um very shortly. Perhaps I can
00:51:06 dates um very shortly. Perhaps I can What is meant by very shortly? Today is the day on which dates are going to be determined. So yes, during the course of this hearing. Um, forgive me if you if you're not able
00:51:19 Um, forgive me if you if you're not able to uh advance submissions for all of the individuals that uh you the firm who instructs you represents. Uh then uh I had better I think start with someone
00:51:30 had better I think start with someone who is in a position to deal with every individual that their firm represents. Very well said. Um, forgive me, I don't mean to be discourtesous, but unless we do these things um, systematically and in detail and by reference to each
00:51:45 in detail and by reference to each individual, we're not going to make progress.
00:51:56 Then um can I put you back uh to enable you to get the instructions from your solicitors about the individuals and would you let the inquiry team know when you're ready to proceed? Yes, sir. Thank you. Thank
00:52:14 you. In that event, uh I think we next then proceed to Miss Dayton.
00:52:21 Good morning, sir. Thank you. My application is on behalf of Dwayne Brooks. Yes. He applies for the inquiry
00:52:40 Brooks. Yes. He applies for the inquiry to ask him to submit his R9 statement by May the 8th. So that is 12 weeks from the date of service of the R9 request. The reason for this application, sir, is simple. Mr. Brooks is unable to provide a statement
00:52:52 is unable to provide a statement addressing 15 years of traumatic eventful
00:52:54 eventful uh occurrences from the time that he was a teenager within the original deadline.
00:53:05 a teenager within the original deadline. To use uh Mr. Bar's words just now, that is simply not achievable. So there were written submissions dated 14th of March. Could I just check that you do have those? Yes, I do.
00:53:16 I do. Then then if I may, I'll take them through you very briefly. So the reasons fall into various categories. The first is the scope of the R9 request. It's farreaching and very demanding of Mr.
00:53:29 farreaching and very demanding of Mr. Brooks. In terms of time, as I've said, he's asked primarily only to address his experiences between 1993 and 2008, a 15-year period, a very long
00:53:42 15-year period, a very long period. In terms of the quantity of disclosure from the inquiry, he was provided with a large number of documents, 267, many of which were
00:53:54 267, many of which were multi-paged or most of which were provided only on the 20th of February. In terms of the issues, the questioning
00:54:07 In terms of the issues, the questioning from the R9 deals with a large number of very different types of occurrences. The most general and demanding is perhaps his involvement in, and I quote it, challenging state misconduct and anti-racism
00:54:21 misconduct and anti-racism activism focusing on these same 15 years. and to detail his involvement with any groups that fall into that
00:54:34 with any groups that fall into that description. He's asked also by way of another example to give details of his relationship with seven individuals. Some of those relationships are very longstanding and very
00:54:52 longstanding and very complicated. He's asked also to deal with a number of false criminal allegations against him. In terms of his own documentation, sir, he's asked, as you know, to provide documents that he considers to be relevant to these questions. He of
00:55:06 relevant to these questions. He of course will want to do that, but it's also particularly necessary for him to research and identify relevant contemporaneous documents because this period starts not only when he was a
00:55:17 period starts not only when he was a teenager, but when he was a teenager suffering from chronic post-traumatic stress disorder. Both factors as as you know sir affect memory. It is essential for him to be able to give the best
00:55:29 for him to be able to give the best evidence to have access to relevant contemporaneous documents. And so it matters. But to give you a sense, these
00:55:41 matters. But to give you a sense, these will be contemporary notes and documents from the Lawrence inquiry from Perm in relation to each criminal allegation in relation to each meeting raised by the inquiry in relation to the ongoing
00:55:55 inquiry in relation to the ongoing investigation into the murder of Steven Lawrence and attack on Mr. Brooks and in relation to each of those meetings that took place. As you'll note, one of the previous inquiry was the covert recording of a meeting
00:56:10 the covert recording of a meeting between the then assistant commissioner John Breeze, Mr. Brooks and
00:56:26 myself. We can't name them. The the scoping has only just started, but we do know that our firm has a considerable number of documents that need to be accessed.
00:56:32 accessed. So the next factor is the solicitor taking the instructions. I consider and would urge you to accept that it would be very counterproductive, slow and timewasting for anybody other
00:56:49 slow and timewasting for anybody other than myself to take these instructions. Sir, I have knowledge of many of the events. I have knowledge of the individuals and I understand better than any other lawyer the context of many of those occurrences. It would be quicker
00:57:02 those occurrences. It would be quicker and cheaper for the inquiry to allow me the time to do that work. Secondly, it would save the retraumatization which is likely if Mr. Brooks has to explain the context of
00:57:16 Brooks has to explain the context of each of those occurrences to somebody who's not familiar with them. And I go into that in some perhaps too much detail for you. So simply for this, the request for the R9 came the day I
00:57:27 the request for the R9 came the day I went on leave. And so in effect, my time working on this R9 started last week. So we lost three
00:57:43 we lost three weeks. The the other aspects are that in itself is an im immense amount of work, but we are hold that that you would be able to address. were hindered by the way in
00:57:54 address. were hindered by the way in which the Epic system works or doesn't work. To give you some examples, as you'll know, we're not permitted to download from that system. So, in practical sense, what that means is for instance, preparing the written
00:58:05 instance, preparing the written submissions to you, sir. I have to copyight bits from the online study rather than cutting and pasting. I mean, it it must be a nonsense, sir. And also
00:58:18 it it must be a nonsense, sir. And also I don't it might be worth addressing the logic of it because when we are preparing the R9 statements we are going to be referring to the documents. We are going to be referring to the concept contents of those documents. So they
00:58:32 contents of those documents. So they will be in word format in any event. So the prohibition on downloading merely delays the transfer of the content of those documents from epic to the word to words and it would speed things up
00:58:44 words and it would speed things up immeasurably if we could download. The other aspect is we could group the the documents together in a way that makes sense to take instructions. we could
00:58:56 sense to take instructions. we could write comments on the index rather than having to copy type the documents. And um it would save us from another very time consuming problem which is that although we can as you know do the annotations on the documents
00:59:13 know do the annotations on the documents on it the annotations sometimes just get deleted and we're not permitted to download those documents any the annotations anymore which is is a change from tranch 2. So sir, those are the problems we
00:59:27 2. So sir, those are the problems we face and those are the difficulties we have and we don't see them in insurmountable but we do know that it's going to take a long time. But in closing I would like to make two positive points. The first is this. Mr.
00:59:45 positive points. The first is this. Mr. Brooks wants to participate and he wants to provide the best evidence as he can as soon as he can. uh estimate is an estimate because as I've made clear we haven't yet got stuck into the scoping work. The second
00:59:57 into the scoping work. The second positive thing so is this. It's the empathetic way you addressed the timing
01:00:08 empathetic way you addressed the timing for my client Mr. Richard Adams to give a
01:00:13 a statement. The the way you addressed it enabled Mr. Adams to take his time to provide a full statement and to source contemporarius documents and disclose them to you in a way which I think was
01:00:24 them to you in a way which I think was helpful to you and you kindly told him at the end of his evidence that you were impressed with it. Sir Richard Adams
01:00:36 impressed with it. Sir Richard Adams gave impressive evidence because he's an impressive person but sir he could only do it because he was not under great pressure. He had no pressing deadline from you. And what that meant for her
01:00:48 from you. And what that meant for her was that when he felt able, he could go up into his attic and delve into documents
01:00:50 documents that recorded traumatic events in his past. When he s felt able, he could come to my offices to give me instructions. And when he didn't feel able, he felt
01:01:06 And when he didn't feel able, he felt fine, as did I, to say, "Sorry, Dane. I'm not coming in. I can't do it. I can't face it." Now, you gave him time to consider in depth the inquiry's disposal to him and as I've said to source, but also to
01:01:18 as I've said to source, but also to consider the documents that he unearthed from his
01:01:20 from his attic. Mr. Adams was respected and he had some control over the process and sir, this application is in effect
01:01:33 sir, this application is in effect asking you to give Mr. Brooks the same opportunity. Unless I can help you further, sir, that's those are my submissions. They are very helpful. I'm going to pause momentarily because I want to
01:01:41 want to um take uh instructions if I can put it in that way about the downloading issue which I know has been a problem. Um I hope it is capable of resolution. I know
01:01:56 hope it is capable of resolution. I know that I do not fully understand it and it is better therefore if I am informed about it now before I respond to you. Thank you sir. Then we'll pause momentarily. Uh the live stream will be cut while I go and talk to my people.
01:06:42 could Miss Dayton be invited back, please.
01:06:44 please. Sir, I'm here. Ah, you are. Forgive me. I didn't Your face was not on the screen and I was not aware that you were there. um qualified uh good news. Um first of
01:07:01 um qualified uh good news. Um first of all um as far as downloading goes um uh what the inquiry is doing is inviting those who wish to download uh to apply for permission to do so. It has been granted in other cases. Uh I am told
01:07:18 granted in other cases. Uh I am told that there is no reason apparent at the moment why it would not be granted in your case as well. uh so that that aspect of the difficulties that your technical difficulties you're experiencing uh with luck uh will be uh
01:07:30 experiencing uh with luck uh will be uh removed. Secondly, I am told although I don't begin to understand it that um cutting and pasting can already be done without a problem. Well, that's two pieces of good news
01:07:42 Well, that's two pieces of good news then sir. Thank you. Now the second and more the sorry the third and more qualified piece of of good news is this. Uh I uh do acknowledge the very great amount of work that has to be done both
01:07:53 amount of work that has to be done both by Mr. Brooks and by yourself and that I I do acknowledge that the um original uh date is too soon. But I cannot postpone
01:08:08 date is too soon. But I cannot postpone it uh as far as the 8th of May. What I'm perfectly happy to do is to require the uh uh witness statement and any exhibits to be provided by Friday the 2nd of May.
01:08:22 to be provided by Friday the 2nd of May. That uh undercuts your request by a week but by no more than a week. Thank you sir. I trust that is acceptable. That is the decision. Thank you.
01:08:44 Uh next I I think it is uh Mr. Owen Greenol and uh Miss Lily Lewis. Uh provided of course that uh Miss Johnson has not yet got fully instructed which I anticipate she will not have
01:08:55 anticipate she will not have been. Could Mr. Green and Miss Lewis be put on screen please? Sir I hope you can uh see and hear me. Yes I can. Thank
01:09:07 uh see and hear me. Yes I can. Thank you. I hope also that you've uh received uh two documents. One is a a general document with submissions filed on the 14th and the other is a document um with personal individual matters that was filed um yesterday.
01:09:31 filed um yesterday. Yes, I'm grateful. um in terms of the um general applications in I will uh make some uh general points um and then I will be dealing with the specific individual circumstances of um Mr. uh
01:09:44 individual circumstances of um Mr. uh Ben Ley and also reclaim the streets and Paul Grabbit and Miss uh Lewis will be dealing with the other clients. Um in terms of the um cases in in general um those instructing me asked for a an
01:09:57 those instructing me asked for a an extension of time until the end of April for all the uh clients that they represent. Um we set out in our document um at paragraph 8 the nature of the difficulties which
01:10:20 8 the nature of the difficulties which our clients have had in um completing uh the um rule line requests. Um there are in in many case a large number of documents. Um they are also um individual work commitments, health commitments and the like. Um they have also an a lot of them have uh
01:10:37 also an a lot of them have uh psychological issues in engaging with the material which requires um a a careful engagement with with material. Um we um set out in writing our our general submissions and we also adopt
01:10:48 general submissions and we also adopt and support those submissions made by Miss Heaven in relation to on behalf of the non police uh non-state participating group. um that is in
01:11:02 participating group. um that is in relation to the general uh application in terms of the individual circumstances. Um if I might deal uh firstly with um Mr. Lei um we have set
01:11:14 firstly with um Mr. Lei um we have set out in writing in the document provided yesterday
01:11:18 yesterday um the chronology of the applications which have been made already on his behalf um and the difficulties that he has had in um accessing the material. Um he made an application for the for to be
01:11:30 he made an application for the for to be able to download. Uh that took some time that has been granted but took some time to do so. Um it was necessary given uh the nature of some of the questions and
01:11:41 the nature of some of the questions and material disclosed for him to re-engage solicitors um having initially being representing himself. Um and that so there have been a a series of applications made um and uh so far th
01:11:55 applications made um and uh so far th those um applications have been refused. And so on his behalf, for the reasons effectively set out in in writing there, um I seek an application until uh the end of
01:12:09 end of April. In relation to other clients uh which um I represent, as I'm indicated, I seek a general application for until the end of April. In relation to two specific
01:12:21 April. In relation to two specific clients, I I seek a further uh extension until the end of May. Those two clients are reclaim the streets and Paul Gravit. Um in relation to reclaim the streets, there is a a very large amount of
01:12:36 there is a a very large amount of material. There are also a large number of individuals who are contributing to the state the rule 9 statement on behalf of reclaim the streets. Um the statement covers a large period of time. it's not
01:12:48 covers a large period of time. it's not possible for one individual to to cover everything themselves and it needs input from from everyone. Um and so on that basis I seek a a longer extension in relation to Mr. Gravit again he has a
01:13:04 relation to Mr. Gravit again he has a significant volume of documentation. He also has significant work commitments. Um so you may recall that in tranch 2 uh Mr. Grab it um was required to come back on a second occasion to to complete his
01:13:18 on a second occasion to to complete his evidence that has already disrupted his his work commitments. He he's keen to engage with the in inquiry but obviously it has a knock-on effect. Um so so those are my submissions in relation to the
01:13:31 are my submissions in relation to the individuals and uh the wider um clients that I represent.
01:13:39 Um deal with Mr. Ley first. Uh he um apparently made it clear that he would um uh not contemplate providing a witness statement unless a raft of
01:13:50 witness statement unless a raft of further documentation was provided to him. What's the status of that? um in terms of well he wishes to have
01:14:02 um in terms of well he wishes to have disclosure um of that further material in order to comply to complete his um his statement um and he maintains position that that it is relevant to his uh his personal statement. um his position is that he will um review the
01:14:19 position is that he will um review the position uh following this um hearing in on his um ability to comply with the rule 9
01:14:20 rule 9 request. May I make it clear that he is has been provided with the documents the inquiry has which it considers relevant for him to see and uh there is not going
01:14:38 for him to see and uh there is not going to be any further disclosure exercise to him. I say not going to be. There are always occasions which arise for a wide variety of reasons why a a tiny handful of documents might be disclosed but he must not assume please
01:14:50 disclosed but he must not assume please that any further documents are going to be disclosed to him on that basis. What is his application? Um, so my instructions are that that he would he
01:15:03 instructions are that that he would he seeks an an an extension of time until the end of April to provide the statement. Um, why does he need an extension until the end of April? He's
01:15:17 extension until the end of April? He's not provided us with any reasons beyond uh uh the demand that or the request that he sees further documents. Um so so in my submission he he had the request for further documentation is not the only basis of his request. Um the
01:15:32 the only basis of his request. Um the there has been a significant amount of time lost in terms of his accessing the material. Um there were difficulties with with the epic system as as sir has already heard. Um he was required to to
01:15:47 already heard. Um he was required to to download material. It took time for that it to be considerable time for that request to be granted. Um there was um a need to to re-engage solicitors um given some of the material that was disclosed to him that uh caused a a delay. He also
01:16:06 to him that uh caused a a delay. He also has uh been has work commitments and has been traveling abroad for work uh for part of the period during which his his
01:16:20 part of the period during which his his statement um was required. So um he has made uh in time applications for extensions. Um the current
01:16:31 extensions. Um the current um e given um the if one takes account of the general um uh extensions granted for um issues with epic and for documents which have been provided to him that that the six
01:16:43 been provided to him that that the six weeks from then actually takes him up to the end of this month. Yeah. So, so that even on that basis he you know the standard six weeks would take him to the
01:16:58 standard six weeks would take him to the end of end of this month. He he seeks an makes an application until the end of April because um he requires further time to to comp compile but it's not it's not simply on the basis that um he needs the the additional documentation u requested.
01:17:15 requested. Um what is the reason why um he requires until the end of April? um he needs to to deal with the allegations made in or and issues
01:17:28 allegations made in or and issues contained in the rule 9 requests. He he needs time to to do that to go through the material um and to prepare his statement. What Mr. Ley and and all my clients wish to avoid is dealing with matters
01:17:40 matters peacemeal, not being able to provide a single statement which deals with the vast majority of issues in in the round. um a and that that's what he requires the time for. He he's had the um
01:17:53 the time for. He he's had the um documents now for 9 weeks. He must be in a position uh to be able to um provide uh his evidence in the near future, not in the middle term. Um so you have my submissions um even
01:18:06 Um so you have my submissions um even taking into account you know from the date that he the documents became every document became available to him and he was able to download in the rest that takes us up already until the end of
01:18:17 takes us up already until the end of March. So so so um it is not the case that he's had access to everything um up until this point.
01:18:55 I intend uh to um uh raise the points that you have raised with me with the inquiry team. And so at this is likely to be a
01:19:03 to be a uh something that happens uh every time I hear submissions that there will have to be a pause while I briefly discuss things with um the inquiry team. But I
01:19:22 things with um the inquiry team. But I have your submission on Mr. Le's behalf. Now the streets you say that you want until the end of May. Yes, sir.
01:19:24 Yes, sir. Now, that causes uh potentially serious problems for the inquiry. I acknowledge that Reclaim the Streets uh has a lot of documents produced to it. Um uh but um
01:19:42 documents produced to it. Um uh but um uh they have been I think produced now for some time. Let me check.
01:19:56 Yes, you've had them for four
01:20:08 weeks. The standard requests that have received has been for a period of 12 weeks from date of receipt of documents which um uh takes us to a date significantly earlier than the end of May. Um
01:20:22 Well, if it's four weeks to date um and then a further um eight weeks be 12, it's not so far from the end of May. I I accept that it is we I we are asking a a for a bit more time. Uh but clearly when
01:20:38 for a bit more time. Uh but clearly when there is a a corporate statement that is needed be produced particularly when there are a large number of um persons contributing to that and there's no one individual or core group of individuals
01:20:51 individual or core group of individuals who have temporal continuity throughout the period who there is going to need to be further time required because different eras as it were are addressed
01:21:06 different eras as it were are addressed by different um individ individuals and different groups. Um so so it is the combination of the volume of documentation and the number of persons present um involved that that uh is forms the basis of we say the exceptional circumstances that are
01:21:18 exceptional circumstances that are needed for the extension of time sorts until the end of May. Forgive me the documents were provided on the 21st of February. 12 weeks from then does not take us to the end of May. No I accept
01:21:31 take us to the end of May. No I accept that sir. Um yes, I I wasn't saying that that it did take us to the end end of May. Um it takes us um until uh sometime towards the end of April. Uh my my point was was that that
01:21:46 was was that that it's looking at matters in the round. Um it is um
01:21:49 it is um a significant but uh not in my submission disproportionate extension uh to the end of May given the particular factors relevant to that group. Uh I am
01:22:12 factors relevant to that group. Uh I am at the moment minded to extend until the 2nd of May but not the end of May. Um I believe on the basis of what I've been told that extensions until the end of May will throw out uh the process of preparing for the hearings in a manner that uh simply cannot be accepted. Uh Mr. Grab it.
01:22:26 Um
01:22:40 him the same time frames apply uh to him as well. Um both date of service and the comments that I've just made. Is there I assume there's nothing further that you
01:22:53 assume there's nothing further that you wish to add on his part. No sir. Right. And
01:23:01 um I will either hear uh
01:23:19 will either hear uh from uh your colleague uh or um uh break momentarily now. I think it is probably better that I hear from Miss Lewis before
01:23:23 before returning with with a decision. Miss Lewis, thank you sir. Um I make
01:23:35 Lewis, thank you sir. Um I make representations in relation to a number of um core participants represented by Hodgej Jones and Allan. Um I'll break those into two groups. firstly core participants associated with movement for justice and secondly what I'll refer to um as as family campaigns
01:23:47 to um as as family campaigns um dealing first with movement for justice. Sir, as you set out in your
01:23:59 justice. Sir, as you set out in your determination on CP status made in 2018, MFJ was and is a campaigning organization founded in 1995 which participated in several campaigns which were the subject to reporting by SDS officers. Um, four core participants
01:24:13 officers. Um, four core participants that we represent were founding members of that group. Antonia Bright, Karen Doyle, Tony Guard and Alex Oarde. the
01:24:25 Doyle, Tony Guard and Alex Oarde. the latter of whom's been designated as the spokesperson for the MFJ statement for the inquiry. Um it's clear on the disclosure to date um totaling around 350 documents that MFJ um were subject
01:24:39 350 documents that MFJ um were subject of detailed and persistent reporting by the SDS. This has meant that a large amount of time and careful consideration is needed in order for um the CPS that we represent to consider the large volume of documents that has been
01:24:51 volume of documents that has been disclosed in relation to the group and also for them to comment on collectively and individually.
01:25:03 Now I I stress at the outset um that given the emphasis placed on the group by the SDS in the context of its overall surveillance of family justice campaigns and police monitoring groups um evidence from from these individuals and the
01:25:16 from from these individuals and the group itself is absolutely essential to the inquiry's analysis for the justification for and proportionality of such monitoring. Um and in order to conduct a full and fair investigation into the deployment of officers in these
01:25:32 into the deployment of officers in these groups in my submission, it's absolutely essential to hear from these four core participants and from the group as a whole. So I I've set out in some detail in the schedule to our submissions um the personal circumstances that are
01:25:43 um the personal circumstances that are relevant to requests by the ACPS for an extension of time. Um I I given the the personal and sensitive nature of some of
01:25:55 personal and sensitive nature of some of those factors, I don't intend to go into detail um into those circumstances. If you'd like me to, sir, I'd request that that is done in a private session. Um
01:26:06 that is done in a private session. Um but I can I can certainly outline um the dates by which those CPS expect that they can comply with the request for a rule 9 statement. Yes, I I think the sensible method of proceeding would be for identified dates.
01:26:23 for identified dates. There was there was a a brief issue with my sound. I can hear you now. Good. Uh let me start again then. I think the sensible method of proceeding is for um uh you to uh indicate to me the dates upon which individuals uh request uh to
01:26:36 upon which individuals uh request uh to be able to provide a witness statement. uh and um then if uh we do need to go into uh private session uh uh we'll do so then but it may not be necessary.
01:26:48 so then but it may not be necessary. Let's let's see. I'm very grateful, sir. Um if I can begin with Miss Bright. I'm instructed that she'd be able to comply with the deadline for a rule 9 um statement by the 5th of May of this
01:27:00 statement by the 5th of May of this year. Miss Doyle by the end of April.
01:27:08 Tony Guard by the end of April. Mr. Aarde um in light of the volume of of both personal disclosure and disclosure to the group as a whole
01:27:19 and disclosure to the group as a whole and his role in providing the rule nine um statement for the group um would request the 7th of May of this year and for the group as a whole um by the end of May.
01:27:40 Yeah, I think so. That that covers all the CPS associated with movement for justice, then turn on to family justice campaigns if that would assist. Yes, certainly
01:27:53 certainly would. I'm grateful um as we set out um in in our written schedule um and and for reasons that again due to their sensitivity I won't address in this open hearing. Um MSW has made a
01:28:04 this open hearing. Um MSW has made a number of requests the inquiry for a
01:28:15 number of requests the inquiry for a meeting. Um the reasons for that request are explained in emails to the inquiry legal team on the 12th and 18th of February.
01:28:20 February. Now I summarize in my written schedule subsequent correspondence that took place in relation to that request. Um and it's now understood that a meeting um
01:28:35 um between MWS's legal representatives and the inquiry legal team um has has been postponed to the 21st of March. As I understand it, a meeting between MWS and the legal team has not yet been set.
01:28:51 the legal team has not yet been set. um in light of the need for that meeting um and the need for the inquiry to take a traumainformed approach to these procedural decisions and its engagement
01:29:04 procedural decisions and its engagement with core participants. Um we would ask for a deadline for both MWS and MSS of 10 weeks following that meeting. Again, sir, if I can assist on on further details relating to that request and the personal circumstances
01:29:16 request and the personal circumstances of those two CPS, I'd ask to do that in a closed hearing. Uh, indeed. Um I think that both uh MWS and MSS
01:29:28 Um I think that both uh MWS and MSS uh need to understand that if they wish to participate in the inquiry uh that it is not acceptable to say uh we have to
01:29:40 is not acceptable to say uh we have to have explained to us personally and in detail aspects of the inquiries and procedures. Um my understanding of the situation at the moment is that um
01:30:01 uh the slaister uh will uh discuss with the inquiry team next Thursday. That's to say,
01:30:05 um, get my dates
01:30:12 right
01:30:17 on the 20th.
01:30:24 I think the date I had, sir, is the 21st, but but you might but I think you're I think you're right. I think it is Friday. Friday the 21st. You're right. Thank you for correcting me. Um that um uh there will be a discussion
01:30:41 that um uh there will be a discussion with the inquiry legal team and uh uh the solicister for uh MSS and MWS.
01:30:53 the solicister for uh MSS and MWS. Um my current view uh is that um uh unless uh
01:30:59 unless uh by 4 p.m. on the following Monday, that's Monday the 24th of March,
01:31:13 that's Monday the 24th of March, uh MWS and MSS indicate uh unequivocally that they intend to provide a witness statement uh to the inquiry that um what will then happen is that they will be invited to submit uh within
01:31:27 will be invited to submit uh within uh four further days. to say by the end of the week why it is that they their designation as core participants should
01:31:40 designation as core participants should continue. Um I'm afraid that the inquiry cannot proceed on the basis that individuals uh can demand um what has been demanded by MWS and MSS
01:31:53 um what has been demanded by MWS and MSS uh and then a further lengthy extension. It is not acceptable. Um so that's noted. I I I know that the coordinating group referred um the inquiry in its in its written submissions um to the government
01:32:05 submissions um to the government guidance on taking a trauma-informed approach. Um I just note very briefly that that guidance includes principles such as asking individuals what they
01:32:20 such as asking individuals what they need and collaboratively collaboratively considering how these needs can be met. Um I I note that that both core participants under consideration have experienced quite unimaginable trauma
01:32:32 experienced quite unimaginable trauma and and I um know that the inquiry has committed to taking a trauma-informed approach. In my submission, that meeting offers an opportunity to put these principles into action and and would allow the inquiry to understand how a flexible and trauma-informed
01:32:46 how a flexible and trauma-informed approach can be taken to ensuring that both core participants are able to participate in this inquiry and for their important evidence to be heard. Um I I note the the comments you've made in relation to these applications and it it
01:33:01 relation to these applications and it it may be um that a further application for an extension can be can best be addressed following um that meeting.
01:33:15 I intend um to set a date for the receipt of their witness statements if they're going to um uh submit them. But I have made it clear that there is a a
01:33:30 I have made it clear that there is a a step to be taken in advance of that um which uh may have consequences which mean that the inquiry will not be able to receive their evidence or may and I
01:33:42 to receive their evidence or may and I hope it can be uh result in the ing of a date with which they can comply which fits in with the inquiries timetable. But I'm afraid we are here for making decisions rather than for um uh expressing views about how in the
01:33:54 expressing views about how in the perfect world things should be done.
01:34:08 So in in light of those comments um then it may assist for me to briefly address um the two remaining core participants who fall under the bracket of family justice campaigns and the request for an extension in relation to those two CPS. Before we get to that, can I I can I
01:34:22 Before we get to that, can I I can I understand the the date by which uh if uh MWS and MSS are going to provide witness statements, they uh request to do so.
01:34:35 do so. Um sir, as I set out my instructions to to ask for 10 weeks following that meeting. Um in light of um your observations, we would ask for the end of
01:34:48 May and and that's on the understanding that that the meeting scheduled for next week will indeed take place. Scheduled for this week, it's Friday the 21st.
01:34:57 21st. Apologies. The end of this week, sir. Thank
01:34:58 Thank you.
01:35:05 you. Very well I've got the date. Yes. Two others now. Um the two remaining core participants um on which I seek to address you as Devriel and Tish Reel. Um similar considerations in in
01:35:17 Reel. Um similar considerations in in relation to um the the requirement for a
01:35:28 relation to um the the requirement for a traumainformed approach apply um to them as they do to MWS and MSS. Um we've set out some um general observations in relation to the the need for more time for those core participants for whom reviewing disclosure is particularly emotionally distressing um in our
01:35:42 emotionally distressing um in our written submissions. So I won't won't repeat those considerations now. Um Sukde and Tishreel would similarly ask
01:35:53 Sukde and Tishreel would similarly ask for the end of May of this year in order to comply with the request for a rule 9 statement. These dates are later than those canvased before in correspondence. What's the reason for
01:36:04 What's the reason for that? I mean the the what what has been set out in documents that I've received is we want until the 30th of
01:36:15 April. So in in in our general submissions um we set out a general starting point. Um I address you on these core participants in particular
01:36:26 these core participants in particular because they have um exceptional reasons necessitating a later deadline particularly um the the the trauma that they've experienced and the difficulties in reviewing sensitive disclosure. Um
01:36:41 in reviewing sensitive disclosure. Um given indications made by the inquiry, um we we've taken time to consider um realistic deadlines that can realistically be complied with um in order to try to avoid the iterative process that's taken um place so far,
01:36:55 process that's taken um place so far, which has involved multiple requests for short deadlines. Um which is of course ownorous not only to call participants and the legal teams but also to the
01:37:08 and the legal teams but also to the inquiry team. Um, and it's so it's with that need for a realistic deadline in mind, um, that I make that request today.
01:37:16 Okay,
01:37:24 that that I think completes um all of the core participants that that we um instructed by HJA wish to address you on. Sir, I'm sorry. You may wish to
01:37:36 on. Sir, I'm sorry. You may wish to address me only on those. Does that mean what what is to be said about all the rest?
01:37:51 Are there are there any applications in relation to um any other CPS for the reasons that we set out in our general submissions? um we would ask for a deadline of the end of April of this
01:38:06 year and and would rely on um reasons given in existing extension of time applications made by Hodgej Jones and Allan. But I'm afraid that is not acceptable. the individual circumstances must be addressed and
01:38:21 circumstances must be addressed and um I I am perfectly happy to extend some to uh the end of April or 2nd of May time difference doesn't matter greatly but I am not prepared to do it on a blanket
01:38:35 blanket basis and I have had no individual applic reasons advanced for why individuals require that length of Sir, it was it was our understanding
01:38:48 Sir, it was it was our understanding that that you would be assisted by um being addressed on seven particular cases set out in our schedule. Um individualized applications have also been made in relation to other core participants and and the requirement for an extension of time. Um those personal
01:39:02 an extension of time. Um those personal circumstances are addressed in in those individual applications made by HJA.
01:39:13 that I suspect that we will have to have a private hearing while you address those issues. But are you in a position to do so?
01:39:28 Yes. Um between Mr. Greenol and I um we can certainly um address you. Apologies, sir. Um if I can perhaps just just turn briefly um to my learned friend.
01:40:12 Yes, I'm very grateful for that time. Um, our our general submissions um apply in in relation to the group as a whole. Um so if if you require further information about um core participants other than um the submissions made
01:40:30 other than um the submissions made already today and those contained within our schedule um then we will need to provide that separately. You'll have to do it
01:40:39 today. I I cannot avoid re-emphasizing that today is a day for making decisions. I am not prepared to make uh uh general extensions of a kind which
01:40:52 uh general extensions of a kind which make the preparation of the hearings in beginning in October problematic.
01:41:00 But that is um well understood and and that information can be provided um today following this hearing. No no it is to be provided at this hearing. I
01:41:26 is to be provided at this hearing. I cannot but emphasize that today is a day for making decisions not will decide it later. Dates are going to be set today and I therefore need to have today submissions made in relation to individual dates.
01:41:35 That's well understood. Um I think Mr. Green is going to um very briefly address you.
01:41:41 Mr. Green, you may have realized I'm sitting in the same room as as Miss L. Yeah, of course. Yes. Um in in relation to to the other clients that that we represent,
01:41:52 clients that that we represent, obviously there are a significant number and this um hearing has come on at at quite some pace. Um we will endeavor to um take whatever instructions we can about individualized circumstances
01:42:03 about individualized circumstances beyond um what is contained in in the written submissions um that you already have sir. Um and our our solicitors will endeavor to do that um whilst this
01:42:18 endeavor to do that um whilst this hearing is in progress. um given the time scales that is all we are in a position to do in to make per individualized submissions beyond what what we you have in writing.
01:42:35 Um I am going to um break now momentarily to deal with the uh specific requests that you have addressed in relation to individuals both you and Miss Lewis uh and um we will return to those where you have not made uh
01:42:46 those where you have not made uh individual submissions later on in the day so as to give you time to take instructions. I'm grateful that helpful. Good. Thanks. Good. Then we'll pause momentally.
01:59:18 Please begin whenever you're ready, sir. Thank
01:59:26 you, Mr. Green or Miss Lewis. Yes, sir. We're here. Good. Um I'll deal first with uh the position
01:59:37 Um I'll deal first with uh the position of MFJ and those who uh participated in MFJ including Mr. Aad uh for two reasons. First the importance and difficulty of the
01:59:51 and difficulty of the task and secondly the personal rel reasons relating to two of the individuals which are set out in the material that has not been made public. Um uh I will extend the time for uh
02:00:08 Um uh I will extend the time for uh submission of the rule 9 uh statements for all of those concerned in MFJ.
02:00:20 for all of those concerned in MFJ. That's to say um Antonia Bright uh Mr. Doyle uh Mr. Guard, Mr. Oardi and MFJ collectively until the 9th of May. That's Friday the 9th of May. I cannot do it beyond then because otherwise it
02:00:38 do it beyond then because otherwise it will throw out uh the um uh preparation of hearings which do have to start on the scheduled date in October. Um as far as uh
02:00:46 uh the reals are concerned um they originally sought an extension I think until the 30th of April. I'm perfectly happy to extend until the 2nd of May,
02:00:58 happy to extend until the 2nd of May, Friday the 2nd of May, but not beyond. And that is the date by which they will be requested uh to provide uh their rule
02:01:11 be requested uh to provide uh their rule 9 statement. Um as far as uh MSS and MWS go um if uh they are going to provide a statement and as I've I've indicated how that issue is going to be approached uh then the date for the provision of their
02:01:27 then the date for the provision of their uh statement will likewise be the 2nd of May, Friday the 2nd of
02:01:33 May. Um Mr. Lei uh has created um a number of problems
02:01:44 uh has created um a number of problems for the inquiry. Um not least uh that he has um uh recently uh it is said breached the terms on which he could download documents from the Epic
02:01:57 download documents from the Epic platform. Uh which means that he may not have had access uh to all of them since there are three documents concerned. uh but um I'm afraid that uh the time for him to provide his uh witness statement
02:02:16 him to provide his uh witness statement in cannot be extended uh for the amount of time that he seeks. [Music]
02:02:18 [Music] um that the issue about uh the supposed breaching of the terms on which he could download documents uh needs to be uh discussed by me
02:02:33 needs to be uh discussed by me momentarily further before I set the final date for the receipt of his witness statement but it will not be of
02:02:44 witness statement but it will not be of the um the length indicated for others. Understood it. Um, you're going to come back later on in the day about the other individuals, you not? Yes, sir. We're endeavoring to to do our best. Um, of course, there's been some
02:02:58 course, there's been some miscommunication about exactly what was required, but we will certainly make whatever submissions we're able to. Thank Thank you very much indeed. Then um the uh next submissions are to be made uh by
02:03:09 made uh by um Mr. Augustino, I think. Are they
02:03:18 not? Morning sir. Good morning. I I make these submissions on behalf of discreet call participants in the absence of Pete Weatherbe and Hannah Webb who are unable to join the hearing and send their apologies.
02:03:33 apologies. Um, we've put in written submissions um, on behalf of Emily Apple and I want to briefly address you in relation to 56A Infosop because I believe there's been some confusion in relation to um, that
02:03:44 some confusion in relation to um, that civilian group, but I'll I'll deal with each one one in turn. Emily Apple has a current deadline of the 28th of March. The main problem that we have in
02:03:55 The main problem that we have in relation to accessing material is difficulties around Epic. Um, Miss Apple works four days a week and has
02:04:08 works four days a week and has significant personal issues, some of which if you need me to address you further on, I can we can move to a closed session. She's um she only is able to work on her reviewing documents and tagging and annotating at weekends.
02:04:25 and tagging and annotating at weekends. We've lost two weekends um due to issues with Epic and I believe seven-day extensions were granted to everyone in relation to those issues, but there were Epic was also down this weekend which
02:04:36 Epic was also down this weekend which hasn't been factored in. Um and can I interrupt you there because my understanding and yours is different about what happened this weekend. My understanding is that um on the first occasion when there were problems with Epic um it it wasn't indeed resolved
02:04:48 Epic um it it wasn't indeed resolved until Monday, but on Monday, Epic made it clear that um they had a 24-hour help service and that if uh for any reason the system did go down, they were
02:05:02 the system did go down, they were available to put it back up so that the second uh incident, second weekend difficulty uh should not have been experienced. um this last weekend, the 15th and 16th, uh there should not have been any
02:05:16 uh there should not have been any problem at all, and I do not understand there to have been any problem. Well, certainly it was posted on um on Epic that it was down for maintenance from 5:00 p.m. Yeah, quite. But not for the whole weekend, only for No, not for the
02:05:32 whole weekend, only for No, not for the whole weekend. But but core participants only have a limited time to work on their statements and access the material. Um so there have been difficulties and and miss uh special measures have been granted to assist.
02:05:44 measures have been granted to assist. Hold on a moment. I I I quite appreciate these technical problems do occur, but they should not be overstated and if um all that happens is that on Friday evening or Friday early hours of
02:05:57 evening or Friday early hours of Saturday morning as I understand it um uh the system is down for maintenance for a couple of hours then that doesn't create a real problem and it is I think not sensible to submit that it does.
02:06:13 not sensible to submit that it does. Well, only that Miss Apple has that her her time frame to be able to work on this material is at weekends. And if a notice comes up saying Epic is down on Friday from 5:00 p.m., that is the window in which she would normally be
02:06:27 window in which she would normally be working. We don't wish to overstate the problem, but there have been ongoing issues with including her getting access to material and also um issues around the being able to
02:06:38 um issues around the being able to annotate the material that was she was previous on one occasion she was able to do it and then subsequently she was not able to do it. So there have been issues with annotations. Um the main problem we have is
02:06:52 Um the main problem we have is commitments with working, family
02:07:03 commitments with working, family commitments assisting with the estate of a deceased family member and personal issues which have been addressed in previous correspondents and um which are touched on in our application which was submitted in writing. We do expect further exhibits
02:07:17 writing. We do expect further exhibits to be coming. We seek an application for an extension of time until the 30th of April. Uh but I just wanted to touch on Excuse me. I I may may be able to cut
02:07:31 Excuse me. I I may may be able to cut you short because I'm perfectly happy to extend until the 2nd of May. Thank you, sir. Um but what I did want to just touch briefly on is I note that the the hard line in relation to the 11th of April for the privacy reductions. We would obviously if any
02:07:43 reductions. We would obviously if any assoc any associated application must be over for privacy reductions over her own material that includes exhibits and her witness statement must be submitted and
02:07:57 witness statement must be submitted and pegged to that 2nd of May deadline. And I would I don't know that that's been considered, but the original our information from the inquiry was that all privacy reductions had to be submitted by the 11th of April. Whether that was over your own witness statement or not, clearly that needs to be that
02:08:09 or not, clearly that needs to be that needs to be pegged. Let let me make the position perfectly clear. um if it if I didn't in when I made opening remarks, the inquiry requires privacy
02:08:22 the inquiry requires privacy applications over the documents that it has disclosed by the 11th of April. Plainly, it cannot require uh by the same deadline privacy applications over
02:08:38 same deadline privacy applications over a witness statement and for that matter documents provided by the uh
02:08:40 uh witness on the 11th of April. They can only be made when the witness statement and any documents accompanying it are provided. That's readily understood.
02:08:52 provided. That's readily understood. Yeah. Okay. I just wanted to make that clear because well then thank you for for giving me the opportunity of making it clear and I hope it is now clear. Thank you. So the issue in relation to 56A infosop is slightly more
02:09:06 56A infosop is slightly more complicated. Um an application was made for core participant status several years ago in in 2018. The inquiry ruling um that covers this which I could it's ruling number 42 refers to an
02:09:18 ruling number 42 refers to an application being made on the 5th of January 2024 which is not the case. The re the relevance of this is because although 56A has is is not core
02:09:32 although 56A has is is not core participant status, there are two core participants within 56A represented by a different firm and a third civilian who is under the umbrella of 56A infosop and has not
02:09:47 umbrella of 56A infosop and has not received a rule 9 request. It seems that 56A has had disclosure through me and all of all the three core participant stroke civilians have had access to that material. But the rule 9 request has
02:09:59 material. But the rule 9 request has gone to a different firm in relation to
02:10:10 gone to a different firm in relation to one core participant and is included in the questions in relation to another core participant. This rule N request in relation to Carolyn Wilson was only submitted sent to her on
02:10:21 to her on the last f Thursday or Friday I believe. I haven't seen it because it went to a different firm. I would ask that we have time to resolve this with the inquiry as it's clearly a little bit more
02:10:32 it's clearly a little bit more complicated given the backstory of how this has come about with different people having access to the disclosure uh than those who've been sent the rule 9 request. So I would ask for the 30th of April to resolve this so that we can liaz about a way forward uh because I
02:10:47 liaz about a way forward uh because I understand that Caroline Wilson has been sent the rule nine with a deadline of
02:10:57 sent the rule nine with a deadline of very early April um which is in addition to uh other statements that she has to submit personally and contributing to the reclaim the street statement. So while this issue is resolved, I did want to make a a request for an extension of time while we look into the issue
02:11:08 time while we look into the issue because obviously if if I have material access material then I need to leaz with the other lawyers and likewise they have the rule 9 requests that I haven't seen in relation to um the people they act
02:11:19 in relation to um the people they act for. There's slight confusion. It dates back to um an original application dated 2018 which the inquiry has indicated was submitted late but it wasn't in fact it
02:11:35 submitted late but it wasn't in fact it was a renewal of application in relation to 56A. The relevance of this is all as you will have heard in in tranch 2 Andy Kohl's gave the name of a civilian from 56A on his arrest when he was arrested.
02:11:56 56A on his arrest when he was arrested. um the arrest that led to his departure and exit strategy. So the name of that person is relevant. He is not part of the restriction order. The there are two one civilian and two two competitants
02:12:08 one civilian and two two competitants who are and so we do need to get to the bottom of this. I haven't seen the questions that have been asked of 56A but I do have the disclosure. So you've lost it completely. Um it's
02:12:21 So you've lost it completely. Um it's it's it is as confusing as I I set out. There are um but 56A is not a core participant. No. Uh nor is it going to be the individuals who who may or may
02:12:36 be the individuals who who may or may not have had something to do with 56A have received um request for witness statements. Um you do not represent them. What what's the problem? I have the
02:12:51 the disclosure in the capacity of 56A as a civilian group and I've been advising 56A for some time two core participants and one
02:13:02 time two core participants and one civilian who's not part of the inquiry. The problem is is that there there are uh two
02:13:03 uh two firms who are instructed and we just need to get to the bottom of it to and I think the the application is for more time while this is resolved because we hope to get to the bottom with the inquiry.
02:13:18 inquiry. But the rule N request was only received towards the end of last week with a deadline for early April which is three weeks away. Rule N request to whom? Carolyn Wilson.
02:13:33 who is represented by whom Alan
02:13:42 then I don't begin to understand why this is a matter of concern for you. Well, I've got the disclosure and I'm liazing with the civilians for who are involved in 56A
02:13:55 civilians for who are involved in 56A and who are on the restriction order the 56A. If this is you're not instructed by Hodgej Jones and Alan who represent the
02:14:06 Hodgej Jones and Alan who represent the individual from whom a witness statement has been requested. No, that's correct. I don't begin to
02:14:18 No, that's correct. I don't begin to understand what um standing you have in this particular matter other than that I've been assisting 56A Infosar a civilian group and received disclosure for them
02:14:24 for them and dealt with privacy reductions in tranch 2 and had conferences with the relevant people one of whom is a
02:14:37 relevant people one of whom is a civilian who will is involved in 56A infos
02:14:44 infos SH um I will pause for a moment while I attempt to get to the bottom of this with my team but my current understanding is that um uh there is no no decision that I need to make about this issue at all but let me go and ask
02:14:57 this issue at all but let me go and ask them. Well, I think the issue sir is the deadline for the witness statement that has been
02:15:02 has been submitted with it which as I understand it is early April witness statement by that but she is a Hod Jones Allen client not your concern.
02:15:13 client not your concern. Anyway, let me go I'm going to rise to to attempt to get to the bottom of this.
02:17:48 Yes. Um I'm afraid that you have no um standing in this matter and uh any application uh will have to be made if
02:17:59 application uh will have to be made if there is one to be made uh by those who represent Carolyn Wilson.
02:18:09 Well, that M Mr. If I could just say that Mr. Greenh Hall is here. So, he may wish to renew the application that I've just made uh to you bearing in mind what I've just said the when the date the
02:18:21 I've just said the when the date the rule 9 request came through. I'm sure he can hear what you say. Thank you, sir. Thank you. Thank you.
02:18:27 Now, it is I think Mr. Scobby, is it not?
02:18:32 not? Yes. Um so, I hope this is going to be relatively straightforward. Yes. Uh because It relates to a single extension for Lois Austin. Um it's the reasons are
02:18:47 for Lois Austin. Um it's the reasons are set out for it in paragraph five amongst others u in our short note dated the 14th of March essentially and the court will know this well um so you know this well the the position is that
02:19:01 well the the position is that unfortunately Mr. Heron has not been on 100%
02:19:03 100% I've I've seen that and uh I make allowance for that. Yes. And and so we are we are hoping that that you'll grant the extension of sort which is until the 3rd of April
02:19:15 3rd of April 2025. There have been others extended but the the most the length of this one is actually Mr. N. I think the 9th of April but all are going to be done by
02:19:29 April but all are going to be done by then. We would ask the third of April for uh Leo.
02:19:38 Agreed. It's I hope I not I I anticipated this will be relatively straightforward. Yes. So that's all you have to ask. So as as far as the remainder go
02:19:53 remainder go um the clients represented by um public interest law. Uh are you am I being invited to do
02:20:04 Uh are you am I being invited to do anything? No, you're not. So we are more than content with the extensions that have been granted administratively. I just wanted to say to the to you sir that there is actually one dated after the 3rd of April. No extensions are required beyond what's already been
02:20:16 required beyond what's already been granted and we're very happy with what we've got. Thank you. In which case um that makes my life and actually today
02:20:27 that makes my life and actually today yours easy. It does. Thank you. Thank you very much. Thank you.
02:20:44 Now I think we've now reached the point where either I should hear from um uh Mr. Morrisan must steal if they're ready
02:20:56 Mr. Morrisan must steal if they're ready or alternatively if uh those who've been taking instructions uh or either of them are ready from them.
02:21:05 them. So if it assists instructions as to the dates of deadlines sort Yes, I represent. Yes. See, forgive me. Your voice um got lost in translation. Say it again, please. I'm sorry. say I I now
02:21:16 again, please. I'm sorry. say I I now have dates for the extensions sought for all those I represent if it would assist from me now then um it would be a sensible course for me to hear your
02:21:28 sensible course for me to hear your submissions on those dates. Thank you sir. I will do that now. Um so given the um approach you've taken thus far, I wonder if I might revise my um
02:21:42 um my the order in which I wish to address you. Yes. to preempt um any questions. Um I ought to say sir, well I ought to
02:21:57 Um I ought to say sir, well I ought to begin by asking whether you've had sight of our document dated the 14th of March 2025 in which some of the reasons for the extensions we seek are set out.
02:22:09 Uh I have um a long document dated the 14th of March.
02:22:14 March. Three pages, sir. It It ought to be just um then let me just check a moment. The date again, please. 14th of March, sir. 14th
02:22:29 March.
02:22:42 Um I don't believe I have. Sir, could I just uh interrupt briefly? I think the document that my learned friend is referring to is the one that you will find in your supplementary bundle at tab 5, page 49.
02:22:59 I do have that. Forgive me. I I have got that. Thank you very much indeed. Thank you, sir. Um I ought to say as a preliminary matter, Miss Steele is in the room with me. Um it on a different
02:23:11 the room with me. Um it on a different laptop. Um, the reason for that is that she and I had some time ago set aside this entire week to work on her witness statement. We did so yesterday and made
02:23:24 statement. We did so yesterday and made considerable progress. I give that as an example, a case in point for a general observation of the proactive approach taken by all and I I emphasize all whom I appear to represent today. These
02:23:38 I appear to represent today. These applications are made in the spirit of engagement and providing realistic estimates in the hope that they may ultimately save time. Um, so you will of course be aware that
02:23:53 Um, so you will of course be aware that the it goes without saying the people I represent are represented by the same team. And so while it might be reasonable for one team to do one statement in a certain number of days, there are other logistical factors to be um put in play as as you've heard so
02:24:05 um put in play as as you've heard so eloquently said by others ahead of me today. people with lives, jobs, caring responsibilities, and then a team that must manage those those deadlines as
02:24:18 must manage those those deadlines as best they can. I emphasize this s to to make the point that we we do not make these applications lightly. Excuse me a moment. I'm so sorry. So, I I have a
02:24:34 moment. I'm so sorry. So, I I have a cough, so I I may mute myself um in the hope of avoiding passing it on. Um it is also I I hope self-evident that in particular for the category H core
02:24:46 category H core participants the process of providing these witness statements is extraordinarily traumat traumatic. The inquiry has as part of tranch 2 already had expert medical
02:24:59 tranch 2 already had expert medical evidence from Dr. Mike Kazinski on the impact of an approach that places adherence to deadlines or appears to place adherence to deadlines ahead of trauma sensitivity
02:25:14 trauma sensitivity um on at least one category H core participant and it is not in my submission unreasonable to infer similar psychological harm um might arise to
02:25:27 psychological harm um might arise to other women if a traumainformed approach is not taken. I understand entirely sir the observations that you've made earlier in this hearing about the need for practicality and the extent to which the inquiry's hands are tied by its terms of reference but I make the point that um
02:25:42 that um that well bluntly sir deadlines that are not
02:25:43 not achievable do not become achievable simply because they remain the the wish of all of the people who I represent today is to be able to give their
02:25:55 today is to be able to give their evidence to assist in its inquiry that many of them are responsible for bringing about and they they are desperate to engage as well as they can. Um turning then to the individual
02:26:07 Um turning then to the individual applications and starting with Helen Steel who sits in the room with
02:26:19 me, excuse me. Um so Miss Steele um you are aware found the process of writing previous statements extraordinarily difficult and the one that she writes now is the one that is likely to be most traumatic for her
02:26:32 likely to be most traumatic for her relating as it does significantly to her relationship with John Dyn. um she has had some 1,600 pages of disclosure in relation to tranch 3 alone as well as of course the many times more than that
02:26:44 course the many times more than that that she had in relation to tranch 2. Um she also has significant privacy reductions. Forgive me I will say of course tranch 2 material remains
02:26:56 course tranch 2 material remains relevant to her because of the need to address her relationship with John. um she has significant privacy reductions um to consider both in terms of her own statement and in terms of the documents that have been served to her
02:27:08 documents that have been served to her and given the shortness of that deadline um or the proximity of that deadline I ought to say um that of course will be a a priority for her alongside writing her statement. I appreciate that the 6th of
02:27:24 statement. I appreciate that the 6th of June the deadline for which Miss Steele asks is the longest deadline for which you've been asked today. Um but in my submission s in particular in light of
02:27:36 submission s in particular in light of the evidence that you heard in tranch 2 from Dr. Kinski hers is an exceptional application and um given the impact that we know from experience as well as from Dr. Kazinsk's
02:27:48 experience as well as from Dr. Kazinsk's report that short deadlines and pressure have of making it substantially more
02:27:59 have of making it substantially more difficult for Miss Steel to um complete her statement. In my submission, that exceptional application is is fairly made and would be fair to grant.
02:28:19 Um, as you acknowledge, uh, this is an application for an exceptional length granted in relation to an exceptional statement. Please explain to me why a witness statement cannot be prepared
02:28:33 prepared uh, within the sorts of time frame that uh, I have been discussing with others up to now. that precisely for the reasons that I've set out in relation to Miss Steele's trauma and the impact that it has on her ability to engage with the material
02:28:45 ability to engage with the material um as well as of course the exceptional volume of material um that is particular to her case given the range of issues that the inquiry is exploring in which
02:28:57 that the inquiry is exploring in which she is engaged. So the the volume of the material and the um particular way in which the trauma impacts her, which is to say that her it makes it pressure makes it
02:29:09 her it makes it pressure makes it extraordinarily difficult for Miss Steel to engage. And the the only practical way for Miss Steele to be able to draft her statement is for her to have space for her to have breaks, for her to be
02:29:20 for her to have breaks, for her to be able to take considerable time and to approach such matters as she is able to when she is able to. And I stress that I I don't make this application lightly. I make it um based on the medical
02:29:34 make it um based on the medical information that we have and based on experience of of working with Miss Steel on her witness statement so far. I absolutely have no desire to give
02:29:46 absolutely have no desire to give evidence. Um but so you can you can imagine I'm sure um the the wish of all involved to ensure that this statement is completed and is
02:29:58 that this statement is completed and is provided to the inquiry and of course to ensure it's done so in a timely manner that allows the inquiry to properly prepare and the inquiry legal team to properly prepare. But in my submission, a shorter deadline runs the risk, as we know from experience, of making it impossible to provide a statement at
02:30:13 impossible to provide a statement at all, which in my submission is something um a situation in which the inquiry would be considerably poorer. Um as um you will be aware the a substantial part of the statement that uh she will make
02:30:30 of the statement that uh she will make uh covers material that was disclosed to her a very long time ago now. uh the
02:30:41 her a very long time ago now. uh the everything in relation to dines, both the um uh contemporaneous reporting while he was deployed and uh as I
02:30:54 while he was deployed and uh as I understand it, that which was created um after he uh left these shores uh and while she was looking for him. Am I right in in assuming that she's had those documents now for very much longer than um would
02:31:08 for very much longer than um would ordinarily be the case? So some of them, yes, although of course they came through um peace meal. That's not a criticism. It's the nature of things. Um some of them she's had um for more time. Some of them are are now only be only
02:31:21 Some of them are are now only be only now able to be read in context of the statement that she now needs to make. But she's certainly had all of the documents relating to the the deployment of Dyn has she not
02:31:32 of Dyn has she not for a long time now. Um so I can I can confirm the exact dates um with those who instruct me. But but I I I take entirely the the point that you make. Now, I can readily
02:31:44 that you make. Now, I can readily appreciate that she needs time, has needed and perhaps still does need time to read into and to respond to um the uh documents uh which concern her efforts
02:32:05 documents uh which concern her efforts to try and find Dyn and what was done uh to on behalf of the Metropolitan Police to protect him. And um that that is an issue in itself which on which I would welcome her evidence. But I've
02:32:24 would welcome her evidence. But I've also got to examine the evidence of the um operation to deal with her research into
02:32:38 dynams of money that was spent on that. Yes. And these are significant issues that I have got to address in due course. Now, uh uh as far as her
02:32:52 course. Now, uh uh as far as her relationship with Dynes, I would have thought that by now um that ought to have been uh in a position where it could be produced in short order.
02:33:03 So, excuse me. Um certainly some significant if I can put it like that progress has been made in respect of the relationship with John D. Um and I I ought to
02:33:14 Um and I I ought to say traumatic as as Miss Steel found the last trunch and giving evidence as she did in the last trench and the need to prepare her statement and prepare herself to do so. she nonetheless took less recovery time than perhaps one
02:33:25 less recovery time than perhaps one might expect in order that she could begin working on this statement herself. Um
02:33:32 Um so considerable work has been done. It
02:33:43 so considerable work has been done. It is still not ready. Um those those two things are are true at the same time. Um, and the reality unfortunately is that the the subject matter of the statement makes it significantly harder for her to engage with than to draft than perhaps, for example, previous
02:33:57 than perhaps, for example, previous material might have been, even knowing what we know about how difficult she found it to engage with, for example, um, allegations made against her in the past, which though not of such an intimate nature, she still found extraordinarily traumatic to have to
02:34:13 extraordinarily traumatic to have to deal with. So this is the most traumatic thing. So if I can put it shortly, it's the most traumatic evidence she will give. I I I readily understand that in relation to her relationship with Dyn while uh he was deployed and her
02:34:25 while uh he was deployed and her decision to to try and find out what had happened to him.
02:34:31 Um, one of the one one of the things I'd like to raise with you, and I haven't discussed this yet with my team, but I want to raise it as a possibility so that we leave no stone unturned, is um,
02:34:43 that we leave no stone unturned, is um, would it be possible to produce uh, two statements, one relating to her um, relationship with Dyn during the time that he was deployed and the second in relation to her um, efforts to try and find him.
02:34:59 find him. that interestingly um that is precisely what Miss Steel and I had described doing yesterday or had discussed doing yesterday. Um and certainly I I'll confirm my instructions. She's in the room. She hears this. Yes. Um but
02:35:12 room. She hears this. Yes. Um but certainly that was an approach that she um felt would be helpful when we discussed it yesterday. So it may be that we we're in agreement on that. Um I I'm merely a floated as an idea upon which I have not yet um gone back and taken instructions. But um uh I if that
02:35:26 taken instructions. But um uh I if that were to be done um are you able to give me um an indication as to when the first of the two documents could be produced?
02:35:38 of the two documents could be produced? Uh so I I need to take instructions from that. Um perhaps while she gives that matter some consideration, I address you on the other um category H and category J core participants. Of course. Thank
02:35:56 J core participants. Of course. Thank you. Um sir, moving then to um the woman referred to as Lindsy. the her current deadline for her statement is the 19th of March, so tomorrow. Yeah. Um Lindsay is a single parent. She
02:36:15 Um Lindsay is a single parent. She homeschools her child. She is also um in what little time she has left a carer for her elderly mother. Yes. As well as working to support her family. Yes. I I I have read the personal details and if if um there is any difficulty about
02:36:31 if um there is any difficulty about referring to them on an open uh screen, you you can take it that I have read them and I do know what they are. I'm grateful, sir. The other um point I wish to make
02:36:44 to make um forgive me about about Lindsay's case in
02:36:46 in particular, excuse me. And but it it says by way of example of some of the technical difficulties that we have had. A request was made in
02:36:57 we have had. A request was made in Lindsay's case on the 14th of February for permission to download certain documents because there were she was finding them very difficult to work on. They weren't search she had a limited time to work on them when her child was doing activities and her her mother
02:37:15 doing activities and her her mother didn't need her. Um that was not able to be approved by the inquiry until the 28th of February. So that that two week
02:37:27 28th of February. So that that two week delay in in um in approving that request cost Lindsay considerable time as well. Um I only mention that sir because it is it's not something that's in the written application that we make but it's
02:37:40 application that we make but it's something that in my submission weighs in favor of the granting of for the application in her case. So and the application in her case is until when? Until the 14th of May, sir.
02:38:05 Um, from what I know, uh, there would be no difficulty about the 2nd of May. Um, but there would be beyond then.
02:38:16 Well, so as as I said at the outset, and I don't um I don't propose to um try your patience by repeating on every but but each of these dates is
02:38:30 every but but each of these dates is considered by those who instruct me and by my lay clients to be the earliest realistic um date by which they can provide the statements. These are these are not arbitrary numbers that are being offered
02:38:45 granted but the documents that were sent in before today's hearing were all talking about the 30th of April.
02:38:56 So I I may need to confirm my instructions.
02:39:02 Um perhaps that you'd allow me to come back to that point, sir. Of course. Um but at the moment you may take it that um uh I I would have no difficulty with the 2nd of uh May. But um anything
02:39:22 the 2nd of uh May. But um anything beyond that uh would uh or is likely to require particular circumstances which uh make it in effect um imperative rather than merely desirable. So yes, I I'm I'm confirming my I'm seeking to confirm my instructions
02:39:33 seeking to confirm my instructions because the the letter I have in front of me doesn't have in which we make our formal application doesn't have the exact date. Um but I'll I'll No, but the the the the document that was sent on
02:39:46 the the the document that was sent on behalf of all notionally on behalf of 92 individual court participants um uh including Lindsay um I think um spoke of the 30th of April. I understand. Thank you, sir.
02:40:06 you, sir. Um sir turning then if I may to Ellie um and again so I I don't wish to um repeat submissions you've already had. She is addressed and her circumstances
02:40:18 She is addressed and her circumstances specifically are addressed in the letter sent to you um on the 14th of March by those who instruct you. Yes. Um I I think it would be sensible unless you
02:40:33 I think it would be sensible unless you um persuade me otherwise uh to deal with the three uh female uh participants who interacted with HN16
02:40:40 HN16 together. I assume you want to deal with them all together. Uh so I I had proposed to deal with them separately um because they have because they have separate circumstances and some are offer shorter deadlines than
02:40:58 some are offer shorter deadlines than others. Um yes. Um so in in respect of Ellie the deadline the extension she seeks is the 12th of May which I appreciate is not much shorter than the 14th but is feel I have to make that point two days shorter than the 14th. Okay. Um so the reasons for her
02:41:10 Okay. Um so the reasons for her particular set out in the letter. I don't propose to repeat them unless be assisted. No. Um, so there is an application in
02:41:24 Um, so there is an application in respect of Donna, but if I may, I I wish to make that application in in closed session. Yes. Um, in due course. Um, and I I may I say allowed for Miss
02:41:36 Um, and I I may I say allowed for Miss Steel's benefit. I may have to ask her to leave the room while do that. Um turning to the others
02:41:47 Um turning to the others um Wendy who is mentioned in our letter but no um reasons are given I can provide all reasons on
02:41:56 y um her current deadline is the 11th of April. The deadline sort is the 23rd of May.
02:42:10 Um Wendy has two part-time jobs and a regular commitment on average every second weekend. Um she is as a result finding it extraordinarily difficult to find substantial chunks of time as she
02:42:25 find substantial chunks of time as she requires to work on her statement. She's found reviewing disclosure on epic difficulty for difficult for example um having to close one document to cross refer to another has been something that she's found it quite difficult to
02:42:44 she's found it quite difficult to navigate and which um I think all of us can empathize with having experienced those early days of epic usage ourselves. Um, having reviewed her disclosure, there are now matters arising out of that that she wishes to review uh to request further relevant disclosure on.
02:42:59 request further relevant disclosure on. Um, and she's also currently attempting to work on a simultaneous deadline in ongoing and related legal proceedings.
02:43:11 ongoing and related legal proceedings. Um the there is a a time difference and I can seek instructions on the exact number of hours but there is I'm instructed a significant time difference between the UK and Wendy's country of residence um which is of course a
02:43:25 residence um which is of course a further factor um that that limits the available time she has to engage with with those who instruct me.
02:43:49 Um she said you say that she uh requires to see further documents. Um I I will
02:44:03 to see further documents. Um I I will obviously ask my team about that. But uh in general um the position is that all documents which the inquiry considers that an individual needs to see and which it has in its possession are sent to them. Um and requests to see other documents
02:44:17 and requests to see other documents before a witness statement is provided uh are not likely to succeed. So that can be put to one side. Understood, sir. Does that affect the time?
02:44:40 Uh sir, I I'll await instructions. I I don't believe it will. Um it will be because the that was supplementary information that was provided me if I can put it like that. Yes. Okay.
02:44:53 Turning then to um the application on behalf of
02:45:04 Sara. Her current deadline is the 11th of April and the extension sort is until the 23rd of May.
02:45:15 The Sara has very recently suffered a very close bereavement um requiring her to take significant time off work. um while she has now returned to work.
02:45:29 um while she has now returned to work. The emotional impact of the bereavement as well as the the additional um administrative burden of having to catch up on the work that she missed while she was away um has hindered her ability to make
02:45:41 has hindered her ability to make progress with her statement both in terms of time available and in terms of as you can imagine emotional capacity.
02:45:57 Um, so sir on on those grounds, an extension is sought on behalf of Sarah until the 23rd of May.
02:46:12 Anyone else? Uh, so in respect of Allison, forgive me. I I've received instructions this morning in in various different formats. So I Of course, please don't worry. I I'm not at the slightest bit bothered about um uh the
02:46:28 slightest bit bothered about um uh the the need to do this, that, and the other during this hearing. We'll do whatever is necessary to arrive at decisions. Thank you, sir. Um Allison, her current deadline is the 24th of March. The
02:46:42 deadline is the 24th of March. The extension she seeks is only until the 7th of April. Um she has very nearly finalized her statement. Um the answer to that is yes. Thank you
02:46:58 Um the answer to that is yes. Thank you sir. Then I I won't trouble you further. Um in respect of Monica sir her current deadline excuse me um is the 11th of April. Um the extension sort is until the 16th of May.
02:47:14 the 16th of May. um she is about to begin a new job. She wants to create to complete the statement um before then and so her her application is made in um I think in fear of not meeting the 11th of April if
02:47:27 fear of not meeting the 11th of April if I can put it like that. Um she and those who instruct me have worked enormously hard on her statement and she again has
02:47:38 hard on her statement and she again has made considerable progress but there are substantial documents to work through. Um, and as I as I've said, those who instruct me have have 12 rule nine statements. They're all um complex. Um, and as well, the the um significant
02:47:50 and as well, the the um significant emotional impact of the material that Monica is reviewing means that in order to ensure she can um provide her very
02:48:01 to ensure she can um provide her very best evidence, she wishes to ask until the 16th of May.
02:48:11 Well, again, I will need to go back uh to my team, but the um indication at the moment that I have is that there is no problem about the 2nd of May, but there are about dates later than that.
02:48:31 So, that's understood. Thank you. Um sir, I have I have also been asked um on behalf of Ms. McSherry who instructs me um to address you briefly on three category J applications for extensions.
02:48:43 category J applications for extensions. Um Miss McSherry wishes me to uh pass on apologies for instructed council, none of whom fortunately available to attend at such short notice. No, I was very short notice and but no conceivable
02:48:56 short notice and but no conceivable complaint about that. I'm grateful, sir. Um, so I I hope you'll forgive if if my submissions are not as clear as they could be um on on category J. I'm not, as you know, not usually instructed for them, but um dealing with them individually, if I may. Um Mr.
02:49:13 individually, if I may. Um Mr. Wodssworth, his current deadline is the 31st of March. Attention request is until the 7th of May.
02:49:24 May. Um Mr. Wodsworth has only been provided with certain documents in which he is named. He has not been provided with documents which name his organization Anti-Racist Alliance and are therefore um relevant to him. Um Mr. Wsworth
02:49:37 um relevant to him. Um Mr. Wsworth hasn't had confirmation from the inquiry that they do not consider those documents to be relevant to him. So he has been seeking access to those documents um in correspondence with the inquiry. So I'm instructed he's been
02:49:48 inquiry. So I'm instructed he's been seeking access to those documents since the 5th of February. Um the last letter received no response and so the matter
02:50:02 received no response and so the matter remains unresolved. There are also three pages of the documents provided to him um for which he has sought legible copies. Um that repeated request I'm instructed has also gone unanswered. Um there are
02:50:13 Um there are also matters of a private nature that give rise to a request for an extension um which I I can address you about privately sir if you if you wish. Um so
02:50:26 privately sir if you if you wish. Um so he seeks an extension to facilitate the disclosure of these documents and to address the private Yeah. Um the extension sort I can't remember if I've said already the extension sort is until the 7th of May.
02:50:45 Uh sir, turning then, forgive me. Uh turning then to uh the participant known as
02:50:59 known as NMP. NMP's current deadline is the 11th of April.
02:51:03 of April. um they apply for an extension on their own behalf to the 9th of May
02:51:10 2025. Um the reasons given are as follows. um first that compiling a response to
02:51:21 um first that compiling a response to the rule 9 is taking more time than it would for an individual because while there's one point of contact who will sign the statement there are five people reading the documents and contributing
02:51:40 reading the documents and contributing to the LMP statement each with limited availability. Um the clients all work full part fulltime or part-time with other important time consuming commitments during the week. The only real time that they have available to work on rule 9 is at weekends around family and other commitments. One of the NMP clients has
02:51:55 commitments. One of the NMP clients has been abroad from the 31st of January to the 3rd of March and will be abroad again for work unavoidably from the 19th of March to the 28th of March. So all of the clients are firsttime users of Epic
02:52:08 the clients are firsttime users of Epic and continue to struggle to navigate it. the fact that it's only possible to open one document at a time is is is causing them some delay as well. And finally,
02:52:19 them some delay as well. And finally, sir, they are consulting their archive for documents that may assist the rule 9 process, but that that process is taking longer than expected. And so the submission made on behalf of NMP is that
02:52:35 submission made on behalf of NMP is that for them to be able to participate fully and effectively in tranch three of this inquiry they they need more time to consider the disclosure to collaborate and to produce a comprehensive rule 9 response. So the extension sort
02:52:48 response. So the extension sort um the extension sort is until the 9th of May.
02:53:00 That I think
02:53:07 uh is it apart from Guy Taylor has it not? Uh well that's been agreed.
02:53:19 So yes um I forgive me I I think there is one more application in respect of Patricia Patricia Armani to Silva. Yes you quite right campaign. Mhm. The existing
02:53:30 right campaign. Mhm. The existing deadline is the 7th of April. Um the extension sort is to the 30th of May.
02:53:48 extension sort is to the 30th of May. Now, I readily appreciate that there are um u problems of a logistical kind with um with her for a whole variety of reasons that you set out um in relation to the uh deadline for submitting privacy applications. My expectation is that um uh she will not
02:54:03 expectation is that um uh she will not be able to comply with that deadline. Am I right in assuming that? I'm so sorry,
02:54:13 I right in assuming that? I'm so sorry, sir. You've cut out for a moment. Could I ask you to repeat? Of course. Of of course with these glitches occur. Um the date for submission of privacy applications over documents supplied to uh participants by the inquiry is the 11th of April.
02:54:28 11th of April. My understanding is that the particular difficulties that face Miss the Silver are such that she uh uh is unlikely to be able to uh meet that deadline. So that the inquiry team will have to do
02:54:45 that the inquiry team will have to do privacy applications on her behalf uh come what may. Am I right in that assumption? Yes, that's correct. Yeah, I thought so. There's no criticism of her because I know the problems under which she operates and the difficulties of
02:54:57 she operates and the difficulties of dealing with with this. But there are particular reasons why in her case I I'm well aware that she can't comply with it and so the inquiry team are going to have to do it. But the the application
02:55:08 have to do it. But the the application for the witness statement is until the 30th of May. So yes, and again there are particular reasons
02:55:20 and again there are particular reasons why um exceptionally um a longer than as far as the inquiry is concerned um sensible or convenient deadline may have to be allowed but I need to speak to the team about that. So yes, thank you.
02:55:32 team about that. So yes, thank you. Now does that deal with all of those on whose behalf you're making submissions?
02:55:46 whose behalf you're making submissions? Uh, so I I need to address you privately about Rosa. Yes. May um I also need to address you privately about uh Donna. Yes. Will you forgive me? I think I'm just um receiving further instructions as we speak. Yes, of course. So, I wonder if
02:56:03 speak. Yes, of course. So, I wonder if now might be an appropriate moment for a very short break while I confirm those instructions. Um certainly, but in relation to um Rosa and Donna Mlan, um are these instructions which relate to them or to others?
02:56:23 Um I'm not entirely clear, sir. Very well. Don't don't worry at all. Doesn't matter. Well, um I I will break for the time being um for a short period to deal with the applications that you have
02:56:35 with the applications that you have made. um uh where you do not need to make any private applications. In addition, I'm grateful. Oh, forgive me, sir. There's one point that I've been asked just before you rise to make. Yes, of course. You are considering um in
02:56:50 of course. You are considering um in respect of Wendy. Yeah. I I'm instructed that the request for the 23rd of May is is maintained and that one reason which has not yet been put. Mhm. is that those who instruct me asked the inquiry to
02:57:01 who instruct me asked the inquiry to download documents on the 7th of March
02:57:12 download documents on the 7th of March um to deal with those problems reglined regarding navigating Epic and that no response has been received from the inquiry yet. Um so it's a small point but one I've been asked to make in respect of the um the Wendy submissions
02:57:23 respect of the um the Wendy submissions if I can put them like that and perhaps I can address you on um other matters after a short break. Of course. Well um I I'm going to rise now for a short period. I'm not going to say how long it's going to be because there are a
02:57:37 it's going to be because there are a number of um individual applications that I must consider. Very cool.
03:22:38 uh some progress has been made. Um I wonder whether you can come back on the screen.
03:22:40 screen. Yes, I am here. Thank you. Good. I I wanted to say as well, sir, there are um there are certain submissions I would
03:22:52 there are certain submissions I would wish to add to in respect of Miss Steel in closed session if I may. I now in case your intention was to give a ruling before I'd have the chance to do so. No, no. I I what I wanted to say about Miss Steel was the um proposal that she
03:23:07 Steel was the um proposal that she should produce two statements. one about her relationship with Dyn during his deployment and the second one about her efforts to find him uh afterwards. Um
03:23:20 efforts to find him uh afterwards. Um that that is an idea which um meets with favor uh in my team and I hope that we
03:23:32 favor uh in my team and I hope that we can agree uh that that is uh what should happen and when I've heard you in private uh we can fix the dates. Thanks.
03:23:37 Thanks. Can I deal with the um the other ones where you have made completed submissions? Um as far as Lindsay
03:23:52 submissions? Um as far as Lindsay uh and Ellie go, uh I extend time until the 9th of May, Friday the 9th of May. Uh, as far as Wendy and Sarah go, because of the particular circumstances in which they find themselves,
03:24:04 in which they find themselves, um, I extend their time until the 16th of
03:24:14 May. Allison, we have dealt with, uh, Monica, uh, I will extend time until the 9th of May.
03:24:21 new monitoring project. I would extend time until the 2nd of May. Because of the uh particular difficulties and circumstances in which Mr. Silva finds herself, I will
03:24:33 Mr. Silva finds herself, I will exceptionally extend her time until the 30th of May. But it is to be understood by those who succeed uh uh these submissions that that is because of
03:24:49 submissions that that is because of truly exceptional circumstances which uh cannot be surmounted before that
03:24:58 date. I think we've now reached um just after 1:00 when it would be a natural time for a break. Um uh I will uh hear your submissions in private. Uh would 2:00 be convenient for that.
03:25:10 2:00 be convenient for that. Thank you sir. Yes. Then we'll resume but in private and not on the uh live link at 2:00. And will we speak after that private hearing?
03:25:22 that private hearing? Certainly we will. Yes. Don't worry. This is me to deal with these private matters and there are then other matters I've got to deal with openly.
03:25:36 I've got to deal with openly. not least your own application. Thank you. Right. until two.