Transcript of the Hearing 25 November 2013

 

           1                                       Monday, 25 November 2013

           2   (10.30 am)

           3                      (Proceedings delayed)

           4   (10.37 am)

           5   THE ASSISTANT CORONER:  Are we ready for the jury?

           6   MR UNDERWOOD:  Yes.

           7   THE ASSISTANT CORONER:  Thank you very much.  We'll ask for

           8       the jury to come in then, please.

           9                  (In the presence of the jury)

          10   THE ASSISTANT CORONER:  Good to see you all refreshed and

          11       relaxed and ready to go, members of the jury, we've got

          12       a busy day ahead so we'll get straight on with calling

          13       the evidence.

          14           Right, Mr Underwood, who do we have first?

          15   MR UNDERWOOD:  We have Miss J's daughter, who's on the other

          16       side of that video screen.

          17   THE ASSISTANT CORONER:  How old is Miss J's daughter?

          18   MR UNDERWOOD:  18.

          19   THE ASSISTANT CORONER:  I wonder if she could be sworn or

          20       affirmed in the usual way.  Is there somebody over there

          21       who can do that?

          22                  THE DAUGHTER OF MISS J (sworn)

          23   THE ASSISTANT CORONER:  Right, thank you very much.

          24                    Questions by MR UNDERWOOD

          25   MR UNDERWOOD:  Good morning.


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           1   A.  Good morning.

           2   Q.  My name's Ashley Underwood and I'm the barrister to the

           3       Inquest and I have some questions for you; do you

           4       understand?

           5   A.  Okay.

           6   Q.  Are you Miss J's daughter?

           7   A.  Yes.

           8   Q.  Right.  In August 2011, how old were you?

           9   A.  I was 17, just turned 17.

          10   Q.  Okay.  I would like you to look at a photograph --

          11   A.  Just turned 16 -- sorry, just turned 16, yeah.

          12   Q.  Best not to debate it with anybody else there, just keep

          13       it for your own head.

          14   THE ASSISTANT CORONER:  We did have her name on a piece of

          15       paper there as well as here.  I think we ought to just

          16       confirm.

          17   A.  (Indicates).

          18   MR UNDERWOOD:  Is your name on that piece of paper?

          19   A.  Yes.

          20   Q.  Good.

          21   THE ASSISTANT CORONER:  That's fine, thank you.

          22   MR UNDERWOOD:  I want you to look at a photograph, it's on

          23       screen there, we can see, and it's also in the jury

          24       bundle, photograph 19A.

          25   A.  Yes.


                                             2
 

 

 


           1   Q.  Now, on 4 August 2011, did you go out of your house for

           2       some reason?

           3   A.  Yes.

           4   Q.  Did you see anything like what we see on that screen?

           5   A.  I did see, like -- where I was standing, I didn't see

           6       the car to the right of the minicab.  So I wouldn't --

           7       I could see the car that's parked behind it, the car

           8       that's parked in front of it, but the one that's on its

           9       right I couldn't see because it was blocking it, from

          10       where I was viewing it.

          11   Q.  Thanks.  Can we, if you wouldn't mind looking in the

          12       jury bundle, have a look at photograph 19B.  That could

          13       come up on screen as well, I think --

          14   A.  Okay.

          15   Q.  -- if you look at it on screen.  Can you see the green

          16       there?

          17   A.  Yeah.

          18   Q.  Do you live the other side of the green?

          19   A.  Yes.

          20   Q.  Now, when you went out of your house and you say you

          21       could see some of these cars, where were you standing?

          22   A.  Shall I get up and show you?

          23   Q.  Would you mind pointing to it?

          24   A.  Like where was I?

          25   Q.  Yes, please.


                                             3
 

 

 


           1   A.  I would have been over here (indicates), you can see?

           2   Q.  Right at the top of the screen, yes?

           3   A.  Yes.

           4   Q.  So on the other side of Jarrow Road?

           5   A.  Yes.

           6   Q.  Thank you.  Could you see whether the minicab door was

           7       open or not?

           8   A.  No.  But I presumed that it was open because I knew

           9       that -- like, I knew that something was happening, that

          10       something was (inaudible), so I presumed that something

          11       happened.  And I could see, like, Mark Duggan and

          12       I could see a lot of people surrounding him.

          13   Q.  Let me just go slowly here.

          14   A.  Yes.

          15   Q.  Did you see anything or anyone go in or out of the

          16       minicab?

          17   A.  No -- well, I don't remember, don't remember.

          18   MR UNDERWOOD:  All right.  Thank you very much.  That's all

          19       I want to ask you, thank you.

          20   A.  Okay.

          21   THE ASSISTANT CORONER:  Right, let's see.  Mr Straw?

          22           All right, Miss J, you can see Mr Straw, can you?

          23   A.  Yes.

          24   THE ASSISTANT CORONER:  He's going to ask you some questions

          25       then, thank you?


                                             4
 

 

 


           1   A.  Okay.

           2                      Questions by MR STRAW

           3   MR STRAW:  Hello, I represent the family of Mark Duggan.

           4   A.  Okay.

           5   Q.  Because we don't have much time, I'm going to go to your

           6       interview.

           7   A.  Yes.

           8   Q.  Is it right that you thought someone had gone to the

           9       minicab?

          10   A.  To get something?

          11   Q.  Is that right?

          12   A.  Yes, to get something.

          13   Q.  Okay.  Can you describe in a bit more detail what you

          14       saw?

          15   A.  Like I saw a guy, like, he was near the minicab and then

          16       it was like -- I thought he got something from the

          17       minicab and then ran towards Tottenham Hale station.

          18   Q.  That guy, was he a member of the public, a police

          19       officer?

          20   A.  I would have thought that he was a police officer, like,

          21       at that moment in time I believed that he was a police

          22       officer.

          23   Q.  Did you see what he got from the taxi?

          24   A.  No, because it looked like it was covered with, like,

          25       either a piece of material or a cloth.


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           1   Q.  Is it right that at the time he was going to the taxi,

           2       you weren't focusing on him because you were focusing on

           3       Mr Duggan who was on the floor?

           4   A.  Yes.

           5   Q.  Is that why you didn't see whether or not he went into

           6       the taxi?

           7   A.  Yes.

           8   Q.  Then you started focusing on him after he sort of came

           9       out from that area of the taxi door?

          10   A.  Yes.  It's like when he started -- just before he

          11       started running towards Tottenham Hale, that's when

          12       I actually noticed that he was there and then when he

          13       started running to Tottenham Hale I was thinking "That

          14       looks a bit dodgy".

          15   Q.  That looks dodgy?

          16   A.  Yes.

          17   Q.  So you looked at him once he appeared to take something

          18       from the cab?

          19   A.  Yes.

          20   MR STRAW:  Thank you very much.

          21   THE ASSISTANT CORONER:  Thank you very much, Mr Straw.

          22   A.  You're welcome.

          23   THE ASSISTANT CORONER:  Mr Stern now.  Let's see if you can

          24       see him on your screen.

          25   A.  Yes.


                                             6
 

 

 


           1   THE ASSISTANT CORONER:  No, you haven't seen him yet.  There

           2       he is.

           3   A.  There we go.

           4   THE ASSISTANT CORONER:  Now, Mr Stern is going to ask you

           5       some questions now.

           6                      Questions by MR STERN

           7   MR STERN:  Morning.

           8   A.  Good morning.

           9   Q.  I wonder if you could just, please, have a look at

          10       a film that you were shown when you were spoken to about

          11       this matter.

          12   A.  Okay.

          13   Q.  First of all, can we just understand, because I don't

          14       think you have told us yet, the first time that you were

          15       asked to say anything about this was this month,

          16       1 November 2013?

          17   A.  Yes, yes.

          18   Q.  It's not your fault, but let me just also ask you this:

          19       I think you were in the interview with your mum, who

          20       we've heard from, or at least part of that interview?

          21       If you don't remember, it doesn't matter.

          22   A.  When my mum was being interviewed, they wanted to

          23       interview me but where it ran on for so long they

          24       couldn't interview us both at the same time, so they

          25       interviewed my mum and it ran on for so long, like, into


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           1       the night that they didn't end up interviewing me and

           2       then I never ended up getting interviewed.

           3   Q.  Do you remember whether you were in the interview with

           4       your mum or you don't?

           5   A.  I wasn't in the interview with my mum.

           6   Q.  I wonder if we could have a look, please, at the disc,

           7       the BBC footage, at 00.31.

           8   MALE SPEAKER VIA VIDEO LINK:  We don't have that here.

           9   MR STERN:  That may be my fault, I rather assumed that it

          10       was there because it was shown to the witness in the

          11       interview.

          12   THE ASSISTANT CORONER:  Unless a pre-arrangement has been

          13       done -- obviously not.

          14   MR STERN:  All right.  Perhaps I can deal with it another

          15       way.

          16   THE ASSISTANT CORONER:  See how we get on.

          17   MR STERN:  Do you remember that you were shown some footage

          18       of people moving around at the scene?

          19   A.  Yes.

          20   Q.  You were asked about a man who had a white arrow

          21       pointing down at him; do you remember that?

          22   A.  Was he near the minicab -- he's talking about that guy?

          23       Yes.

          24   Q.  Do you remember or not?

          25   A.  Yes, yes.


                                             8
 

 

 


           1   Q.  You said that it wasn't that man that you had seen --

           2   A.  Yes.

           3   Q.  -- and that you had seen -- if you want to, it's page 46

           4       or 47 of your interview, that may help you.  I'm sure

           5       somebody will be able to give you the page numbers

           6       there.  I hope you've got that.

           7   A.  Okay.

           8   Q.  Page 47, internal numbering.  Do you have that?

           9   A.  Yes.

          10   Q.  Thank you.  If you look, right at the top, it said:

          11           "We positioned some white arrows on certain officers

          12       to show movement.  It does not mean anything apart from

          13       that it helps people to identify them, I want you to

          14       focus on the man with the white arrow pointing down on

          15       him.  Does this look like the person who ran off

          16       towards -- as you said was running towards Hale Lane

          17       station?  Can you remember what the man was wearing?

          18           You say no.  Then this question was put to you:

          19           "You don't recognise that person with the white

          20       arrow as the person who then ran off?

          21           "Answer: Who was that person that ran off ..."

          22           You then identified a man in a dark top running

          23       across; do you remember?

          24   A.  Yes.

          25   Q.  The timing of it is put there and I'll just put this


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           1       down as 00.35.14 so that the jury can look at it in

           2       a moment or two when you've gone.

           3   A.  Okay.

           4   Q.  You said that that person you remember running and he

           5       was the person who ran off towards Tottenham Hale

           6       station.

           7   A.  Yes.

           8   Q.  Yes?

           9   A.  Yes.

          10   MR STRAW:  I think, sorry to interrupt, there's a line in

          11       the middle of the page that's important where she says:

          12           "I would have thought it was a bit after that time."

          13   MR STERN:  I'm on page 47 and I just read that out:

          14           "So you don't recognise that person with the white

          15       arrow as the person who then ran off?

          16           "Answer: Who was that person that just ran off

          17       a second ago?

          18           "Question: We'll just stop and go back.

          19           "Answer: That's the person in dark that I remember

          20       running.

          21           "Question: Okay, towards Hale Lane.

          22           "Answer: Yes."

          23   A.  Yes.

          24   Q.  So if we go back:

          25           "So if you stop there ... we're looking at 00.35.15


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           1       and it's a man.

           2           "Answer: Like a black jumper.

           3           "Questions: Black jumper and it's jeans or grey-ish

           4       coloured trousers; is that correct?

           5           "Answer: I remember seeing him run."

           6           I'm on 48, it's over the page.

           7   A.  Yes.

           8   Q.  "Question: Do you think he was the one running towards

           9       Hale Lane, the man you were describing?

          10           "Answer: I would have thought that was a bit after,

          11       for some reason, like the person I can remember.

          12           "Question: But you think it was a police officer you

          13       saw running rather than a pedestrian who tried to get

          14       out of the way?

          15           "Answer: Yeah."

          16           But it's that individual that you identified and the

          17       timing is there 00.35.14 in the dark top as the person

          18       you recall running, who you thought may have got

          19       something -- sorry, I don't know who you're talking to

          20       there?

          21   A.  I can't actually see this 00.35.14, I can't see this.

          22   Q.  It's page 48, just over the page.

          23   THE ASSISTANT CORONER:  They might have two lots of numbers.

          24   MR STERN:  I'm doing the internal numbering because

          25       I thought that would be easier, but maybe it's not.


                                            11
 

 

 


           1       Does it have 48 in the bottom right-hand corner?

           2   A.  Yes, yes.

           3   Q.  Just at the top --

           4   A.  I thought you were talking about a picture for some

           5       reason.  Okay, yes.

           6   Q.  Sorry, I went over the page without telling you.

           7   A.  Yes, okay.

           8   Q.  Can you see it now?

           9   A.  Yes.

          10   Q.  All right.  So the person that you saw running was not

          11       the one in the white arrow but with the dark top?

          12   A.  Yes, yes.

          13   Q.  You did not see a gun at any stage, did you?

          14   A.  No.

          15   Q.  You saw, I think, some exhibit bags, but that was after

          16       the whole incident had finished.

          17   A.  Yes.

          18   Q.  You've told the jury helpfully where you were standing,

          19       which was -- is it by Erskine Crescent?

          20   A.  Yes.

          21   Q.  It's right, isn't it, that -- were are you standing with

          22       other people?

          23   A.  I was standing with my mum and there were other --

          24   Q.  The only reason I'm stopping you, and I'm sorry to cut

          25       across you, is because the name of one person I do not


                                            12
 

 

 


           1       want you to give us, but I think it's someone I think we

           2       are calling Miss Z; was she near you?

           3   A.  Yes.

           4   Q.  Yes, all right.  Your mum was there with you as well?

           5   A.  Yes.

           6   Q.  You didn't see, did you, the doors of the minicab,

           7       whether they were open or not?

           8   A.  Yes.

           9   Q.  Sorry, yes, you didn't or -- you didn't see --

          10   A.  Yes, I didn't.  I didn't, yes.

          11   Q.  Now, I think you said in this interview that you

          12       couldn't see what he was holding, this individual.  The

          13       man with the dark top --

          14   A.  Yes.

          15   Q.  -- that you saw running towards Tottenham?

          16   A.  Yes.

          17   Q.  You couldn't see?

          18   A.  Yes.

          19   Q.  Right.

          20   A.  No, I couldn't.

          21   Q.  I beg your pardon?  Sorry, I missed what you just said

          22       there.  "No, I couldn't", thank you.

          23   A.  I said "No, I couldn't".

          24   Q.  Thank you.  When you said it was covered with a cloth,

          25       where did you get that from?


                                            13
 

 

 


           1   A.  Because the way it looked is like it was covered so

           2       no one else could see it.  That's why I couldn't see the

           3       actual object.  It looked like he had put something over

           4       the object to cover it from everyone else.  I --

           5   Q.  Could we have a look at page 34, what you said a few

           6       weeks ago about this and, again, it's the bottom right

           7       hand corner, the pages.

           8   A.  Yes.

           9   Q.  You are asked:

          10           "Question: Was he carrying anything or did you see?

          11           "Answer: Whatever he took from the cab it's like he

          12       got something from that area.  I don't know whether it

          13       was in the cab, if it was out of the cab, something he

          14       took, something -- and he ran towards Tottenham Hale

          15       but --

          16           "Question: Right, and could you see what he was

          17       holding?

          18           "Answer: No.

          19           "Question: Was he holding it in one hand or two

          20       hands; can you remember?"

          21           Then over the page you say you cannot remember.

          22   A.  Yes.

          23   Q.  "What did it look like he was carrying.  Did you think

          24       'Oh, he's' --

          25           "Answer: I didn't really think about it, like,


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           1       I just remember thinking -- like, I thought it was

           2       dodgy.  That's why it stood out to me because it's,

           3       like -- I can proper remember him running because that's

           4       really weird.

           5           "Question: Did you see a gun at any stage?

           6           "Answer: No."

           7           That's what you said.  I do not think you mentioned

           8       about the cloth or anything in this interview, did you?

           9   A.  It doesn't look like it.

          10   MR STERN:  Thank you very much.

          11   THE ASSISTANT CORONER:  Thank you, Mr Stern.

          12           Mr Keith, do you have any questions?

          13           Mr Butt?

          14   MR BUTT:  No, thank you, sir.

          15   THE ASSISTANT CORONER:  Mr Glasson?

          16   MR GLASSON:  No, thank you, sir.

          17   THE ASSISTANT CORONER:  Anything back from you,

          18       Mr Underwood?

          19   MR UNDERWOOD:  No, thank you, sir.

          20   THE ASSISTANT CORONER:  If the camera can be put on to me,

          21       please.  Can you see me all right, Daughter of Miss J?

          22   A.  Yes, hey!

          23   THE ASSISTANT CORONER:  We will wave at each fondly across

          24       from one building to another.  That concludes you giving

          25       evidence, thank you very much for coming forward and


                                            15
 

 

 


           1       assisting the jury.  In a moment the screen will go

           2       blank and you will be free to go.  Please do not discuss

           3       the case with anyone else for a week or two while we

           4       conclude the proceedings.

           5   A.  Yes, that's fine.

           6   THE ASSISTANT CORONER:  All right, thank you very much

           7       indeed.

           8   A.  You're welcome.

           9                      (The witness withdrew)

          10   THE ASSISTANT CORONER:  Right, we can have that turned off

          11       then, thank you.

          12   MR UNDERWOOD:  I will call Miss Z now, please.

          13   THE ASSISTANT CORONER:  I will ask Miss Z to come forward

          14       into the witness box.

          15   MR UNDERWOOD:  I'm being warned that for the next ten

          16       minutes we won't be able to use the screens but I think

          17       it's better to crack on.

          18   THE ASSISTANT CORONER:  I think so.  We'll see how it goes.

          19       If there are any problems, but we have the box over the

          20       camera at the moment.

          21                        MISS Z (affirmed)

          22   THE ASSISTANT CORONER:  Thank you very much.  Have a seat,

          23       firstly, would you?

          24           We will ask Ms Day to stand near to you because you

          25       have the name of Miss Z, have you, on a piece of paper?


                                            16
 

 

 


           1       So let's have that given.  There we are, it's all right.

           2           Just make sure -- you are going to be shown a piece

           3       of paper, can you just confirm that that is your full

           4       name?

           5   A.  (Nods)

           6   THE ASSISTANT CORONER:  All right, we are going to refer to

           7       you as Miss Z, I hope you don't mind that, but that's to

           8       make you feel as ease and Mr Underwood will ask you some

           9       questions.

          10                    Questions by MR UNDERWOOD

          11   MR UNDERWOOD:  Good morning.

          12   A.  Good morning.

          13   Q.  There's nothing to be nervous about.  You have just

          14       seen, I think, the video evidence we have heard from

          15       Miss J's daughter; is that right?

          16   A.  Yes, I did.

          17   Q.  Do you know her?

          18   A.  Yes, I do.

          19   Q.  Do you know her mother?

          20   A.  Yes, I do.

          21   Q.  Were you with them on 4 August 2011?

          22   A.  I can't remember.

          23   Q.  Do you remember the incident that everybody here is

          24       talking about?

          25   A.  Some of it.


                                            17
 

 

 


           1   Q.  Did you see any of that?

           2   A.  Some of it.

           3   Q.  Tell us what you saw?

           4   A.  Okay.  I came out of my front door with a friend of

           5       mine.  I was seeing her off.

           6   Q.  Sorry, could you move the microphone a bit closer to

           7       you?

           8   THE ASSISTANT CORONER:  Before you go on with a long story,

           9       if you move a little closer to us, that microphone will

          10       pick up a little bit more about what you are saying.

          11           So we have you coming out of your front door.  Take

          12       your time and tell us what you saw.

          13   A.  I was coming out of the front door with my friend, I was

          14       seeing her off.  There was a commotion but I didn't

          15       really take any notice of it, I was busy with her and

          16       then after a while I did go and had a look but I didn't

          17       go on the road, I went on the pavement.

          18   MR UNDERWOOD:  On Jarrow Road?

          19   A.  Yes.  But Jarrow Road is there (indicates) and the

          20       pavement is kind of here (indicates), like this is my

          21       house and I'm just within my estate, I didn't go out.

          22   Q.  Right.  Didn't actually go onto the pavement of Jarrow

          23       Road; is that right?

          24   A.  No, no.

          25   Q.  What did you see?


                                            18
 

 

 


           1   A.  (Pause)

           2           I saw two policemen -- there was loads of policemen,

           3       cars and stuff going on.  I saw this figure, saw this

           4       man, and I saw two policemen beside him.  There was one,

           5       like, over here (indicates) and there was the one in

           6       front of him.  (Pause)

           7           The policeman that was in front of him put his arms

           8       out like this (indicates), he didn't touch him, I didn't

           9       see him touch him like this.  Something was said or

          10       something was shouted.  Then there was a bang, like

          11       a car backfiring or something, and then it went quiet

          12       for a little while, and then I saw the policeman trying

          13       to save the person that was on the ground.

          14   Q.  Right.  Was the person who you saw standing up the

          15       person who ended up on the ground or were they different

          16       people?

          17   A.  No, it was the same person.

          18   Q.  Let's go back over that a little bit.  So the person who

          19       ended up on the ground had, when you first saw him, been

          20       standing up with a policeman reaching out to him; is

          21       that right?

          22   A.  Yes.

          23   Q.  You heard something shouted before he went down; have

          24       you any idea what it was?

          25   A.  Yes, something but I don't know what it was, I don't


                                            19
 

 

 


           1       know what it was.

           2   Q.  Do you know who was shouting it?

           3   A.  No, I don't.

           4   Q.  You say that you had heard a commotion and you went to

           5       the area where you watched this from.

           6   A.  Yes.

           7   Q.  Can you tell us what the commotion was?

           8   A.  From where I was standing, there was all -- the road was

           9       blocked off, there was -- blocked off on that side

          10       (indicates), there was more blocked off on that side

          11       than there was on my right-hand side.

          12   Q.  So more on the left than on the right?

          13   A.  Yes, and I saw -- I can't remember exactly how many but

          14       there was quite a lot of policemen on the other side of

          15       the road on the pavement --

          16   Q.  This is on the green, do you mean, or the green area or

          17       right at the top?

          18   A.  No, not on the green, on the barriers walking up to go

          19       to the -- to go to --

          20   Q.  So on Ferry Lane?

          21   A.  Ferry Lane is on this side but you have to cross over

          22       the road, like if you're going to Tesco, on that side,

          23       because they were in the middle of the road.

          24   Q.  So lots of policemen in the middle of the road before

          25       you saw the policeman with his arm out?


                                            20
 

 

 


           1   A.  Yes.

           2   Q.  After you had seen the person go down, or at least the

           3       person who you saw stand up be on the ground and some

           4       first aid being given to him, what else happened?

           5   A.  That went on for a while in the background, the air

           6       ambulance was coming but something happened and they

           7       weren't getting there fast enough, but they arrived in

           8       the end.  After they came, everything -- I think he

           9       probably died then because it was all -- everybody was

          10       going about their business and --

          11   Q.  Are you assuming that the person you saw being given

          12       first aid was the one who died or do you know that that

          13       was?

          14   A.  No.

          15   MR UNDERWOOD:  Very well.  Thank you very much.  That's all

          16       I want to ask you.  Other people may have some questions

          17       for you.

          18   THE ASSISTANT CORONER:  Thank you.  Mr Straw?

          19                      Questions by MR STRAW

          20   MR STRAW:  Good morning.

          21   A.  Good morning.

          22   Q.  I would just like to go back to that point when the

          23       police officer had his hand out and the man opposite

          24       him, Mark Duggan, was standing up.  Focusing on Mark

          25       Duggan at that period, just before he goes over, just


                                            21
 

 

 


           1       before the shot or the bang, did you see what he was

           2       doing with his arms?

           3   A.  Where I was standing, the policeman face was to me but

           4       Mr Duggan's back was towards me.  So I couldn't see --

           5       I didn't see where his hands was, I don't remember where

           6       they were but, no, I don't know, I don't know.

           7   Q.  Let me just ask about what you said in interview,

           8       because we don't have much time.  You were asked -- you

           9       are saying Mark -- sorry, this is internal page 28, if

          10       anyone else wants to look at it.  You're asked by the

          11       interviewer:

          12           "But you're saying Mark wasn't moving about?

          13           "Answer: I didn't see no body movement from him, no

          14       I didn't.

          15           "Question: Okay, could you see his hands at all?

          16       I think you have already answered that question but --

          17           "Answer: I don't know where they were but I didn't

          18       see them up or in the pockets.  You know, if your hand

          19       was in the pockets it's going to be something like, you

          20       know, not straight.  I don't know where they were,

          21       I don't know.

          22           "Question: But just on that, when you've been

          23       demonstrating Mark stood in front of the railings you

          24       stood like this a couple of times.

          25           "Answer: Yeah.


                                            22
 

 

 


           1           "Question: Is that what you saw?

           2           "Answer: Yeah, I just saw him standing straight but

           3       I can't remember whether -- I don't remember seeing his

           4       hands by -- I don't know where they were but I know if

           5       they were in his pockets I would have seen something,

           6       like.

           7           "Question: So his arms were -- you feel his arms

           8       were straight?

           9           "Answer: Yeah.

          10           "Question: Like, the impression you've been left

          11       with, you didn't see them up, bent out.  You didn't, for

          12       example --

          13           "Answer: This -- I don't know about this one but

          14       definitely it was down.  It wasn't --

          15           "Question: So there you're talking about that would

          16       be his right arm -- I'm not very good with right and

          17       left -- his right arm?

          18           "Answer: Yes.

          19           "Question: So you feel that was down?

          20           "Answer: Yeah, I didn't see any movement from

          21       there."

          22           Is that all accurate?

          23   A.  As far as I can remember, yes.  I don't remember seeing

          24       where his arms were but, like you said, if they were in

          25       his pocket they would have been something like that but


                                            23
 

 

 


           1       I can't remember, I don't know.

           2   MR STRAW:  Thank you very much.

           3   THE ASSISTANT CORONER:  Thank you.  Yes, Mr Thomas?

           4                      Questions by MR THOMAS

           5   MR THOMAS:  Good morning.

           6   A.  Good morning.

           7   Q.  I represent the loved once of Mark Duggan.  I've only

           8       got one question for you.

           9   A.  Okay.

          10   Q.  Just before you heard what sounded like a bang, you said

          11       that you could see Mark Duggan from behind, you could

          12       see his back?

          13   A.  Yes.

          14   Q.  What I would like to know is whether you saw

          15       Mark Duggan, before the bang, make any sudden movement?

          16   A.  No.

          17   Q.  Are you sure about that?

          18   A.  I didn't see him twist, I didn't see him turn, I didn't

          19       go see him go forward, I didn't see him go backward, if

          20       that's what you're asking me.

          21   Q.  That's exactly what I'm asking you.

          22   A.  No, he didn't.  He was just there.

          23   Q.  He was just there?

          24   A.  Yes.

          25   Q.  Then you heard the bang?


                                            24
 

 

 


           1   A.  Yes.

           2   MR THOMAS:  Thank you.

           3   THE ASSISTANT CORONER:  Thank you very much, Mr Thomas.

           4           Yes, Mr Stern.

           5                      Questions by MR STERN

           6   MR STERN:  Thank you, sir.  Good morning.  I wonder if we

           7       could just try to get your location again.  As

           8       I understand it, you were on Erskine Crescent; is that

           9       right, on the corner of Erskine Crescent?

          10   A.  Yes.  These are the houses, you come out my front door,

          11       you walk up, there's a bus stop there (indicates) but

          12       I didn't go over to the pavement, I stayed within --

          13       within -- inside -- inside the box.

          14   Q.  So is this further back from Jarrow Road; is that right?

          15   THE ASSISTANT CORONER:  That photograph, 19B, might that be

          16       an advantage.

          17   MR STERN:  Yes.

          18   THE ASSISTANT CORONER:  I think actually it might be easier,

          19       rather than you worry about that, let me pull out 19B

          20       and ask those in front of me to hand that over to the

          21       witness.

          22           Would you?  (Handed)

          23           Just have a look at 19B, that's the best photograph

          24       that we have of that.  Can we see the sort of angle

          25       where you were looking on that photograph?


                                            25
 

 

 


           1   A.  This is the green, right, and the pavement is further

           2       back from the green where I was standing.

           3   MR STERN:  Where you are standing we cannot even see on that

           4       photograph, it's even further back than that?

           5   A.  Yes, yes.

           6   MR STERN:  Just so we understand where you are.  That's very

           7       helpful.

           8   THE ASSISTANT CORONER:  Can I just clarify that?  You have

           9       the right side of the road there.  The bottom of the

          10       picture is where Tesco is and the top of the picture is

          11       where Jarrow Road is; do you see that?  Just make sure

          12       you are not confused.  Yes?  Do you see the bus stop

          13       there and the cars?

          14   A.  Okay.  That's the pathway where you go -- okay, I get

          15       you.  That's the bus stop, that's the pathway, that's

          16       the road there and then you cross over and I was there

          17       (indicates).

          18   THE ASSISTANT CORONER:  Just off the top right-hand corner

          19       of that picture, 19B?

          20   A.  Yes.  Because that's the -- that's where you walk to go

          21       to the bus stop and then you have to walk a little bit

          22       further down and I was there, yes, down here.

          23   THE ASSISTANT CORONER:  I understand.  So top right of that

          24       picture.  Thank you very much.  Back to questions about

          25       it.  Keep that photograph there for the moment.


                                            26
 

 

 


           1   MR STERN:  Were you there for the whole time that you

           2       were --

           3   A.  No, I wasn't.  I was only there for a little while and

           4       then I just went in.

           5   Q.  But for the little while you were there, were you just

           6       at that point, you didn't go any nearer?

           7   A.  Yes.  No, no, no.

           8   Q.  Approximately how long do you think you were there; do

           9       you remember now or not?

          10   A.  I mean, I saw him go down, I saw the policemen trying to

          11       save him, I heard the air ambulance and then I stayed

          12       a little bit longer and then I went inside.

          13   Q.  Okay.  As I understand it, when you arrived, there was

          14       a car blocking the road, blocking your road, was it, or

          15       not?  Was there a police car there around?

          16   A.  Not on Ferry -- not on -- coming into the estate, no.

          17   Q.  So far as seeing anything, you didn't see anything in

          18       the officer's hand at all?

          19   A.  No, I didn't.

          20   Q.  You didn't see a gun?

          21   A.  I didn't see anything.

          22   Q.  I think you thought it was a shot but you didn't

          23       actually know which officer had fired?

          24           Sorry, you have to answer rather than --

          25   A.  No, no.


                                            27
 

 

 


           1   Q.  Otherwise it doesn't go down.

           2   A.  Sorry, no.

           3   Q.  Don't worry.

           4   THE ASSISTANT CORONER:  You describe hearing a noise you

           5       thought was like backfiring.

           6   A.  Yes, I did.

           7   MR STERN:  So far as Mark Duggan is concerned, you couldn't

           8       see his face, you have told us --

           9   A.  No, I couldn't see his face, I just saw the back of him.

          10   Q.  He had his back to you and you weren't able to describe

          11       him?

          12   A.  No, I can't.

          13   Q.  There was an officer that was facing Mark Duggan?

          14   A.  Yes.  He was there (indicates) and there was one there

          15       (indicates).

          16   Q.  There was one --

          17   A.  On my left and --

          18   Q.  Therefore on his left as well?

          19   A.  On Mark Duggan's left and the other one was -- yes.

          20   Q.  So there was -- Mark Duggan was facing towards me --

          21   A.  Yes.

          22   Q.  -- that he would have a police officer here that you saw

          23       and one directly opposite him, facing him; is that what

          24       we have understood from your evidence?

          25   A.  Yes.  There was one here -- I only saw two in front of


                                            28
 

 

 


           1       him, one here on the left and one in front of him, as

           2       you just said.

           3   Q.  Presumably, you couldn't see much of that officer who

           4       was opposite him?

           5   A.  No, I couldn't, no.

           6   Q.  You couldn't see his face, I think?

           7   A.  No, I couldn't, no.

           8   Q.  But you could just make out somebody there, could you,

           9       because he was taller?

          10   A.  No, he was a police officer.  He had his shirt on --

          11   Q.  What shirt was that?

          12   A.  I think a white shirt, white shirt, but I'm not

          13       absolutely sure.  No, but he was a policeman, I didn't

          14       get that wrong.

          15   Q.  No, I'm not suggesting that you did.  I'm just trying to

          16       understand what part of him you saw --

          17   A.  I saw his body frame.

          18   Q.  Just the outside of his body frame?

          19   A.  Just his body frame facing me but I couldn't tell you

          20       what he looked like or anything like that.  I don't

          21       know.

          22   Q.  The reason I'm asking is because how is it that Mark

          23       Duggan didn't obscure your view if he was standing

          24       opposite Mark Duggan; do you see what I mean?

          25   A.  I am only telling you what I saw, I don't know.


                                            29
 

 

 


           1   Q.  Mark Duggan, his position was that he was very close to

           2       the railings?

           3   A.  Yes.

           4   Q.  He was standing?

           5   A.  Yes.

           6   Q.  He was just to the left, as you were looking at it, of

           7       that brick wall.  We can look at that photo again,

           8       perhaps if we close in on it, that might be helpful.

           9       It's gone a bit obscured.  It may be we can find another

          10       photo.  If we look at 19C --

          11   THE ASSISTANT CORONER:  I do not know whether that would

          12       help or not.  She has 19B, do you want her to have 19C?

          13   MR STERN:  All right, the Noble-Thompson photos might help.

          14   THE ASSISTANT CORONER:  Have a look on the screen there's

          15       another photograph coming up that might --

          16   MR STERN:  Hopefully one will come up.  Thank you very much,

          17       Mr Scott, I'm grateful.

          18           Is that the brick wall that you mean?

          19   A.  Yes, but it was -- it wasn't behind this, it was more

          20       that side (indicates).  It wasn't -- he wasn't behind

          21       this.

          22   Q.  No, not behind, he was to the left of that.

          23   THE ASSISTANT CORONER:  Those are the railings, are they?

          24   A.  Well, no, because I wouldn't have been able to see if he

          25       was -- it was more -- on a clearer point.


                                            30
 

 

 


           1   THE ASSISTANT CORONER:  On a clearer point?

           2   MR STERN:  It was what, sorry?

           3   THE ASSISTANT CORONER:  On a clearer point that she could

           4       see.

           5   A.  This wasn't all here, I can't see from this.

           6   MR STERN:  What do you mean "This wasn't all here"?

           7   THE ASSISTANT CORONER:  Where you were, were you looking

           8       through the rails to see this?

           9   A.  Yes.

          10   THE ASSISTANT CORONER:  You were to the left as you were

          11       looking at this photograph in front of you -- sorry, not

          12       the photograph, the screen -- you would be somewhere to

          13       the left of that, would you?

          14   A.  More like the side where the pathway -- where you were

          15       walking up the pathway.

          16   THE ASSISTANT CORONER:  So further back down there.

          17   MR STERN:  Do you have your interview there?

          18   THE ASSISTANT CORONER:  No, she doesn't.  It may be

          19       available for her.

          20   A.  It's over there (indicates).

          21   MR STERN:  Internal page number 25, or do you want the --

          22   THE ASSISTANT CORONER:  It's all right, it's coming up on

          23       the screen.

          24   MR STERN:  Thank you very much.  It's the lower half.  You

          25       say:


                                            31
 

 

 


           1           "The brickwork, the brickwork.  And he was just

           2       literally near the -- if he wanted -- if he wanted to

           3       move closer to the brickwork he could have done, but he

           4       didn't.  He was just there, just there.

           5           "Mr Jones: And as you were looking at it, he was on

           6       the left-hand side of the brickwork.  That's what you

           7       pointed out to me earlier?

           8           "Yeah, he's -- the brickwork is here so Mark is

           9       here."

          10           We don't have a video so when you say "here",

          11       obviously we don't have exactly what it is that you say?

          12   A.  Okay.

          13   Q.  Does that refresh your memory, what you have said there,

          14       that he was to the left of the brickwork?  If you cannot

          15       remember -- I know it's a long time ago.

          16   THE ASSISTANT CORONER:  Don't worry about it, if you're

          17       getting confused whether it's left or right or behind or

          18       alongside, don't worry about it.

          19   A.  All I can tell you, Mark Duggan was here (indicates),

          20       the policeman was about here, that's how I could see him

          21       putting his arms out and the other one was something

          22       like this here (indicates).

          23   THE ASSISTANT CORONER:  They were on the pavement?

          24   A.  Yeah, towards the fencing.

          25   MR STERN:  The railings?


                                            32
 

 

 


           1   A.  The railings.

           2   Q.  Mark Duggan was very near the railings and he was

           3       standing --

           4   A.  Yes.

           5   Q.  -- and you heard somebody shout?

           6   A.  Something was shouted.

           7   Q.  Something was shouted, obviously you cannot tell from

           8       the distance where you were what it was but --

           9   A.  I don't know.

          10   Q.  -- something was shouted and then you heard a shot and

          11       he went down to the ground?

          12   A.  Yes.

          13   Q.  You only heard one shot; is that right?

          14   A.  Yes.

          15   Q.  In relation to seeing all of this, this happened,

          16       I think, in a split second, is that right --

          17   A.  Yeah.

          18   Q.  -- including the arm out as well?

          19   A.  Yes.

          20   Q.  When you saw the arm out, I think you said it was the

          21       left arm of the officer?

          22   A.  Yes.  If he's facing me this way, yes, it would be his

          23       left arm, yes.

          24   Q.  If you're looking, it would be -- the arm could be

          25       appearing to come out of the right side of Mark Duggan?


                                            33
 

 

 


           1       If you see what I mean.  You're looking at him and the

           2       arm is on the right side of Mark Duggan or the left side

           3       of the officer as you're looking at it?

           4   A.  Right, you're there, I'm here and it's your arm -- this

           5       one, yes, and it was like --

           6   Q.  Mark Duggan is there so, that was it, forward --

           7   A.  That arm was there, yes --

           8   Q.  -- you saw it coming forward?

           9   A.  -- like that (indicates).

          10   THE ASSISTANT CORONER:  You're putting your right arm

          11       forward.  Don't worry about Mr Stern for the moment, you

          12       are giving evidence, not him.  Whose arm was it you saw

          13       firstly?

          14   A.  Okay.  (Pause)

          15   THE ASSISTANT CORONER:  Take your time.

          16   A.  I'm Mark Duggan, you're the policeman, your arm came

          17       out.

          18   THE ASSISTANT CORONER:  My left arm?

          19   A.  Yes, that arm came out because you're facing me, so

          20       I saw his arm.  I didn't see your other arm, I saw this

          21       one.

          22   THE ASSISTANT CORONER:  You were not confused with this arm

          23       being the officer's or Mark Duggan's?

          24   A.  No, no.

          25   THE ASSISTANT CORONER:  Absolutely sure?


                                            34
 

 

 


           1   A.  Yes.

           2   THE ASSISTANT CORONER:  Good, thank you.

           3   MR STERN:  You didn't see anything in that hand of the

           4       officer at all?

           5   A.  No, I didn't, I didn't, no.

           6   Q.  This person -- you saw the left hand in a split second,

           7       was it moving forward very quickly or how was it moving?

           8   A.  It was just there, it was just there.

           9   Q.  Just literally had his left arm out?

          10   A.  Just there, yeah.  I don't know if he said something

          11       to -- I don't know, it was just there, the arm was just

          12       there, I don't know.

          13   Q.  You couldn't see the other side of the officer?

          14   A.  No.

          15   Q.  You couldn't see Mark Duggan's hands or where they were?

          16   A.  No.

          17   Q.  Obviously we've seen the picture there and there's some

          18       shrubbery.  All that was there, wasn't it, at the time,

          19       we can see, because these are photos of the day in

          20       question?

          21   A.  All I know what I saw -- I saw the guy standing, his

          22       back was to my face, I saw the policeman there, I saw

          23       the other one there, his arm went out, I heard

          24       something, a bang went off, he went down, the police

          25       tried to do what he could.  I heard in the background


                                            35
 

 

 


           1       somebody said "The air ambulance is here", I don't know

           2       why it took so long to come, I don't know, then it came,

           3       everything kind of mellowed out a bit.  (Pause)

           4           Then after a while -- I stayed there for a bit and

           5       then on both sides of the green there were police

           6       officers looking for something.  What they were looking

           7       for, I don't know.

           8   Q.  I'm going to come to that in a minute.

           9   A.  That's all.

          10   Q.  It's right, isn't it, that you didn't see the skin on

          11       the arm or hand of the officer?  You didn't see what

          12       colour of the skin was of the hand or arm of the

          13       officer?

          14   A.  He was white.

          15   Q.  The reason I say that is because you said in your

          16       interview that you couldn't see.

          17   A.  I couldn't see.  But I could tell -- I could see

          18       (shrugs) -- (Pause)

          19           The police officer was white, both of them was white

          20       but Mark Duggan was white.

          21   Q.  Right.  Did you see the skin on the hand or arm of the

          22       officer?

          23   A.  No, I didn't.  No, I didn't.

          24   THE ASSISTANT CORONER:  You cannot help us about the size or

          25       can you?


                                            36
 

 

 


           1   A.  The size?

           2   THE ASSISTANT CORONER:  The police officers, were they big,

           3       small or the same as --

           4   A.  The police officer was a little bit taller and he was --

           5   THE ASSISTANT CORONER:  The one with his arm out was

           6       a little bit taller than Mark Duggan?

           7   A.  A little bit, not that much, a little bit.

           8   MR STERN:  Then you said the officers were looking for

           9       things on the grass --

          10   A.  Yes.

          11   Q.  -- and you saw them looking for an item?

          12   A.  I don't know what they were looking for but they were

          13       just --

          14   Q.  Obviously, but you saw them looking on the grass trying

          15       to find something?

          16   A.  Yes, I did.

          17   MR STERN:  Thank you very much.

          18   THE ASSISTANT CORONER:  Mr Keith?  No.

          19           Mr Butt?

          20   MR BUTT:  No, thank you, sir.

          21   THE ASSISTANT CORONER:  Mr Glasson?

          22   MR GLASSON:  No, thank you, sir.

          23   THE ASSISTANT CORONER:  Mr Underwood, any further questions?

          24   MR UNDERWOOD:  No, thank you.

          25   THE ASSISTANT CORONER:  That completes your evidence.  Thank


                                            37
 

 

 


           1       you for coming along to assist the jury.

           2                      (The witness withdrew)

           3   MR UNDERWOOD:  Mr McGuire, please.

           4           We are now back in completely open session.

           5   THE ASSISTANT CORONER:  Thank you very much.  I'll indicate

           6       therefore that, as far as anyone in Court 76 is

           7       concerned, we are now open and open for visitors and we

           8       will take the cameras off so we can see the witnesses

           9       for the moment.

          10                   MR VALENTINE MCGUIRE (sworn)

          11   THE ASSISTANT CORONER:  Thank you very much.  Have a seat,

          12       would you?

          13   A.  Thank you.

          14   THE ASSISTANT CORONER:  Mr Underwood will ask you some

          15       questions.

          16                    Questions by MR UNDERWOOD

          17   MR UNDERWOOD:  Good morning, Mr McGuire.

          18   A.  Good morning.

          19   Q.  My name's Underwood, I'm the barrister for the Inquest.

          20       I'll start the questioning off for you.

          21   A.  Sure.

          22   Q.  I want to ask you about 4 August 2011.  At about

          23       6 o'clock, 6.15 or so, can you remember where you were?

          24   A.  I was getting off the train from Liverpool Street and at

          25       Tottenham Hale.


                                            38
 

 

 


           1   Q.  Right.  Where were you due to be going to from Tottenham

           2       Hale station?

           3   A.  Home.

           4   Q.  Which was roughly where?

           5   A.  The Ferry Lane estate.

           6   Q.  Right.  What happened as you were making your way there?

           7   A.  Do you want me to guide you from when I got off the

           8       train or not particularly?  I think it's quite

           9       important, actually.

          10   THE ASSISTANT CORONER:  You tell us what you want to tell

          11       us.

          12   A.  I came -- I got off the train was making my way up

          13       towards -- to go home and some youths came up to me and

          14       asked me if I wanted to buy a mobile phone, and I said

          15       no.  So I was quite angry by this, because I thought

          16       they might have stolen it.

          17           So I left it and walked up the stairs towards my

          18       direction of home and I kept looking back to see what

          19       these children were doing and they approached another

          20       guy and obviously I assumed they were trying to sell the

          21       phone to him.  As I was walking towards home I kept

          22       looking back and then, with that, I saw about four

          23       police sirens -- cars, and one was a van, going quite

          24       fast.

          25           So then they carried on, so I'm still looking back


                                            39
 

 

 


           1       at the children talking to a man about the mobile phone

           2       and as I'm walking towards where I live, I kept looking

           3       back and then I heard three gunshots.  Then I looked

           4       towards my front of me and there was a police officer

           5       walking away from where Mark Duggan was killed.

           6   Q.  Right.  Let's have a look at a photograph shall we, 19B,

           7       up on the screen?

           8   A.  Sure.

           9   Q.  Now --

          10   A.  Shall I look behind me?

          11   Q.  Yes, or there's a screen in front of you.

          12   THE ASSISTANT CORONER:  Is it on that screen?

          13   A.  Yes, it's much sharper, as well.

          14   MR UNDERWOOD:  Where were you when you heard shots?

          15   A.  Right.  I would have been further -- probably about

          16       here, actually (indicates).

          17   Q.  So on the left-hand side of the road as you are

          18       walking --

          19   A.  Towards Walthamstow.

          20   Q.  So just the bottom left-hand corner of our photograph?

          21   A.  Yes.

          22   Q.  What did you see?

          23   A.  I saw a policeman walking away -- after the gunshots,

          24       walking away with the gun up to his shoulder.

          25   Q.  Walking away from where?


                                            40
 

 

 


           1   A.  From where the incident took place.

           2   Q.  Right.  If you look there, you can see a silver minivan;

           3       do you see that?

           4   A.  Yes, which is the taxi.

           5   Q.  Whereabouts, compared with that, was this police

           6       officer?

           7   A.  He would have been here, directly here (indicates),

           8       because he was walking away, you see, walking backwards.

           9   Q.  Where the little white arrow is now?

          10   A.  I would have been here by that point (indicates).

          11   Q.  So you heard shots, you saw a police officer walking

          12       back with a gun, did you say?

          13   A.  Yes, up to his shoulder.

          14   Q.  What else did you see?

          15   A.  Then there was -- I didn't see anyone on the floor but

          16       there was lots of police on this person on the floor and

          17       it just complete panic and chaos and I knew something

          18       dreadful had happened.

          19   Q.  Did you know -- sorry, we have lost the picture for some

          20       reason.  The picture is back up.  We lost it for a good

          21       reason, which is that arrows were being put on.  So do

          22       you see the lower arrow to the right there is where you

          23       were, was it?

          24   A.  Where the circle is?

          25   Q.  Yes, sorry, the circle.


                                            41
 

 

 


           1   A.  Yes.

           2   Q.  The other circle is where the police officer was?

           3   A.  Yes, walking backwards.

           4   Q.  You saw a lot of police officers around someone on the

           5       ground, did you say?

           6   A.  Yes.

           7   Q.  Whereabouts roughly was that?

           8   A.  Well, here (indicates), that's it there, that's where

           9       it's happening.

          10   Q.  Okay, where we actually see a cluster of officers there?

          11   A.  Yes.

          12   Q.  Where that black circle is?

          13   A.  That's correct.

          14   Q.  What else did you see?

          15   A.  Lots of people panicking and running around and it just

          16       literally just happened, so there's uniformed police

          17       officers as well trying to stop the traffic.  Literally

          18       just as I approached it, basically, they started to stop

          19       the traffic, then a bus -- I remember there being a 230

          20       bus behind me which has actually got me on film walking

          21       past at that point, basically.

          22   Q.  Did you hear any shouting at any stage?

          23   A.  Yes, complete chaos.

          24   Q.  Before the shooting?

          25   A.  No, it was afterwards.  If you remember, I heard police


                                            42
 

 

 


           1       sirens and --

           2   Q.  Looking back on that now, were those sirens to do with

           3       something else or do you think they were the sirens --

           4   A.  When I first heard them I thought they was going to some

           5       incident but I know why it was now.

           6   Q.  What I want to try to get clear for the jury, if I can,

           7       is whether we are talking about another group of police

           8       cars with sirens or whether you think it was this group

           9       of police cars?

          10   A.  I think it was this group, yes.

          11   Q.  So you see a lot of people running around after the

          12       shooting, yes --

          13   A.  Yes, the police.

          14   Q.  -- and police also stopping the traffic; is that right?

          15   A.  Yes.  Only in front of me.  I could see them stopping

          16       traffic from this end, but not from behind because

          17       I don't think it --

          18   Q.  Did you see anything else going on?

          19   A.  Just people running around and -- yes, I mean, then

          20       I saw some people coming out of the flats, some guy with

          21       no top on.  He had a big smile on his face, I think he

          22       thought it was fun or something, and as I looked back at

          23       the 230 bus, there were lots of people standing up and

          24       looking out like this, sort of thing, with smiles on

          25       their faces, for some reason (indicates).


                                            43
 

 

 


           1   Q.  Did you manage to see the first aid being carried out?

           2   A.  No, no.

           3   MR UNDERWOOD:  Very well.  Mr McGuire, thank you very much

           4       indeed.  Other people may have some more questions for

           5       you but that's all I've got.

           6   THE ASSISTANT CORONER:  Yes, Mr Straw?

           7                      Questions by MR STRAW

           8   MR STRAW:  Just one question, Mr McGuire.  The gentleman who

           9       you saw on the pavement between the taxi and the

          10       railings, who we now know to be Mark Duggan, can you

          11       give us an idea of where he was?

          12   A.  I didn't say he was on the floor.  I didn't say I saw

          13       him on the floor.  I saw people on top of a person.

          14   Q.  Okay.  So the person then who was underneath those

          15       people that you saw, can you tell whereabouts he was on

          16       the pavement as compared to the taxi and the railings?

          17   A.  Sure.  Well, it's -- he was there (indicates).

          18   THE ASSISTANT CORONER:  In the black circle that's been put

          19       on that photograph?

          20   A.  Yes, yes.

          21   MR STRAW:  In your witness statement you say:

          22           "The person on the ground was approximately 3 foot

          23       away from the people carrier in the centre of the

          24       pavement."

          25           Is that correct?


                                            44
 

 

 


           1   A.  Yes.

           2   MR STRAW:  Thank you very much.

           3   THE ASSISTANT CORONER:  Thank you very much, Mr Straw.

           4           Let's see -- do you have any questions Mr Stern?

           5                      Questions by MR STERN

           6   MR STERN:  Yes, thank you.  First of all, I think you

           7       described in your statement the minicab as being

           8       "browny-gold".

           9   A.  Right, that's right.

          10   Q.  Secondly, you saw one individual that was behind the

          11       minicab being -- who was handcuffed I think -- do you

          12       remember that?

          13   A.  Do you mean the cab driver?

          14   Q.  The cab driver, yes.  I didn't know if you knew he was

          15       the cab driver.  But you saw the cab driver?

          16   A.  I didn't know that at the time, I didn't know it was

          17       a taxi.

          18   Q.  Then you saw somebody else on the ground but that person

          19       was about a few feet away in the centre of the pavement;

          20       did this person have their head towards Walthamstow?

          21   A.  Yes, I think so, yes.

          22   Q.  That's what you put in your statement, and their feet

          23       towards Tottenham Hale?

          24   A.  Yes.

          25   Q.  This person was being seen to by a number of other


                                            45
 

 

 


           1       people?

           2   A.  Yes.

           3   Q.  So was it the person in that black circle or was that

           4       somebody different?

           5   A.  It's the person in the black circle.

           6   Q.  You think that it was the person in the black circle.

           7       But there was a police officer there, wasn't he?

           8   A.  There was lots of police officers.

           9   Q.  I think you looked across at that for about a few

          10       seconds and then moved on.

          11   A.  At the -- where the incident took place?

          12   Q.  Yes.

          13   A.  Yes, because I was a bit shocked really.

          14   MR STERN:  Yes, yes I'm sure.  Thank you very much,

          15       Mr McGuire.

          16   THE ASSISTANT CORONER:  Mr Keith?  Mr Butt?

          17   MR BUTT:  No, thank you, sir.

          18   THE ASSISTANT CORONER:  Mr Glasson?

          19   MR GLASSON:  No, thank you, sir.

          20   THE ASSISTANT CORONER:  Mr Underwood?

          21   MR UNDERWOOD:  Nothing arising out of that, thank you.

          22   THE ASSISTANT CORONER:  Thank you, Mr McGuire, for coming.

          23       That completes your evidence.  You're free now to go but

          24       thank you very much.

          25   A.  That was quick, blimey!


                                            46
 

 

 


           1   THE ASSISTANT CORONER:  Thank you for coming forward.

           2   A.  All right.  Take care.

           3                      (The witness withdrew)

           4   MR UNDERWOOD:  Mr Ely O'Carroll, please.

           5                MR KIERAN ELY O'CARROLL (affirmed)

           6   THE ASSISTANT CORONER:  Thank you very much.  Have a seat

           7       would you please and come and sit in close to the

           8       microphone and Mr Underwood will ask you some questions.

           9                    Questions by MR UNDERWOOD

          10   MR UNDERWOOD:  Good morning.

          11   A.  Good morning.

          12   Q.  My name is Underwood and I'm counsel to the Inquest.

          13       Can I ask your full names, please?

          14   A.  Kieran Peter Ely O'Carroll.

          15   MR UNDERWOOD:  This would explain why we have some

          16       confusion.  So sorry, Mr O'Carroll, we were expecting

          17       someone else.

          18   THE ASSISTANT CORONER:  No, we are expecting you but you

          19       just arrived a little earlier.

          20   MR UNDERWOOD:  We were expecting someone else for about

          21       10 minutes before you.

          22   Q.  Thank you very much for coming.

          23   A.  Good morning.

          24   Q.  I want to ask you about matters that occurred in

          25       August 2011, on the 4th --


                                            47
 

 

 


           1   A.  Okay.

           2   Q.  -- a little after 6 o'clock.  Can I ask you where you

           3       were at that time?

           4   A.  Right, on 4 August, which I assume that's the same day

           5       that this occurred, I had been working, I think, in --

           6       I had been working somewhere for a job agency doing

           7       landscape gardening or building and I was on my way

           8       home.  I stopped to go to an Internet cafe and I walked

           9       back from kind of near to Seven Sisters Tube station

          10       back down past Tottenham Hale, towards the canal where

          11       my boat is, or was.

          12   Q.  Did anything happen while you were in the area around

          13       Tottenham Hale?

          14   A.  Yeah.  I stopped to finish a cigarette outside Tottenham

          15       Hale Tube on a little corner of grass.  There were some

          16       people kind of stopping traffic at the lights and as

          17       I finished the cigarette I walked up over the bridge and

          18       there were a number of cars pulled up on the opposite

          19       side of the road.  There was a gentleman coming towards

          20       me, looked in his 50s, with a Fred Perry type of t-shirt

          21       on and he was saying "Get back, get back", trying to

          22       stop people from coming down there.

          23   Q.  Which side of the road was he on?

          24   A.  He was walking towards me, I don't know -- basically

          25       walking up I think either the road or the pavement


                                            48
 

 

 


           1       towards me, stopping traffic, stopping people, pushing

           2       people back.

           3   Q.  Right.  Could you see anything?

           4   A.  I could see a car -- I believe a silver car -- pulled

           5       diagonally across the pavement with the front left part

           6       of its bumper was touching the railings, the front

           7       passenger window was down part of the way.  There was

           8       a minivan, silver minivan pulled up as if the diagonally

           9       parked car had stopped it, and, yeah, there was a guy on

          10       the floor by the front driver's side wheel of the

          11       minivan sitting in the foetal position, crouched, and

          12       some officers with automatic weapons, kind of large

          13       automatic weapons pointed at him, yes.

          14   Q.  What did you do?

          15   A.  I stopped, had a cigarette or -- yeah, chilled out for

          16       a bit and thought "How am I going to get past this

          17       cordon?"  So I jumped over the railings and jumped over

          18       the railings on the other side.

          19   Q.  Onto the green or the Tesco side?

          20   A.  Yeah, I was at the Tesco side walking up, so jumped over

          21       the railings there and there's some stairs that lead

          22       down by the railway track, so I took those stairs trying

          23       to get round the obstructions.

          24   Q.  Those are the stairs that take you down to the Jarrow

          25       Road area, are they?


                                            49
 

 

 


           1   A.  I don't know what road it is but onto the estate, yes.

           2   Q.  Where did you go to?

           3   A.  Walking through the estate, there was a lady there,

           4       people were talking, some youths on one of the paths

           5       looking at the incident.  I stopped there for a little

           6       while.  I was chatting to the lady, she said she'd heard

           7       some shots and et cetera, so we kind of discussed what

           8       was going on.  I saw the cops come and put an evidence

           9       board out and I eventually kind of realised that more

          10       and more cordons were going up and just decided to get

          11       out the area so --

          12   Q.  When you say an evidence board, whereabouts were they

          13       putting that?

          14   A.  From my perspective, where I was standing, I would have

          15       been looking at the minivan raised up on the road above

          16       me and it seemed to be (indicates) kind of approximate

          17       to where the very front of the minivan would have been,

          18       but down -- the roadway is raised (indicates) and the

          19       estate is kind of down lower, so the minivan would have

          20       been sort of here, the evidence board was kind of down

          21       the other side of the railings.

          22   Q.  On the green somewhere?

          23   A.  On the green, yes.

          24   Q.  You've described in a statement how that looked; was it

          25       something like an open pizza box?


                                            50
 

 

 


           1   A.  An open pizza box?

           2   Q.  Mm-hmm.

           3   A.  No, it looked to me like a board, you know, that

           4       a cleaner would put out to show there's wet floors but,

           5       if I remember rightly, it was white in colour.  That's

           6       what -- that's how I remember it.

           7   Q.  Did you actually see it put up, like an A-frame?

           8   A.  I saw a chap come and put it down there, yeah, and --

           9       oh, gosh, I've described in my statement I think I saw

          10       him interacting with other police officers, some other

          11       police officers turned up on the scene.  I can't

          12       remember fully and clearly now but I know whatever I put

          13       in my statement at that time was correct.

          14   Q.  All right.  Have I got this right: in terms of the

          15       sequence of events about other officers turning up and

          16       the placing of that whatever we want to call it,

          17       box/board, you can't remember the precise sequence;

          18       would that be fair?

          19   A.  I know that whatever I said in my statement would have

          20       been correct at the time.  But I haven't been

          21       remembering over it, I haven't taken any notes,

          22       I haven't looked at any newspapers I have deliberately

          23       been keeping my mind pretty clear of it until now, so

          24       I do recall giving the correct version of events in my

          25       statement.


                                            51
 

 

 


           1   Q.  Right.  Then did you see the air ambulance arriving?

           2   A.  I did, yes.

           3   Q.  Did you see --

           4   A.  I walked around from where I was standing and from the

           5       area by the grass, round to some traffic lights further

           6       on towards the river, and looked up the street and saw

           7       a guy on the ground getting chest compressions.

           8       I crossed over the street eventually down onto the

           9       river, a cyclist came and I was about to continue off

          10       home and I saw the air ambulance came, and that was

          11       interesting, watching a helicopter land in the middle of

          12       the street, so I watched that for a bit.

          13   Q.  I think you drew some sketches, did you, for the IPCC?

          14   A.  I may have -- yeah, I believe so.

          15   Q.  Can we have a look?  We have the originals in court if

          16       we need them, but can we start at CD4446.  It's going to

          17       come up on screen.

          18           If we are looking here towards the top right-hand

          19       corner, are those the steps you went down on the Tesco

          20       side of the road?

          21   A.  Yes, that looks about right -- opposite the Tesco side.

          22   Q.  I'm so sorry.

          23   A.  "Entrance to student flats" would also lead to a Tesco

          24       express store.

          25   Q.  If we look at CD4447 is this setting out where you see


                                            52
 

 

 


           1       the casualty near the minicab?

           2   A.  I'm trying to look at which -- which way round that is.

           3       Yeah, where the casualty is laying up from the bus stop,

           4       yes?

           5   Q.  Yes.

           6   A.  And outside the minicab and, yeah, with the car parked

           7       diagonally across the pavement.  That's as I remember

           8       it, yes.

           9   Q.  Right.  Then if we look at 4448 --

          10   A.  Oh, yes.

          11   Q.  -- what is that marked "G"?

          12   A.  I can't remember.  I can't remember what I've marked "G"

          13       there.  "F" -- that's quite a vague --

          14   THE ASSISTANT CORONER:  Is that one that you drew?

          15   A.  Yes.

          16   THE ASSISTANT CORONER:  Your drawing, is that?

          17   A.  Yes, that looks like one of mine.  Railway line there,

          18       grass area there -- (Pause)

          19           No, I can't --

          20   MR UNDERWOOD:  Don't worry.  Help us with your view points.

          21       If we have a look at photograph 19B.

          22   A.  Yes.

          23   Q.  It's a bit cut off, you can see, but what we are looking

          24       at is over from roughly the top of Tesco down onto the

          25       scene, then there's the green and there's Jarrow Road at


                                            53
 

 

 


           1       the top of our photograph there?

           2   A.  Yes.

           3   Q.  Were you -- once you got down through the tunnel way,

           4       did you manage to walk along up Jarrow Road?

           5   A.  Jarrow Road?  (Pause)

           6           Where -- the railway line would be running in this

           7       direction --

           8   THE ASSISTANT CORONER:  Yes, on the right.

           9   A.  -- and Jarrow Road, you mean, is this road up here

          10       (indicates)?

          11   MR UNDERWOOD:  That's it.

          12   A.  Yes.

          13   THE ASSISTANT CORONER:  So, yes, you did walk along there,

          14       in the end?

          15   A.  Yes.

          16   MR UNDERWOOD:  When you were able to see the movement of

          17       this evidence board or whatever it was and when you were

          18       able to see the casualty were you down on Jarrow Road or

          19       had you got up onto the grass?

          20   A.  I was down on Jarrow Road.  I don't believe that I would

          21       have been on the grass if -- no, I do not think I was on

          22       the grass.  I think I was on the other side of the

          23       road -- of Jarrow Road.

          24   Q.  I am just interested in viewpoints and how well people

          25       could see through the trees?


                                            54
 

 

 


           1   A.  Yes.

           2   Q.  You were able to get a clear enough view through

           3       whatever foliage was there?

           4   A.  Yes, as I remember it, yes.

           5   MR UNDERWOOD:  That's helpful.  Thank you very much indeed.

           6   A.  Yes.

           7   Q.  Other people will have some more questions for you.

           8   THE ASSISTANT CORONER:  Mr Straw?  No.

           9           Mr Stern?

          10                      Questions by MR STERN

          11   MR STERN:  Yes, please.  Maybe I'm confused, I am not quite

          12       clear where you were.

          13   A.  Okay.

          14   Q.  Were you beyond the grass area looking up at the grass

          15       area?

          16   A.  I believe so, yes.

          17   Q.  So you were looking up and that slope obviously makes it

          18       difficult to see everything that you want to be able to

          19       see --

          20   A.  Erm --

          21   Q.  -- but you could see things there, could you?

          22   A.  Yes, I mean, I was more initially interested in getting

          23       out of the area, but obviously it's -- you know, a bit

          24       of commotion going on, I spoke to a lady, she was

          25       outside a house, I think it may have been her house, and


                                            55
 

 

 


           1       yeah, kind of -- I don't know -- yeah.

           2           So that's fairly -- I'm fairly clear of where I was,

           3       so if you need to --

           4   Q.  That's fine.  I wonder if you could just have a look at

           5       CS543, it will come up on the screen for you because you

           6       were asked about this letter G and you have answered it

           7       in your statement, so it's probably helpful if we just,

           8       as it were, have the answer.  If we look at the lower

           9       half of this statement --

          10   A.  Officer G?

          11   Q.  Let's take it from the top, you say from point 5, which

          12       is, I think, just on the Jarrow Road area, is it?  Do

          13       you remember?  Do you have your plan there?

          14   A.  No.

          15   THE ASSISTANT CORONER:  No, he hasn't, it's only on the

          16       screen.

          17   A.  I don't.

          18   THE ASSISTANT CORONER:  We'll just go back to that last one

          19       because the one he said was a bit vague we have point 5

          20       written on it.

          21   MR STERN:  It does have 5 on it.

          22   THE ASSISTANT CORONER:  That's point 5 on the left and you

          23       have the road.

          24   MR STERN:  Can you see?  So there's Jarrow Road and there's

          25       the grass area and you have written "G" and "F" there,


                                            56
 

 

 


           1       yes?

           2   A.  Yes.

           3   Q.  Anything else you want to look at for that?

           4   A.  No.

           5   Q.  No, all right thank you.  Can we go back to the

           6       statement then.  Just so we understand what you're

           7       saying:

           8           "From point 5 I could see the sliding door on the

           9       side of the cab was open."

          10           Yes?

          11   A.  "From point 5 I could see the" --

          12   Q.  No need for you to read it, I just want to read it and

          13       then refresh your memory and see if you accept it as

          14       being accurate.  You say that you were about 25 to

          15       30 metres from the cab:

          16           "Because of the nature of the rise of the grass

          17       I couldn't see exactly what was going on on the

          18       pavement."

          19           I think you have dealt with that.

          20   A.  Okay.

          21   Q.  Presumably you saw nobody -- there were officers around

          22       the cab but nobody was in the cab?

          23   A.  I don't know.

          24   Q.  Then further down:

          25           "A group of another police officers arrived to move


                                            57
 

 

 


           1       the youths on the tarmac path ..."

           2           That's near Jarrow Road, is it?

           3   A.  Yes.

           4   Q.  Two or three officers there, and they were armed:

           5           "They arrived in some form of estate car that had

           6       pulled up.  I have a memory of cordoning tape being put

           7       up around the grass area but I do not know at which

           8       point chronologically this happened."

           9           "G", I think is a police officer, yes?

          10   A.  Yes.

          11   Q.  He greeted one of the officers within a group of the

          12       other officers that arrived to put the cordon up and

          13       officer G:

          14           "... pointed out something on the grass to the

          15       officer."

          16           Yes?

          17   A.  Yes.

          18   Q.  That's what you have marked as "J", but I cannot see "J"

          19       on your map.

          20   A.  Okay.

          21   Q.  It may be on the version that you have there.  What you

          22       say is:

          23           "My assumption was that officer G was pointing out

          24       a gun on the floor, this was an assumption based on the

          25       size of the area being pointed out.  I did not actually


                                            58
 

 

 


           1       see what was being pointed out ..."

           2           Is that correct?

           3   A.  That's correct, yes.

           4   Q.  Then you say:

           5           "The open side of the cab seemed to be in a straight

           6       line with whatever commotion was taking place on the

           7       pavement at H, through the railings, to the grass with

           8       whatever officer G was pointing out at point J to his

           9       colleagues ..."

          10           Were you saying there was a straight line between

          11       the minicab and the point where the officer was pointing

          12       at G or J?

          13   A.  As I remember it now, the point he was pointing out

          14       would have been slightly to the right of the open door,

          15       as I remember it now.

          16   Q.  Perhaps we had better look at the original because it

          17       does not seem to have come out on my copies.  Then you

          18       will be able to see it.  Could you have a look at the

          19       original and you will be able to see J on here.

          20       (Handed)

          21           Just to refresh your memory, if you wouldn't mind.

          22       Then perhaps the learned Coroner might want to have

          23       a look.

          24   A.  (Pause)

          25   MR STERN:  Perhaps we can get a copy of this.  For some


                                            59
 

 

 


           1       reason it's not been --

           2   THE ASSISTANT CORONER:  Does that help you, Mr O'Carroll?

           3       You can take it out of the plastic bag if you want.

           4   A.  I don't see -- is that --

           5   MR STERN:  The one you are just looking at, can you see G

           6       and J there?

           7   A.  I can see "G", there's an "I", I don't see a "J" at the

           8       moment.

           9   MR STERN:  Perhaps you could give it back to me.  I thought

          10       I saw what perhaps looked like a "J" to me but maybe

          11       it's not.

          12   A.  Oh, here.  Here is a "J".

          13   THE ASSISTANT CORONER:  You have found a "J"?

          14   A.  I have found it.

          15   MR STERN:  Just so we are clear about it, we'll get it

          16       copied, obviously, after you have gone, but just so we

          17       know what your evidence is: the officer was at G --

          18   A.  Yes.

          19   Q.  -- and he pointed something on the grass to another

          20       officer --

          21   A.  Yes.

          22   Q.  -- and J is the point at which the item was being

          23       pointed at?

          24   A.  Yes.  I would stand by that, with myself marked at 5 --

          25   Q.  That's fine.


                                            60
 

 

 


           1   A.  -- and the houses.  I would say that's as accurate as --

           2       (Handed)

           3   MR STERN:  That's very helpful.  Perhaps we could get that

           4       copied.

           5   THE ASSISTANT CORONER:  That's much better, isn't it, on

           6       this?

           7   MR STERN:  Just let me explain, because obviously other

           8       people have not got the pictures.  As I understand it,

           9       J is approximately five to ten metres distance from the

          10       cab; is that right?

          11   A.  10 metres?  I suppose counting the downward --

          12   Q.  Just looking at your statement --

          13   A.  -- counting the downward drop -- I mean, as a bird

          14       flies -- you know, if you took a piece of string from

          15       the cab and ran it down, it could be five to ten metres.

          16   Q.  You thought it was less than that?

          17   A.  Would you -- you know, it would be maybe within

          18       five metres of the cab in a straight line.  Remember

          19       it's down the wall as well, so I mean that point there

          20       could be three or four feet away from me but it's

          21       also -- (indicates).

          22   Q.  But, as the crow flies, in a straight line, it's your

          23       recollection, is it, that it was five metres or less

          24       than that?

          25   A.  Yes, less than five metres.


                                            61
 

 

 


           1   THE ASSISTANT CORONER:  It might need to be opened, I won't

           2       tear it but it's a composite sort of document, whereby

           3       different pages have been stuck together and it looks

           4       like we have three separate ones on the screen but it

           5       might all be one.  So if somebody could open, I think

           6       that might only be fair to the witness and to everybody

           7       else.

           8   MR STERN:  The other thing that you put in your evidence was

           9       that point J was about 4 feet to the railings.  It's in

          10       your statement if you want to look --

          11   A.  Okay.  No, I would be happy with what I said at the time

          12       as being a clearer, more recent recollection.

          13   Q.  Yes.  I just want to see, obviously, if you can help us.

          14   A.  Where is this?

          15   Q.  Point J, you said at the time, was approximately 4 feet

          16       to the railings.  This was a statement you made on

          17       14 November 2011, so obviously it's going to be fresher

          18       in your mind then than it is now.

          19   A.  Where does it --

          20   Q.  Right at the top, first --

          21   A.  "Approximately 5 or 10 metres distance, point J was

          22       approximately 4 feet to the railings."

          23           Yes.

          24   Q.  Yes?

          25   A.  Yes.


                                            62
 

 

 


           1   Q.  All right.  Then can I just ask you about this board

           2       that you have mentioned.  Again, if you have a look at

           3       544 because it may help to refresh your memory.  It says

           4       there:

           5           "Another officer brought over a board to officer G."

           6           That you say was an A-frame board:

           7           "It was like a small board that opens and is used by

           8       cleaners to indicate a wet floor but this board was

           9       white and blue.  I thought it was a blue and white

          10       evidence board.  I saw the officer open it and head

          11       towards area J with it, the officer was within half

          12       a metre of it, but I did not see them place it on the

          13       ground.  The board was approximately 40 cm tall and

          14       20 cm wide.  It had a white back ground with blue

          15       writing on it in but also a rectangle or square blue

          16       block on it."

          17           Do you remember that or not?

          18   A.  Yeah, that rings a bell.  Now, I read that I would stand

          19       by that as being the most accurate description.

          20   Q.  So it was blue on the thing, on the board?

          21   A.  In my mind's eye I cannot see it right now but if I've

          22       said it there, I believe that would be the most accurate

          23       description I'd be able to give.

          24   MR STERN:  Thank you very much.

          25   THE ASSISTANT CORONER:  Mr Underwood, I wonder if you could


                                            63
 

 

 


           1       rescue that document from Mr Stern and with the scissors

           2       open it, so we can actually allow the witness to see.

           3   MR UNDERWOOD:  I do not know how easy it would be to put it

           4       on the docucam at the moment.

           5   THE ASSISTANT CORONER:  Probably not, just pull it out and

           6       see.  I do not think we need to do more than that, just

           7       to make sure whether it's one document, two, or what's

           8       stuck together and whether it's a work of art or not.

           9       It looks as though it may well be.

          10   MR UNDERWOOD:  It may be origami.

          11   THE ASSISTANT CORONER:  It's one document telling the whole

          12       story, isn't it, Mr O'Carroll?

          13   A.  It's the --

          14   THE ASSISTANT CORONER:  It's got you starting over then

          15       coming underneath and then going round.

          16   A.  I believe so, yes, it would be the best map I could draw

          17       from recollection of --

          18   MR UNDERWOOD:  Holding it up, Mr Ely O'Carroll, looking

          19       here, the Tesco area here, the grass area down here and

          20       Jarrow Road at the bottom; is that right?

          21   A.  I believe so, yes.  Jarrow Road would be at the bottom,

          22       yes.

          23   Q.  So can we just look at the -- your drawing again and can

          24       you -- with the aid of this, if I give it back to you,

          25       would you very kindly stand up and mark on the screen up


                                            64
 

 

 


           1       there for us where your point J is.  (Handed)

           2   A.  Okay.  Thank you very much.

           3   Q.  Roughly.

           4   A.  Here (indicates), if that's that far -- about here

           5       I think (indicates).

           6   Q.  Off the page, thank you.

           7   THE ASSISTANT CORONER:  It's accurately put on there as best

           8       you could, that document?

           9   A.  Yes.

          10   THE ASSISTANT CORONER:  Can we just show it round the jury.

          11       There you are members of the jury, just pass that round

          12       amongst yourselves.  I think it brings these different

          13       documents together and you can see what Mr O'Carroll was

          14       doing.

          15   MR UNDERWOOD:  We'll attempt to have it copied.

          16   THE ASSISTANT CORONER:  Or available in due course.  It

          17       might be a feat too much for a photocopy.  You will see

          18       there are three documents stuck together really.

          19              (The document is past around the jury)

          20   THE ASSISTANT CORONER:  Just see if anyone from counsel rows

          21       requires to have a view of that?  No.

          22   MR UNDERWOOD:  I have nothing else arising.

          23   THE ASSISTANT CORONER:  Thank you very much then,

          24       Mr O'Carroll, that concludes your evidence, you are free

          25       now to go.


                                            65
 

 

 


           1   A.  Thank you very much.

           2   THE ASSISTANT CORONER:  Thank you for coming to assist the

           3       jury.  That will be a convenient moment, I think, to

           4       have our mid-morning break.  Thank you very much.

           5                      (The witness withdrew)

           6   THE ASSISTANT CORONER:  So members of the jury, thank you

           7       very much, if you would like to leave us for five or

           8       ten minutes, that would be good.

           9           Cameras off.

          12   (11.56 am)

          13                         (A short break)

          14   (12.14 pm)

          15   THE ASSISTANT CORONER:  Right.  Jury in, yes?  Right, we'll

          16       have the jury in then, please.

          17                  (In the presence of the jury)

          18   THE ASSISTANT CORONER:  Thank you very much, members of the

          19       jury.

          20           Yes, then, Mr Underwood, who do we have?

          21   MR UNDERWOOD:  We are going to have Mr O'Carroll again for

          22       a short while because Mr Butt wants some more questions

          23       but he is not available as I speak, so can I call

          24       Ms Tilinskaite, please?

          25   THE ASSISTANT CORONER:  Yes, of course.


                                            66
 

 

 


           1                 MS GIEDRE TILINSKAITE (affirmed)

           2   THE ASSISTANT CORONER:  Well done, thank you very much.

           3       Come and have a seat.

           4   A.  Thank you.

           5   THE ASSISTANT CORONER:  If you pull the chair close to the

           6       microphone then we will pick up everything you have to

           7       tell us and Mr Underwood will ask you some questions.

           8                    Questions by MR UNDERWOOD

           9   MR UNDERWOOD:  Good morning.

          10   A.  Good morning.

          11   Q.  My name's Underwood and I'm the barrister working for

          12       the Inquest.  Can you tell us your name please?

          13   A.  My name's Giedre Tilinskaite.

          14   Q.  Tilinskaite?

          15   A.  Yes.

          16   Q.  I want to ask you questions about something that

          17       happened on 4 August 2011 in the Ferry Lane area; were

          18       you there?

          19   A.  Yes.

          20   Q.  Can you tell us what you saw, please?

          21   A.  I was going home on a 123 bus towards Walthamstow and

          22       I was sitting at the first -- at the first floor and the

          23       bus stop -- not at the bus stop, so it was for a few

          24       minutes and I wasn't interested at the time, but then

          25       through the window I could see some guys running away


                                            67
 

 

 


           1       and a police chasing them, so I bent down and looked

           2       through the bus window what was happening there.

           3           I could see some person dragged on the sidewalk and

           4       I could see some car blocked by other cars and that

           5       person was dressed of -- his t-shirt had been taken off

           6       and he was put down on the sidewalk and then people

           7       started going upstairs the bus, so I was one of them as

           8       well, going to the second floor of the bus.

           9           There I could see there was another person, a bit

          10       further down on the sidewalk, which was surrounded by

          11       a lot of police officers and I couldn't see him and

          12       I just was seeing the man next to the silver car and

          13       later, when, after a few minutes, bus started to move

          14       and go towards Walthamstow, I could see that person was

          15       without his t-shirt and his chest was covered in blood

          16       and he was giving a CPR.

          17   Q.  Let's take this in stages.  When you were downstairs you

          18       saw a man who ended up having his t-shirt taken off

          19       that; is right?

          20   A.  Yes.

          21   Q.  Can you remember what colour clothes, what colour top he

          22       had?

          23   A.  No, can't recall.

          24   Q.  How many people were with him when his t-shirt was being

          25       taken off, can you recall that?


                                            68
 

 

 


           1   A.  At least two or three.

           2   Q.  Then when you got upstairs you saw police surrounding

           3       a different person, did you?

           4   A.  Yes.

           5   Q.  Then, as the bus moved away, you were telling us you saw

           6       something else; was that a third person or was that

           7       a better view of one of those two?

           8   A.  No, it was a better view of those two because from where

           9       the bus was, we couldn't see that far.  We could see the

          10       people in that area, but we couldn't see what was

          11       exactly happening there.  There was a crowd of people.

          12   Q.  When you got that better view, you spoke a moment ago of

          13       seeing some blood?

          14   A.  Yes.

          15   Q.  Was that on the second person you saw or the first

          16       person?

          17   A.  The second person.

          18   Q.  Did you hear any shots at any point?

          19   A.  No.

          20   MR UNDERWOOD:  Thank you very much.  Other people may have

          21       some other questions for you.

          22   THE ASSISTANT CORONER:  Mr Straw, do you have questions?

          23   MR STRAW:  No, thank you, sir.

          24   MR STERN:  No, thank you.

          25   MR KEITH:  No, thank you.


                                            69
 

 

 


           1   MR BUTT:  No, thank you.

           2   MR GLASSON:  No.

           3   THE ASSISTANT CORONER:  I have no other questions either.

           4           Thank you very much for coming forward to assist the

           5       jury.  That completes your evidence, you are free now to

           6       go.  Thank you.

           7                      (The witness withdrew)

           8   MR UNDERWOOD:  Thank you.  May we have Mr O'Carroll back

           9       briefly, please.

          10                MR KIERAN ELY O'CARROLL (recalled)

          11   THE ASSISTANT CORONER:  You are still under the oath that

          12       you took before.  Mr Butt has thought of some questions

          13       to ask you.

          14                       Questions by MR BUTT

          15   MR BUTT:  Just some questions concerning officer G on the

          16       map.  Do you recall the position G that you marked?

          17   A.  Yes.

          18   Q.  You thought that was an armed police officer; is that

          19       right?

          20   A.  If I've said that in my statement, that will be what

          21       I -- as I recalled it.

          22   Q.  You said in your statement that you recognised the black

          23       and white checked cap; does that ring a bell?

          24   A.  That rings a bell.

          25   Q.  He was stood over an area of grass and you thought he


                                            70
 

 

 


           1       was protecting that area on the ground; is that right?

           2   A.  That rings a bell from the statement, yes.

           3   Q.  Yes.  Then a little later, a number of other armed

           4       police officers come onto that grassed area; do you

           5       recall that?

           6   A.  As I say, it's -- you know, if that's what it says in

           7       the statement then that would be the most accurate

           8       recollection.  Now it's quite a long time ago.

           9   Q.  Perhaps if you look at page 544 -- 543, I'm sorry.  It's

          10       paragraph 4, so this is after you have described

          11       officer G with the black and white checked hat.  A group

          12       of -- another group of police officers arrive to move

          13       the youths on the tarmac path back:

          14           "I think there were two to three police officers.

          15       This group of officers were armed police.  I think they

          16       had arrived from some form of estate car that had pulled

          17       up.  I have a memory of cordoning tape being put up

          18       around the grass area.  I don't know at which point

          19       chronologically this happened.  Officer G greeted one of

          20       the officers within this group of officers by name, they

          21       were on first name terms but I cannot recall what.

          22       Officer G pointed out something on the grass to the

          23       officer.  I have marked this point as J on my map."

          24           Yes?

          25   A.  Yes.


                                            71
 

 

 


           1   Q.  Looking at that in sequence then.  To begin with,

           2       officer G is guarding a small area of grass, yes?

           3   A.  Yes.

           4   Q.  Then a short time later, two or three or armed officers

           5       arrive on the scene, yes?

           6   A.  Yes.

           7   Q.  To begin with, they are concerning themselves with

           8       moving the youths away from the area and that sort of

           9       thing, yes?

          10   A.  Yes.

          11   Q.  Then a short time later, they join officer G, who is

          12       standing over this small area of grass that he is

          13       protecting; is that right?

          14   A.  To begin with, they were concerned with moving the

          15       youths on.  I believe -- I believe that one of the

          16       officers may have stepped towards officer G and G

          17       towards one of the officers as they have greeted, yes.

          18   MR BUTT:  Thank you very much.

          19   THE ASSISTANT CORONER:  Thank you, Mr Butt.

          20           Anyone else got anything?  No.  Mr Underwood,

          21       anything arising out of that?

          22   MR UNDERWOOD:  No, thank you very much.

          23   THE ASSISTANT CORONER:  Thank you then, Mr O'Carroll, you

          24       may now escape completely.  I should leave the building

          25       very quickly before someone else can find something else


                                            72
 

 

 


           1       to ask you.  Thank you very much.

           2                      (The witness withdrew)

           3   MR UNDERWOOD:  Mr Biggs, please.

           4                    MR DARREN BIGGS (affirmed)

           5   THE ASSISTANT CORONER:  Right, thank you very much,

           6       Mr Biggs.  Come and have a seat firstly.  Pull the chair

           7       in a little bit so we pick up your voice on the

           8       microphone and Mr Underwood will ask you some questions.

           9                    Questions by MR UNDERWOOD

          10   MR UNDERWOOD:  Good morning, Mr Biggs.

          11   A.  Morning.

          12   Q.  My name's Underwood and I'm counsel to the Inquest, so

          13       I start the questioning.  As I'm sure you know, we are

          14       interested in 4 August 2011.

          15   A.  Yes.

          16   Q.  Where were you at about 6.15?

          17   A.  I was coming home from work.  I was working on the

          18       Tottenham Hale job and I was walking up towards -- I'm

          19       not a local, by the way, I'm from Portsmouth, so I don't

          20       really know the area.  I was walking up the roads

          21       towards the traffic lights where you turn right onto the

          22       hill, onto the bridge going over the railway.

          23   Q.  Can we have a look at a sketch you have drawn -- in

          24       fact, two sketches you have drawn.  CE164 to start with,

          25       it's up on the screen there.


                                            73
 

 

 


           1   A.  Yes.

           2   Q.  Does this help you orientate yourself?

           3   A.  Where is the site from there?  I've got you, right.

           4   THE ASSISTANT CORONER:  Do you want it twisted round a bit?

           5       It might be upside down.  Is that better?

           6   A.  That's the road where the bus stop is, yeah?  This one

           7       here.  So I'm walking up this road (indicates) maybe

           8       200 yards away from where the crossing is.

           9   MR UNDERWOOD:  Right.

          10   A.  Just heard a load of sirens, lot of cars pulling up

          11       quick against lights and everything, didn't take much

          12       notice of it.  Turned up onto the road, then got --

          13       maybe just level with the bus stop, past the bus stop

          14       maybe, heard a load of commotion behind me, turned

          15       round, then they had some officers coming up the bridge

          16       telling people to get off the bridge, so I just carried

          17       on walking to the train station.

          18   Q.  Right.  Let's have a look at a couple of still

          19       photographs taken from some CCTV if we can, what's said

          20       to be 18.13.27 seconds there (indicates); is that you?

          21   A.  Yes.

          22   Q.  I think the next frame catches you turning round.

          23   A.  Yes.

          24   Q.  We're told that that's 18.12.46 seconds in real time,

          25       but whatever the timing was, you say that there was


                                            74
 

 

 


           1       a bit of commotion behind you, that's what made you turn

           2       round?

           3   A.  Yes.

           4   Q.  Can you remember exactly what it was that made you turn?

           5   A.  Screeching of tyres -- just a general commotion,

           6       screeching of tyres maybe.  Yeah, just a load of noise

           7       that shouldn't have been there.

           8   Q.  Right.  Were there gunshots at all in this incident?

           9   A.  (Pause)

          10           From now, I can recall a crack.  Not ever having

          11       heard a gunshot before in my life, I heard a crack.

          12   Q.  Just one crack?

          13   A.  Yeah.

          14   Q.  Before the screeching of tyres, after the screeching of

          15       tyres, can you help?

          16   A.  You would have to go back to my original statement to

          17       check out what I said there because it's very, very

          18       vague now.

          19   Q.  You made your statement on 22 September 2011.

          20   A.  Yes.

          21   Q.  Were things clear enough in your mind then?

          22   A.  They were clear enough as a point of having to remember

          23       at the time.  Not a lot of thought process had gone into

          24       it between August and September but --

          25   Q.  Okay.  So there's a commotion, you turn your head; what


                                            75
 

 

 


           1       did you see?

           2   A.  Yes.  I just remember, just a load of grey cars.

           3       I remember a taxi, kind of, taxi shaped car -- I just

           4       remember a load of grey cars.  Lots of people's heads

           5       behind the cars.  The one thing that does stick out in

           6       my mind -- was a mop-haired -- black, mop-haired officer

           7       doing that (indicates), that's the one thing that just

           8       stays in my mind.

           9   Q.  Just pulled something -- as if from your left waistband?

          10   A.  Whether he was just pulling a waistcoat up or -- yeah,

          11       he was just doing that motion (indicates).

          12   Q.  Did you see anybody on the ground?

          13   A.  No.

          14   Q.  Did you see any first aid?

          15   A.  No.

          16   Q.  Before you turned your head round, in this commotion,

          17       can you help us with whether there was any shouting?

          18   A.  (Pause)

          19           No, I can't, no.

          20   MR UNDERWOOD:  Thank you very much.  There may be some other

          21       questions from other people.

          22   THE ASSISTANT CORONER:  Let's see, Mr Straw?

          23   MR STRAW:  No, thank you.

          24   THE ASSISTANT CORONER:  Mr Stern?

          25                      Questions by MR STERN


                                            76
 

 

 


           1   MR STERN:  Yes, please.

           2           You made a statement on 22 September 2011.

           3   A.  Yes.

           4   Q.  I don't know if you have had an opportunity of reading

           5       that through today or not?

           6   A.  No.

           7   Q.  No, all right.  I wonder if you could perhaps have up on

           8       the screen CS400.  If we look at the top part of it, let

           9       me just see if this helps you refresh your memory:

          10           "As I reached the entrance to the student

          11       accommodation which is on the right-hand side, of the

          12       road -- the same side that I was walking on; I heard

          13       a commotion behind me.  I don't know what that commotion

          14       was I just remember hearing a noise behind me to my left

          15       which made me turn around to see what was happening; in

          16       the process of turning I heard 'crack crack' a noise

          17       which I believed to be gun fire.  It was one crack

          18       followed immediately by another crack.  As I've turned

          19       I've seen a group of cars, three maybe four."

          20           Then you say you have made a sketch plan, all right?

          21   A.  Yes.

          22   Q.  Perhaps we could just have a look now at the CCTV which

          23       shows that, or just shows that very movement that you

          24       have just described there.  We can see it in motion,

          25       I think.  We have it in motion.


                                            77
 

 

 


           1   THE ASSISTANT CORONER:  There are just two still ones,

           2       aren't there?

           3   MR STERN:  No, there's motion as well, there's four stills

           4       and one motion, I think.

           5   THE ASSISTANT CORONER:  Let's see what we can get.

           6   MR STERN:  Exhibit 149 is what the whole thing is.  You've

           7       only got the stills?  I have the others, all right.

           8       Perhaps you could look at all the stills then.  Let's

           9       just look at those.

          10           If we zoom in a little we might be able to see it

          11       more clearly.

          12           You see, you're walking along, then you turn and

          13       then you turn and stand and that may be all the stills

          14       that there are.  Thank you.

          15           Now, is the statement that you made, or the comment

          16       that you made in your statement, that in the process of

          17       turning you heard "crack, crack", a noise which you

          18       believed to be gun fire --

          19   A.  Yes.  In fact, that was made at the time.  It's much

          20       fresher in my mind then than it is now.

          21   Q.  Right.  Have you any reason to believe that was not

          22       accurate when you made your statement or not?

          23   A.  No, no reason whatsoever.

          24   Q.  The timings on there, just so we have it -- on the

          25       timing on the photograph is 18.13.26, 27, 28 and 30.


                                            78
 

 

 


           1       I can give you what they translate to afterwards.

           2   THE ASSISTANT CORONER:  Yes.  I know they are translated

           3       into more accurate 18.12.48 --

           4   MR STERN:  They've been corrected.  Can I just also ask you,

           5       please, to look at the plan, because I don't suppose you

           6       have looked at the plan, either, since you drew them.

           7   A.  No.

           8   Q.  Would you look, please, at CE0165.

           9   THE ASSISTANT CORONER:  We have that up on the screen.

          10   MR STERN:  Thank you very much.  If you zoom in a little

          11       bit, you describe the car that's "car 2" as being the

          12       minicab; does that come back to you or not?

          13   A.  Yeah.

          14   Q.  That's what you put in your statement, you describe it

          15       as a -- you don't call it a minicab, you say "people

          16       carrier type of car, grey/silver in colour"?

          17   A.  Yes.

          18   Q.  You say:

          19           "I could see the driver's side of the car 2, the

          20       windows and doors to car 2.  The windows and doors of

          21       car 2 were shut [the driver's side] I couldn't see

          22       anyone in car 2 ..."

          23           Car 2, you say, was taller than car 1.

          24   A.  Yes.

          25   Q.  So you couldn't see in it, there was no one in there, in


                                            79
 

 

 


           1       car 2?

           2   A.  Not that I can remember, no.

           3   THE ASSISTANT CORONER:  You are in the position on this plan

           4       at position A; is that right?

           5   A.  Yes.

           6   THE ASSISTANT CORONER:  You are looking back and you've got

           7       those two cars there, the front car is number 1 and

           8       behind that you have position B --

           9   A.  Yes.

          10   THE ASSISTANT CORONER:  -- which is the person that you're

          11       describing in your statement?  Thank you.

          12   MR STERN:  Thank you very much indeed.  How long were you

          13       actually there for?  Did you wait for some time?

          14   A.  (Pause)

          15           It's hard to say, five minutes, maybe -- (Pause)

          16           A minute, a minute and a half maybe?  Not even that

          17       long?

          18   Q.  I think you actually looked at some photographs of

          19       images in a further statement at 403.  It will come up

          20       on the screen in a minute.

          21           What we can see is you identified yourself in

          22       a number of photo images.  If we look at the bottom,

          23       it's 18.13.26, as they were marked on those photographs,

          24       and it goes right up to 18.15.14.

          25   A.  Right.


                                            80
 

 

 


           1   Q.  So you were there for at least that period of time but

           2       maybe you were there longer?

           3   A.  All right, okay, fair enough.

           4   Q.  At the time, when we can see you on those photographs,

           5       you have said in your original statement that you

           6       weren't wearing headphones and you were not on the

           7       phone?

           8   A.  No.

           9   MR STERN:  Thank you very much.

          10   THE ASSISTANT CORONER:  Thank you, Mr Stern.  Mr Keith?

          11   MR KEITH:  No, thank you.

          12   THE ASSISTANT CORONER:  Mr Butt?

          13   MR BUTT:  No, thank you.

          14   THE ASSISTANT CORONER:  Mr Glasson?

          15   MR GLASSON:  No, thank you.

          16   THE ASSISTANT CORONER:  Back to you Mr Underwood?

          17   MR UNDERWOOD:  Nothing arising.  Thank you very much.

          18   THE ASSISTANT CORONER:  That concludes all the questions for

          19       you, Mr Biggs.  Thank you very much for coming along to

          20       assist the jury.

          21   A.  Cheers, thank you.

          22   THE ASSISTANT CORONER:  You are free now to go.

          23                      (The witness withdrew)

          24   MR UNDERWOOD:  The next witness is Mr Drzewiecki.  He has an

          25       interpreter and he is not coming until 1.30, as I


                                            81
 

 

 


           1       understand it.

           2   THE ASSISTANT CORONER:  We have been so efficient.

           3                           Housekeeping

           4   MR STERN:  May I suggest two things we do now, only very

           5       briefly.  The first is in relation to the timing, that

           6       that timing, so it's cross referenced, is 18.12.47.

           7   THE ASSISTANT CORONER:  Yes.  That's what Mr Underwood said

           8       in-chief actually: at 18.12.46 he turned around.  But

           9       anyway that's helpful, I have that noted.

          10   Video footage evidence (as per Miss J's daughter's evidence)

          11   MR STERN:  Thank you very much.

          12           The second is this: you will remember that when

          13       Miss J's daughter gave evidence she was describing the

          14       man in the black t-shirt.  We have now got that set

          15       up -- Mr Scott has that set up -- to show the jury.  If

          16       that would be a convenient moment?

          17   THE ASSISTANT CORONER:  To show the jury?

          18   MR STERN:  The particular time that she referred to --

          19   THE ASSISTANT CORONER:  All right.

          20   MR STERN:  -- and the man in the black t-shirt.

          21   THE ASSISTANT CORONER:  That would be quite useful to do

          22       that now.  Could that be done now, Mr Underwood?

          23   MR UNDERWOOD:  It can.

          24   THE ASSISTANT CORONER:  Is someone going to say anything or

          25       are we just going to play it?  Do you want to say


                                            82
 

 

 


           1       anything?  I am quite happy for anybody to give

           2       a running commentary.

           3           Miss J has talked about seeing a man with a dark

           4       grey/black t-shirt going off towards Tottenham Hale

           5       direction.  She, as we know, when we're looking at this

           6       screen, is down the far right underneath the trees,

           7       isn't she, looking up towards the incident?

           8   MR STERN:  Yes.  We'll see the man come from the left at

           9       about 00.31, going in -- he will be the nearest.  He

          10       runs over to the right.  So I think that's probably the

          11       nearest that I could say for the moment.

          12   THE ASSISTANT CORONER:  Let's play it and we'll look out for

          13       someone in grey and then we'll let anyone else make a

          14       comment in a moment.  Let's do that firstly.

          15            (The BBC footage was played to the court)

          16   MR STERN:  Here he comes, he's running over there.

          17   THE ASSISTANT CORONER:  That's certainly a man in a dark top

          18       running off towards Tottenham Hale.

          19                     (The BBC footage ended)

          20   MR STERN:  Mr Scott has also cleverly put this together with

          21       the closer CCTV from the bus where we can see the same

          22       individual far closer but running across.

          23              (CCTV footage was played to the court)

          24   THE ASSISTANT CORONER:  There's someone ... the timing of

          25       this is what?


                                            83
 

 

 


           1                     (The BBC footage ended)

           2   THE ASSISTANT CORONER:  I'm trying to look at the top of it.

           3   MR STERN:  I think Mr Scott has the time on his disc.

           4   THE ASSISTANT CORONER:  Yes.  It's a matter of comment,

           5       I suppose, but it may not be that which Miss J was

           6       referring to, I don't know.

           7   MR STERN:  No, no, that's precisely why I pointed to that

           8       time.  Because you will remember she was shown in her

           9       interview exactly that time and that is the time that we

          10       have just looked at.

          11   THE ASSISTANT CORONER:  We'll work out --

          12   MR STERN:  If there's any problem with that -- I didn't want

          13       to have to ask for her to ...

          14   THE ASSISTANT CORONER:  I do not know whether that could be

          15       done now anyway.

          16   MR STERN:  No.  That was precisely the time that, in her

          17       interview, you will remember, that I asked her about it,

          18       and it's the time we just looked at.

          19   THE ASSISTANT CORONER:  All right.

          20           Mr Straw, you wanted to say something?

          21   MR STRAW:  Thank you sir.  So that segment was played to

          22       Miss J's daughter in interview and she was given

          23       precisely that time and asked whether the man she

          24       remembered taking something from the area of the cab was

          25       this one.  She said:


                                            84
 

 

 


           1           "I thought it was a bit after the person I can

           2       remember."

           3           So it sounds like the person she can remember is not

           4       this one, it's someone a bit after.

           5   THE ASSISTANT CORONER:  Yes, all right.  We may not be able

           6       to clear that anymore.  But anyway, thank you; that's

           7       what was put to her.

           8           There we are, members of the jury, I do not know

           9       whether that's clarified anything or made things

          10       slightly more opaque really.  But anyway, we'll have to

          11       argue about that amongst ourselves as to what happens.

          12           Right, well, that's it then for this morning.  We've

          13       been so efficient you will have longer to enjoy the

          14       sunshine outside because I think the next witness is due

          15       with his interpreter at 2 o'clock.

          16           Thank you very much then.  If you would like to

          17       leave us and be ready for a 2 o'clock start then.


                                            85
 


          10   (1.02 pm)

          11                     (The short adjournment)

          12   (2.00 pm)

 

                                          102
 

 

          18                  (In the presence of the jury)

          19   THE ASSISTANT CORONER:  Yes, Mr Underwood.

          20   MR UNDERWOOD:  Mr Drzewiecki, please and his interpreter.

          21   THE ASSISTANT CORONER:  I wonder if Mr Drzewiecki and his

          22       interpreter could come forward, please.

          23           Firstly, the interpreter first.

          24                      INTERPRETER (affirmed)

          25   THE INTERPRETER:  My name is Lukasz Ciolek and the language

 

                                           103
 

 


           1       is Polish.

           2   THE ASSISTANT CORONER:  Thank you very much indeed.  We will

           3       now ask for the witness to be sworn or affirmed.

           4                    MR EMIL DRZEWIECKI (sworn)

           5      (All evidence interpreted unless otherwise indicated)

           6   THE ASSISTANT CORONER:  Thank you both, very much.  If you

           7       would like to have seats then, please.  We'll see how it

           8       goes, thank you.

           9                    Questions by MR UNDERWOOD

          10   MR UNDERWOOD:  What are your full names, please?

          11   A.  Emil Drzewiecki.

          12   THE INTERPRETER:  My name is Lukasz Ciolek.

          13   MR UNDERWOOD:  I want to ask questions about 4 August 2011.

          14       Can you tell us where you were at about 6.10 that

          15       evening?

          16   A.  6.10?

          17   Q.  Yes, please.

          18   A.  I think I was already at home.

          19   Q.  Right.  Were you aware of the incident that involved

          20       cars and firearms?

          21   A.  Yes, but this happened after work.

          22   Q.  What time was that?

          23   A.  About 5.00 -- a few minutes after 5.00.

          24   Q.  Can you tell us what you think happened at about a few

          25       minutes after 5.00?


                                           104
 

 

 


           1   A.  I heard gunshots and lots of commotion.

           2   Q.  Where were you?

           3   A.  I was sitting at the bus stop.

           4   Q.  Which bus stop was that?

           5   A.  So it was a bus stop on Ferry Lane.  It was next to the

           6       building site.

           7   Q.  Right.  You heard gunshots and a lot of commotion, did

           8       you?

           9   A.  So after the gunshots -- because I was facing my back

          10       towards the whole incident, so after I heard the

          11       gunshots, I stood up and then I noticed that something

          12       was happening on the other side of the road.

          13   Q.  Right.  What was happening?

          14   A.  Behind the line of cars, there was lots of commotion,

          15       a lot of running.  I saw police hats and heard some

          16       screams, something like single shouts.

          17   Q.  How many gunshots were there?

          18   A.  So there were three gunshots.  The first one, then there

          19       was a break, and then two very quick ones.

          20   Q.  Are you familiar with gunshots?

          21   A.  Yes.

          22   Q.  Where have you heard them before?

          23   A.  In the army and when I go back to Poland, I sometimes

          24       take part in hunting.

          25   Q.  Did you see anybody who looked as if they had been


                                           105
 

 

 


           1       injured?

           2   A.  No.

           3   Q.  Did you see the police guarding anybody?

           4   A.  Yes, between the cars.

           5   Q.  Were you still there when a helicopter arrived?

           6   A.  Yes.

           7   MR UNDERWOOD:  Thank you very much.  That's all I want to

           8       ask.

           9   THE ASSISTANT CORONER:  Thank you.  Yes, Mr Straw?

          10                      Questions by MR STRAW

          11   MR STRAW:  Thank you.  Just one question to confirm.

          12           At the time the gunshots went off, were you at the

          13       bus stop just across the road from the incident?

          14   A.  Yes.

          15   MR STRAW:  Okay, thank you.

          16   THE ASSISTANT CORONER:  Let's see, Mr Stern, do you have any

          17       questions?

          18   MR STERN:  No, thank you.

          19   THE ASSISTANT CORONER:  Mr Keith?

          20   MR KEITH:  No, thank you.

          21   THE ASSISTANT CORONER:  Mr Butt?

          22   MR BUTT:  No, thank you.

          23   THE ASSISTANT CORONER:  Mr Glasson?

          24   MR GLASSON:  No, thank you.

          25   MR UNDERWOOD:  No questions, thank you.


                                           106
 

 

 


           1   THE ASSISTANT CORONER:  Thank you very much then,

           2       Mr Drzewiecki.  That concludes your evidence.  Thank you

           3       very much for coming forward to help us.

           4           Thank you very much, Mr Interpreter.

           5              (The witness and interpreter withdrew)

           6   MR UNDERWOOD:  The advice is we call Nino Hamadouche next.

           7   THE ASSISTANT CORONER:  Right, good.

           8                    MR NINO HAMADOUCHE (sworn)

           9   THE ASSISTANT CORONER:  Thank you very much.  If you come

          10       forward Mr Hamadouche.  Are you all right?

          11   A.  Yes.

          12   THE ASSISTANT CORONER:  Thank you, good.

          13                    Questions by MR UNDERWOOD

          14   MR UNDERWOOD:  Good afternoon, Mr Hamadouche.

          15   A.  Good afternoon.

          16   Q.  My name's Underwood and I'm counsel to the Inquest, so

          17       I start the questioning off.

          18   A.  Sure.

          19   Q.  I want to ask you about 4 August 2011 --

          20   A.  Okay.

          21   Q.  -- and an incident which we've heard took place at about

          22       6.10 or 6.12 in the evening in Ferry Lane?

          23   A.  Okay.

          24   Q.  Were you there?

          25   A.  I was, yes.


                                           107
 

 

 


           1   Q.  Whereabouts were you?

           2   A.  Inside the bus.

           3   Q.  Which bus was that?

           4   A.  The 123.

           5   Q.  The?

           6   A.  The 123 bus.

           7   Q.  We've seen CCTVs of two buses.  There's a double

           8       decker --

           9   A.  The one -- I took a bus from Seven Sisters towards

          10       Blackhorse Lane -- Blackhorse Road.  So I took the 123

          11       and then when I arrived -- when we arrived to

          12       Ferry Lane, so -- the bus was stopped suddenly and there

          13       was an undercover police car that blocked the bus.  So

          14       when I looked at my right, it was chaos basically so --

          15   Q.  Was there another bus in front of you or was yours the

          16       first bus in the queue?

          17   A.  No, I think it was the only bus, the one I was on.

          18   Q.  So which side of the bus were you on?

          19   A.  On the left-hand side.

          20   Q.  Okay.  So you had to look across the other seats and so

          21       on, did you?

          22   A.  Yes, on the right.

          23   Q.  What could you see?

          24   A.  Well, I could see the -- there was like five or six

          25       undercover police officers, there was a lady as well,


                                           108
 

 

 


           1       a blonde lady, cover -- undercover police.

           2   Q.  I'm sorry, could you move that microphone closer to you?

           3   A.  Okay.

           4   Q.  You were saying that you saw a number of undercover

           5       police officers?

           6   A.  Yes.

           7   Q.  How did you know they were police officers?

           8   A.  They were wearing the -- what is it called -- the vest,

           9       a vest.

          10   Q.  You say there was a lady officer as well?

          11   A.  Yes.

          12   Q.  Was she in uniform as well or plain clothes?

          13   A.  Well, she was plain but she was wearing a vest, a black

          14       vest.

          15   Q.  Did you draw a plan of what you saw?

          16   A.  Yes, I did.

          17   Q.  Can we have a look at CE101, please.  If we turn that on

          18       its left, thank you.  Now, can you recall what you were

          19       setting out here?

          20   A.  Pardon?

          21   Q.  Can you recall what you were drawing here?

          22   A.  Right, yeah.

          23   Q.  Can you help us with that?

          24   A.  Yes, that's -- (Pause)

          25           Right.  There was like a -- the car -- the minicab,


                                           109
 

 

 


           1       you know, the car, you know, was like an estate car.

           2   Q.  Yes, is that at D?

           3   A.  Eh?

           4   Q.  Where you have put the letter D?

           5   A.  I can't really remember now, it was, like, over two

           6       years ago so --

           7           Yeah, there was a car there, and there was another

           8       police car, like, just -- because I couldn't really see

           9       properly, you know, but I could see, like, police

          10       officers there and I saw -- and after that, I knew that

          11       that was two police officers, it wasn't Mark.  Someone

          12       was just sitting like I was sitting and there was

          13       another guy.  He put -- you know, his colleagues --

          14       I worked it out afterwards that they were police

          15       officers.  So he just put it down like --

          16   Q.  Put his colleague down?

          17   A.  Yes, laying down and I saw actually again on the floor.

          18   Q.  When you saw the colleague being put down, compared with

          19       the minicab, the silver car, where was that?  Was it to

          20       the front of it, the side of it or what?

          21   A.  It was just like, about, like, I would say a metre away

          22       from the minicab driver -- the minicab.

          23   Q.  All right.  What else did you see?  You say you saw

          24       a gun?  Where was that?

          25   A.  Just like between the two guys, the two police officers.


                                           110
 

 

 


           1   Q.  One of them was holding it, was he?

           2   A.  Actually, it was like that (indicates) and the gun, it

           3       was on the right-hand side, one of the police

           4       officers -- the one who was, like, laying down -- his

           5       colleague he helped him down, you know, to lay down.

           6   Q.  So one of those was carrying a gun, were they?

           7   A.  No.

           8   Q.  Where did you see the gun?

           9   A.  On the floor.

          10   Q.  By them?

          11   A.  Well, yeah, I mean it was obvious to me that it's one of

          12       the gun.

          13   Q.  Was it a long gun like a rifle or a short, like

          14       a pistol?

          15   A.  It's not a pistol for sure, but it's not like type of

          16       the Kalashnikov but it was, like, a bit smaller.

          17   Q.  Did you see anybody else injured?

          18   A.  No.

          19   Q.  What else did you see?

          20   A.  (Pause)

          21           It was chaos basically, it was a lot of shouting --

          22       I saw that blonde police officer.  She went to the car,

          23       she opened the car and she got, like, a -- like a file

          24       on her hand.  Definitely I saw that, and then she went

          25       back where the Mark was or where the incident --


                                           111
 

 

 


           1   Q.  When you say a file, a file like that red one there?

           2   A.  Yes, something like that, yes.

           3   Q.  Did you see anyone being guarded by police?

           4   A.  No.

           5   Q.  Did you see any of the cars move after this initial

           6       incident?

           7   A.  I did not.

           8   MR UNDERWOOD:  Thank you very much.

           9   A.  You're welcome.

          10   THE ASSISTANT CORONER:  Mr Straw?

          11                      Questions by MR STRAW

          12   MR STRAW:  Hello.

          13   A.  Hi.

          14   Q.  How far from the incident did the bus stop?

          15   A.  I would say about four metres, four or five metres.

          16   Q.  So you were that close to it?

          17   A.  Well, yes.

          18   Q.  Apart from you, were there a number of other members of

          19       the public on that bus?

          20   A.  Oh, yeah it was quite -- a lot of people inside the bus.

          21   Q.  What impact did the incident have on you?

          22   A.  Pardon?

          23   Q.  What impact did the incident have on you?

          24   A.  I didn't get that?

          25   Q.  Very well, possibly just the sneezing.  How did you feel


                                           112
 

 

 


           1       afterwards?

           2   A.  How I felt afterwards?

           3   Q.  Yes.

           4   A.  Well, confused.

           5   Q.  You mentioned in your statement that you were a little

           6       shaken about the incident and thought about it a lot for

           7       a few days afterwards; is that right?

           8   A.  Yes.  It was like a horror movie -- I mean, I didn't --

           9       when we stopped -- when we'd been stopped, it was, like,

          10       I thought to myself what's going on and then it's like

          11       a movie thing because I saw guns, so --

          12   MR STRAW:  Thank you very much.

          13   A.  You're welcome.

          14   THE ASSISTANT CORONER:  Mr Stern?

          15                      Questions by MR STERN

          16   MR STERN:  Just one brief matter, if I may.

          17   A.  Sure.

          18   Q.  I wonder if we could have the plan up at CE101 on the

          19       screen.

          20           You were asked about a car that's marked "D" and

          21       perhaps you will take it from me in your statement that

          22       you said that that was the car that you thought was

          23       boxed in?

          24   A.  Yes.  It was actually about -- as far as I remember it

          25       was -- I'm just going to try to picture it.  It was like


                                           113
 

 

 


           1       the car was one, two, three -- it was about three cars,

           2       yeah, and the car where Mark was, it was like -- it was

           3       actually boxed in, yes.  It was about one two three,

           4       three cars.

           5   Q.  Thank you, sir.  Will you look also at E on that picture

           6       that you will see up there.  What you said about E was

           7       that that was further away and there was a female police

           8       officer in this car, the car was blue, and that she came

           9       out of the vehicle then ran back to get a black file --

          10   A.  Mm-hmm.

          11   Q.  -- you say the sort that you would keep paper in.  Then

          12       she ran towards the incident, behind car D?

          13   A.  Yes.  Yes.

          14   Q.  Is that your recollection?

          15   A.  I think -- you know, it was like a long time ago but

          16       definitely I saw the lady and she ran back to her car,

          17       to the car, and then she got something like a file and

          18       then she went back straight where the incident was.

          19       That's 110 per cent.

          20   MR STERN:  Thank you very much.

          21   A.  You're welcome.

          22   THE ASSISTANT CORONER:  Thank you, Mr Stern.

          23           Mr Keith?

          24   MR KEITH:  No, thank you.

          25   THE ASSISTANT CORONER:  Mr Butt?


                                           114
 

 

 


           1   MR BUTT:  No thank you, sir.

           2   THE ASSISTANT CORONER:  Mr Glasson?

           3   MR GLASSON:  No, thank you, sir.

           4   THE ASSISTANT CORONER:  Back to you, Mr Underwood, if you

           5       have any further questions.

           6   MR UNDERWOOD:  No, thank you very much.

           7   THE ASSISTANT CORONER:  Thank you very much that completes

           8       your evidence, you are free now to go.  Thank you.

           9   A.  Thank you.

          10                      (The witness withdrew)

          11   MR UNDERWOOD:  Mr Finbar Hanrahan.

          12                    MR FINBAR HANRAHAN (sworn)

          13   THE ASSISTANT CORONER:  Thank you very much indeed.  Come

          14       forward and have a seat then, please.

          15   A.  Thank you.

          16                    Questions by MR UNDERWOOD

          17   MR UNDERWOOD:  Good afternoon, Mr Underwood.

          18   A.  Do I have to stand?

          19   Q.  No, stay there.  My name's Underwood, as you will have

          20       gathered, I ask questions on behalf of the Inquest.

          21       I want to ask your full names first?

          22   A.  Finbar Gerard Hanrahan.

          23   Q.  As you will have gathered, we are asking about the

          24       events of 4 August 2011.

          25   A.  Yes.


                                           115
 

 

 


           1   Q.  Between roughly 6.10 and 6.15 that night, that afternoon

           2       rather, where were you?

           3   A.  I just returned home from work and was parked outside my

           4       house, which is number Erskine Crescent.  I was

           5       unloading tools from my van, transit van when I heard

           6       the shots.

           7   Q.  Can we have a look at a diagram you drew.  It's at

           8       CD2195.  It will come up on the screen.  If we twist it

           9       that way we can see that Jarrow Road, which we know

          10       fronts onto the green --

          11   A.  Mm-hmm.

          12   Q.  -- twists around on the right-hand side of the diagram

          13       there.  It goes left and then there's Erskine Crescent.

          14       So you parked outside your house --

          15   A.  Yes.

          16   Q.  -- working with your tools and heard shots, you say?

          17   A.  Mm-hmm.

          18   Q.  Are you familiar with gunshots?

          19   A.  Yes.

          20   Q.  Because?

          21   A.  I was in the Territorial Army in Ireland.

          22   Q.  How many shots did you hear?

          23   A.  Three.

          24   Q.  Okay.  What did you do?

          25   A.  I immediately walked across the green, which is just


                                           116
 

 

 


           1       here (indicates), proceeded up along a little raised

           2       section and then I saw all the police and cars and then

           3       I was pushed back by the police.

           4   Q.  How far did you get?

           5   A.  To about 3 feet from the railings.  I had a clear view.

           6   Q.  You obviously know that we're talking about Mr Duggan

           7       and that he was shot and that there was a point at which

           8       he was on the pavement.

           9   A.  Mm.

          10   Q.  Did you get to the railings near where he was or --

          11   A.  Yes.

          12   Q.  -- just -- so how close were you to him?

          13   A.  I was about 3 foot from the railings and he was just off

          14       the pavement -- so I would say about 5 foot, 5 or

          15       6 foot.

          16   Q.  In terms of his position on the pavement, we've seen

          17       photographs of the width of the pavement, there's the

          18       minicab there, the railings on one side of the pavement,

          19       can you help about whether he was closer to the minicab

          20       or to the railings or halfway between or what?

          21   A.  No, he was nearer the outer edge of the pavement.

          22   Q.  So closer towards the minicab than the railings?

          23   A.  Yes.

          24   Q.  As far as you were concerned, in terms of people coming

          25       up on the green, were you the first on there or was


                                           117
 

 

 


           1       anybody else there?

           2   A.  No.  There was various other people that I could see

           3       further down the road, down Jarrow Road, that were

           4       coming forward at the same time.  As I've stated, it

           5       really was a matter of seconds is all, that I actually

           6       got there -- sorry, what was the question again?

           7   Q.  Were you the first one there, really?

           8   A.  No, I don't think I was the first one there but I was

           9       one of the first ones there at the scene.

          10   Q.  Okay.  So you described where Mr Duggan was, so closer

          11       to the minicab than to the railings, but what was his

          12       orientation?  Was he lying along the pavement?

          13   A.  Parallel with the pavement.

          14   Q.  What was happening?

          15   A.  There was various police coming around him and there was

          16       one policeman that was knelt down in front of him and

          17       I think -- I mean, in retrospect, I think he was giving

          18       him -- what do you call it, emergency C -- what do you

          19       call it?

          20   Q.  Chest compressions?

          21   A.  Yes.

          22   Q.  Just the one there at that stage?

          23   A.  No, there was at least three or four around him and

          24       other ones just behind him coming forward.

          25   Q.  Did you see a gun anywhere, a pistol?


                                           118
 

 

 


           1   A.  I saw the police guns but I didn't see any other gun.

           2       I saw the armed response, that's the only mental image

           3       I had.

           4   Q.  When you say you saw the armed response, you mean armed

           5       officers?

           6   A.  Yes.

           7   Q.  Did you see anybody else injured?

           8   A.  No.

           9   Q.  What happened to you?

          10   A.  I can remember there was police running down the stairs,

          11       because there's a stairwell down, and I remember being

          12       conscious of police running down, yeah, and then, from

          13       the other side of the railings, the policeman came

          14       forward like that (indicates) and he's pushed back.

          15           Then when I looked around, the police were actually

          16       putting tape around the trees -- it really happened

          17       really, really quickly.

          18   Q.  Were you pushed back --

          19   A.  I was, yes.

          20   Q.  -- or asked to go back?

          21   A.  Well, I was asked to, so I did.  I didn't want to be

          22       involved to be honest with you.

          23   Q.  Some of those officers were uniformed, were they --

          24   A.  Yes.

          25   Q.  -- including the ones asking you to go back?


                                           119
 

 

 


           1   A.  Yes.

           2   MR UNDERWOOD:  Very well.  Thank you very much.  There may

           3       be some other questions from other people.

           4   THE ASSISTANT CORONER:  Yes, Mr Straw, do you have

           5       questions?

           6                      Questions by MR STRAW

           7   MR STRAW:  Thank you, sir.  Could you have a look, please,

           8       at photograph CE315.  Do you see there there's the taxi,

           9       the silver people carrier --

          10   A.  Mm-hmm.

          11   Q.  -- and then some people on the floor on the pavement --

          12   A.  Mm-hmm.

          13   Q.  -- and behind that, there's the green.

          14   A.  Mm-hmm.  That's where I was stood, right there, that's

          15       as far as --

          16   THE ASSISTANT CORONER:  Where are you pointing to?

          17   A.  The people behind, that's where I got to, approximately.

          18   THE ASSISTANT CORONER:  Can you point it up there, so the

          19       jury can see, Mr Hanrahan?

          20   A.  I got to about here (indicates).

          21   MR STRAW:  Right next to where those two men are standing?

          22   A.  Yes.

          23   THE ASSISTANT CORONER:  That's when you say you were 3 feet

          24       away from the railings?

          25   A.  Yes.


                                           120
 

 

 


           1   MR STRAW:  Just to make sure I've got the sequence of events

           2       right: you heard the gunshots?

           3   A.  Yes.

           4   Q.  Then within seconds you came and walked across the

           5       green --

           6   A.  Mm-hmm.

           7   Q.  -- and got to where those two men are standing.  Any

           8       idea how long it took you to get to where those men are

           9       standing?

          10   A.  20 seconds, 30 seconds.

          11   Q.  Okay.  After the shooting?

          12   A.  Mm.  I don't know why but instinctively -- because

          13       I have three sons -- instinctively when I heard that

          14       I wanted to see what was going on.

          15   Q.  Yes.  Did you see a gun on the green at any point?

          16   A.  No.  Not to my recollection, no.

          17   Q.  Would you describe yourself as an observant person?

          18   A.  Yes.  I'm a designer.

          19   THE ASSISTANT CORONER:  Sorry?

          20   A.  I'm a designer.

          21   THE ASSISTANT CORONER:  You're a designer, right.

          22   MR STRAW:  Could you keep that photo up, please.  That will

          23       come back up again in a moment.  You mention you're

          24       an observant person.  If there had been a gun on the

          25       green around where you were then, would you have seen


                                           121
 

 

 


           1       it?

           2   A.  Well, I didn't.  I possibly could have if it was there.

           3       I can see where you've circled now and it is

           4       approximately where it was but, in truth, my

           5       concentration was on the man -- was further like that

           6       (indicates).

           7   THE ASSISTANT CORONER:  We note you wear glasses for what,

           8       for looking at the screen, or --

           9   A.  Well, both actually.  I have to wear glasses for reading

          10       and for looking at the screen.

          11   THE ASSISTANT CORONER:  Did you have your glasses on at this

          12       time when you were walking over there?

          13   A.  No, no, I don't wear the glasses, you know, when I'm

          14       working.

          15   THE ASSISTANT CORONER:  When you're working on the tools and

          16       such like outside your house you don't wear glasses?

          17   MR STRAW:  But presumably you are not so short-sighted that

          18       without your glasses on you wouldn't be able to see

          19       a gun laying on the floor 5 foot in front of you?

          20   A.  No, no.  I've only started wearing glasses actually in

          21       the last probably two and a half years.  So my eyesight

          22       is only just starting to go, it's only a little bit

          23       impaired and not very impaired.

          24   MR STRAW:  Thanks very much.

          25   THE ASSISTANT CORONER:  Mr Thomas?


                                           122
 

 

 


           1                      Questions by MR THOMAS

           2   MR THOMAS:  Could you leave the photo up, please.

           3           Sorry, I should have introduced myself.  My name is

           4       Thomas, I represent the loved ones of Mark Duggan.

           5   A.  Sorry?

           6   Q.  My name's Thomas and I represent the loved ones of Mark

           7       Duggan.

           8   A.  Okay.

           9   Q.  You have just indicated where you got to about 3 feet,

          10       did you say, from where the railings were?

          11   A.  Approximately.

          12   Q.  Approximately, and this was fairly shortly after you

          13       heard the gunshots?

          14   A.  (Nods).  About 20 to 30 seconds.

          15   Q.  20 to 30 seconds.  Can you just, just so we can picture

          16       it in our mind's eye, when you get to where you get to,

          17       what sort of activity is going on?

          18   A.  Well, there's a lot of police and plain clothes as well.

          19       I mean, that's my presumption, because they seemed to be

          20       a part of what was going on, so that's just my

          21       presumption.  I've lived there in that house for

          22       18 years and I've brought three children up, and --

          23       sorry, what was the question again?

          24   THE ASSISTANT CORONER:  When you're within the 3 foot -- in

          25       that position, what's going on on the other side of the


                                           123
 

 

 


           1       railings?

           2   A.  As I said, there was like three or four immediately

           3       around the person on the floor, yes.  He's -- his body

           4       is spasming and there's other people further back --

           5       there seemed to be a lot of people to me but, at that

           6       stage, I was pushed forward and once I -- I am --

           7       basically, what I was looking for was my sons, if any of

           8       my sons were around, I wanted to ensure -- it's

           9       a parent's instinct, isn't it?

          10   THE ASSISTANT CORONER:  Yes, of course.  Thank you.

          11   MR THOMAS:  Just so we're clear on this, by the time you get

          12       there, I think you said you indicated that there was

          13       spasms coming from Mark --

          14   A.  Mm.

          15   Q.  So you're there very, very quickly after this incident?

          16   A.  Yes, I'm nearly -- I'm more or less on the doorstep.

          17   Q.  Right, you're more or less on the doorstep.  I fully

          18       appreciate what you say, that you were concerned about

          19       your sons and all the rest of it and you didn't see

          20       a gun, but the object that would have been in the

          21       vicinity -- if you look at the photo, can you see --

          22       this was in August and the grass wasn't particularly

          23       long grass; do you follow?

          24   A.  Yes.

          25   Q.  Right.


                                           124
 

 

 


           1   A.  All this vegetation now has been trimmed down.

           2   Q.  There's some vegetation there, but we are not talking

           3       right up against the fence, we are talking about on the

           4       green.  The object is about that size (indicates).  It

           5       wouldn't have been orange.  I wonder if we could put up

           6       a photograph of the gun in the sock; do you see that?

           7   A.  Mm.

           8   Q.  Can we go to the next one, please.  So that's the sort

           9       of object we're talking about.  You didn't see anything

          10       like that?

          11   A.  No, I would recognise a gun.  As I said, I was in the

          12       army for two years, I've used all sorts of weapons.

          13       I was in at the ack-ack.

          14   MR THOMAS:  Thank you very much.

          15   THE ASSISTANT CORONER:  Mr Stern, do you have questions?

          16                      Questions by MR STERN

          17   MR STERN:  Thank you very much.  As I understand it, you

          18       heard shots and you recognised that it was gunshots for

          19       the reasons you have already told us today.

          20   A.  Yes.

          21   Q.  I think that when you wrote your statement, which was on

          22       6 December 2012, you were not sure of the number of

          23       shots.  I don't know if you have had an opportunity --

          24   A.  I said three or four -- I think I said three or four.

          25   Q.  It's not a criticism of you at all.  I want to know


                                           125
 

 

 


           1       whether you have looked at your statement since.

           2   A.  No, I haven't.

           3   Q.  You haven't, all right.  Obviously you are now looking

           4       quite far ahead, but I wonder if you could just have

           5       your statement put up on the screen, CS2221.  It goes

           6       over to 222.  It's right at the bottom of the page.

           7       I can probably take it a bit more quickly -- it's at the

           8       bottom of the page you say:

           9           "As I opened the front door to my house, I heard

          10       gunshots go off.  I can be sure that the noise I heard

          11       was from a gun because I was previously in the army."

          12           That's what you have told us today:

          13           "It was clearly a gun.  I know the difference

          14       between other noises, like the sound of a car

          15       backfiring ... and I have heard gunshots before in the

          16       area but these were particularly close and particularly

          17       loud.  I am not sure but I think I may have heard two

          18       gunshots but because they were fired in quick succession

          19       of each over it appeared to sound like one loud bang but

          20       possibly with two shots within it."

          21           I think that was the way it was.  So, even though

          22       you are experienced with guns and hearing gunshots, you

          23       could not say precisely the number of shots there were

          24       when you came to --

          25   A.  Well, the initial sound, to me, sounded like they were


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           1       in quick succession.  It was a quick succession.  When

           2       guns are fired in quick succession it's very hard to

           3       distinguish how many shots.

           4   Q.  Exactly.

           5   A.  Because one noise leads into another so --

           6   Q.  Then you went on to the green and, as I understand it,

           7       there was no one else there at the time.

           8   A.  There was no one on the green but there were people on

           9       Jarrow Road coming up.

          10   Q.  Yes.  If we look at the BBC footage right from the

          11       start -- I don't know if you've seen this.  Can we see

          12       you there on the green?

          13   A.  Excuse me.

          14   Q.  Can we see you on the green?  I know it's not very clear

          15       but can we see you on the green at all, on the far side?

          16   THE ASSISTANT CORONER:  Do you want to play it a bit and

          17       make it move and be clearer?

          18             (Video footage was played to the court)

          19   MR STERN:  Just so you get your bearings, you may not have

          20       seen this before.

          21   A.  No.

          22   Q.  Don't worry about those arrows in the way but you can

          23       see the green area is beyond that, can't you?

          24   A.  I'm about there.

          25                    (The video footage ended)


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           1   Q.  If you could stand up and show us on the big screen that

           2       would be very helpful.  Are you about there?

           3   A.  There (indicates), I was down there.  That's the route

           4       I came up, right behind those trees.

           5   Q.  So is that where you think you were?

           6   A.  Yes, I think I got further along than that but

           7       I definitely got to those trees.

           8   Q.  So you were at those trees.  If we play it on a little

           9       more maybe you'll see yourself.  You tell us where it is

          10       you get to near the railings?

          11             (Video footage was played to the court)

          12   A.  There (indicates).

          13   Q.  Sorry, just pause it a moment.

          14   A.  There.

          15   Q.  You are over there, are you?

          16                    (The training video ended)

          17   A.  That's my feeling.  I am not 100 per cent certain but

          18       that's my feeling, yes.  That's my memory of it.

          19   Q.  Is that as near as you got to the incident, for example

          20       where the white arrow is?

          21   A.  I thought I got closer to it.

          22   Q.  Yes.  Do you think on reflection that maybe you didn't

          23       now?

          24   A.  No, I'm still sure I got closer than that.

          25   Q.  We'll carry on playing it, you tell us when we get


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           1       there.

           2             (Video footage was played to the court)

           3           Obviously that's a slight impediment but we are back

           4       on.

           5   A.  I've got a feeling I was more like there (indicates).

           6   Q.  You are pointing near that lamp post.

           7                    (The video footage ended)

           8   A.  That's too far away, I was somewhere around there.

           9       I can't see myself.  It's very blurred, obviously, but

          10       that was -- that's the proximity.  It's more than

          11       3 feet, for sure.

          12   Q.  Yes.

          13   A.  I mean, it's 3 feet to the railings but it's not 3 feet

          14       to where the gentleman was unfortunately shot.

          15   Q.  It's always difficult because obviously you were writing

          16       your statement in December 2012, obviously it was some

          17       time later.  What you said in your statement -- and

          18       perhaps I will just read it to you for moment, but it's

          19       page 2225 for anybody who wants to follow it -- you say:

          20           "For the second or two I was stood by the railings

          21       before I turned around ..."

          22           You remembered seeing the vehicles in Ferry Lane,

          23       you say.  Were you only there for a second or two?

          24   A.  Oh yes, three seconds at the most.  Because, as I said,

          25       my -- I kind of knew what was going on before I got


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           1       there, you know, within a couple of seconds.

           2   Q.  You had heard the shots?

           3   A.  I had heard the shots, I could see the commotion as

           4       I was walking over the little green there but what I was

           5       looking out for was my sons.

           6   Q.  Obviously.  No, I understand that.

           7   A.  Once I had ascertained they were actually near my house,

           8       then they came out too.

           9   Q.  All right.  I think you looked at the bus stop and there

          10       was no one at the bus stop to the side of where Mark

          11       Duggan was --

          12   A.  Yes.

          13   Q.  -- to the right of where Mark Duggan was.  There was

          14       no one at that bus stop, was there?

          15   A.  Not that I had noticed.

          16   Q.  The reason I say that is from your statement, again at

          17       2225, you say:

          18           "I did notice there was no one stood at the bus stop

          19       which was just to the left of Mark Duggan."

          20           You changed that in a later statement to being the

          21       right of Mark Duggan, I think.

          22   A.  Yes, I think it was more to the right now.  No, it could

          23       have been to the left, too far down.

          24   Q.  You're dropping your voice.

          25   A.  Yes, it was more to the right, I think, in my


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           1       recollection.

           2   Q.  Yes.  The other question that I wanted to ask you was

           3       this: there were no police officers -- or you didn't

           4       notice any police officers, on the green there, did you?

           5   A.  Yeah, there was.  They came up from down the stairwell,

           6       I came up and they further pushed us back and they were

           7       putting up tape around the trees.

           8   Q.  So the first thing that you remember of seeing a police

           9       officer, just if I've got this right, is that you were

          10       in the position that you have shown us now on the

          11       footage --

          12   A.  Mm.

          13   Q.  -- and the police officer, after a couple of seconds,

          14       sent you back down and then they put up this cordon,

          15       yes?

          16   A.  Yes, they said, like, "Go back onto the road off the

          17       green completely, don't want anybody on the green".

          18   Q.  The other question I want to ask you, please, is this:

          19       you say it was a nice sunny day, not hot but not cold;

          20       it was perfectly light not windy and there was no rain?

          21   A.  It was quite mild, like today.

          22   Q.  I'm just reading from your statement page 2228; do you

          23       remember that or not really now?

          24   A.  Two years ago, mate.

          25   Q.  Exactly, exactly.  Anyway, that's what you wrote on your


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           1       statement.  Any reason to suggest that might not be

           2       right?

           3   A.  I still remember it clearly, it was a nice day, I was

           4       unloading my tools.  I know when it's raining I have to

           5       do it in a different way, I have to reverse my van

           6       completely into my garage when it's raining.

           7   Q.  The other thing I want to ask you is this again at 2229:

           8       you said you had a better view of Ferry Lane now, you

           9       were talking about in December:

          10           "... as at the time there were bushes running along

          11       the railings, which have been cut down since last year

          12       and the bushes were two and a half to three feet high

          13       and they would have restricted my view of the ground

          14       until I got to within approximately five to six feet of

          15       the railings."

          16   A.  Well, yes, they did obscure, yeah, because there was --

          17       they've cut them down, but there was bushes -- not trees

          18       just bushes, small bushes, you know.

          19   Q.  Yes, we've seen them on the pictures.

          20   A.  But they are quite dispersed so it's not as if it's

          21       completely obscured, just a little obscured but, as you

          22       can see in the thing right there, it's not screening the

          23       whole thing off, you can see quite clearly through it.

          24   MR STERN:  Just give me a moment.  (Pause)

          25           Yes, thank you very much.


                                           132
 

 

 


           1   THE ASSISTANT CORONER:  Thank you, Mr Stern.

           2           Mr Keith?

           3                      Questions by MR KEITH

           4   MR KEITH:  May I just ask you about one issue, please?

           5   A.  About what, sorry?

           6   Q.  I ask questions on behalf of the Metropolitan Police.

           7   A.  Okay.

           8   Q.  In your statement dated 6 December, you were asked, and

           9       you noted, that you didn't, in fact, see any guns or

          10       weapons or objects on Mr Duggan or on the pavement and,

          11       moreover, that you didn't see any guns or Tasers or

          12       weapons or side arms or any weapon at all, in fact,

          13       being held or carried by any of the police officers on

          14       the pavement?

          15   A.  Initially, yes.

          16   MR KEITH:  Thank you.

          17   THE ASSISTANT CORONER:  Thank you.

          18           Yes, Mr Butt?

          19   MR BUTT:  No, thank you, sir.

          20   THE ASSISTANT CORONER:  Mr Glasson.

          21   MR GLASSON:  No, thank you, sir.

          22   THE ASSISTANT CORONER:  Now, Mr Straw is very keen to ask

          23       another question.

          24   MR STRAW:  Sorry, there's something that arises from what

          25       Mr Stern heard, I wonder if I could be permitted to ask


                                           133
 

 

 


           1       these questions?

           2   THE ASSISTANT CORONER:  Yes.

           3                  Further questions by MR STRAW

           4   MR STRAW:  Thank you.  Mr Hanrahan, the video that was just

           5       played to you, did you realise that video didn't start

           6       until more than 35 seconds after the shooting.

           7   A.  No, I've never seen it before.

           8   Q.  You've never seen it before.  I think you told us

           9       earlier after the shooting it took 10 to 12 seconds for

          10       you to get to the point you pointed out on the photo

          11       near to the railings; is that right?

          12   THE ASSISTANT CORONER:  20 to 30.

          13   A.  20 to 30 seconds.

          14   MR STRAW:  Okay.  In your -- the only reason I said that to

          15       you --

          16   A.  It's an approximation.

          17   Q.  Of course.  The only reason I ask you that is that in

          18       your statement at 2222 you say:

          19           "I would say that it took me approximately 10 to 12

          20       seconds to get to this point as I was walking fast

          21       paced."

          22           Does that jog your memory?

          23   A.  I think when I was retracing my steps -- was it?  That's

          24       when I reached -- with the interviewers I retraced my

          25       steps.


                                           134
 

 

 


           1   Q.  Yes.

           2   A.  Then -- I said that and thought "Well, actually no, it's

           3       probably a little more than that, in retrospect, after

           4       I have retraced my steps", that it was more like 20 or

           5       30 seconds.

           6   Q.  20 or 30.  You are only at the location for a couple of

           7       seconds?

           8   A.  Yes, three or four seconds.

           9   Q.  Is it right that you immediately came back again?

          10   A.  Yes.  I turned around and walked right back to my own

          11       business.

          12   Q.  In fact --

          13   THE ASSISTANT CORONER:  You were asked to do that by the

          14       police?

          15   A.  Yes.  Well, I was asked to go back onto the road, you

          16       know (indicates).

          17   THE ASSISTANT CORONER:  Right.

          18   MR STRAW:  Here we go, I have found the point in your

          19       statement actually that I was looking for, about the 10

          20       to 12 seconds, and you say at the end of it, 2229:

          21           "I have also walked the route I took from my front

          22       door, across Jarrow Road and up onto the green at

          23       a similar pace to the speed that I went on the day of

          24       the shooting and I still feel it took me 10 to

          25       12 seconds to reach three feet from the black railings.


                                           135
 

 

 


           1       This is an estimate but I still feel confident this is

           2       the correct range of time as I was in a heightened state

           3       and I can move fast when I'm not running."

           4           It is a while ago but does that sound about right

           5       that it took about that length of time to get to the

           6       green?

           7   A.  As far as I recollect, when I was saying 10 or

           8       12 seconds, when I retraced might steps to my knowledge,

           9       to my memory, that actually that was an underestimation,

          10       that it would have -- when I retraced my steps, that's

          11       the point I was making.

          12   THE ASSISTANT CORONER:  Sorry, you wanted to say -- you were

          13       going to say something else, Mr Straw interrupted you at

          14       the end there, no?

          15   A.  That's the point I was making, yes.

          16   THE ASSISTANT CORONER:  An underestimation, you thought it

          17       took longer or short?

          18   A.  It took longer, but it couldn't have taken 10 to

          19       15 seconds.  That was my statement but when I retraced

          20       my steps I thought, well -- to my memory I was saying 10

          21       or 12 or 15 seconds was an underestimation.

          22   MR STRAW:  So something around that.  As we have said, the

          23       BBC footage doesn't start for some 35 or more seconds

          24       until after the incident.  Looked at in a round, could

          25       it be you arrived at that point which you pointed out on


                                           136
 

 

 


           1       the green and went before the video started?

           2   THE ASSISTANT CORONER:  Don't feel tempted to answer that.

           3   A.  I don't understand the question.

           4   THE ASSISTANT CORONER:  You are quite right.  We all

           5       understand the question, don't worry about it.  Could we

           6       just have Mr Noble-Thompson's picture up on there, just

           7       to see if that helps Mr Hanrahan find out if he was in

           8       the position.  There we are.  This is -- you can come

           9       back a bit actually, the gentleman with the bag --

          10   A.  Is that me?

          11   THE ASSISTANT CORONER:  Do you see where -- there we get

          12       more of an idea of the slope going up, there's the

          13       railings there across.  Do you see where it is?  Does

          14       that show us the area that you went to?

          15   A.  Precisely.

          16   THE ASSISTANT CORONER:  Well, you tell us where precisely

          17       where it was or point out there, if it helps.

          18   A.  To my knowledge, to my memory, it was somewhere around

          19       here (indicates).

          20   THE ASSISTANT CORONER:  Let's just -- over there?

          21   A.  Yes.

          22   THE ASSISTANT CORONER:  You can see where the little bit of

          23       wall and the railings are --

          24   A.  You can quite clearly see through the bushes there, they

          25       are quite dispersed.


                                           137
 

 

 


           1   THE ASSISTANT CORONER:  All right, thank you very much.

           2   MR STRAW:  Thank you, sir.

           3   THE ASSISTANT CORONER:  Thank you.  Let's just see then if

           4       any matter arises.

           5           Mr Stern?

           6   MR STERN:  No, thank you.

           7   THE ASSISTANT CORONER:  Mr Underwood, anything you want to

           8       add?

           9   MR UNDERWOOD:  No, thank you very much.

          10   THE ASSISTANT CORONER:  Thank you very much, Mr Hanrahan,

          11       for coming forward and helping the jury.  You are free

          12       now to go.  Thank you very much indeed.

          13                      (The witness withdrew)

          14   MR UNDERWOOD:  I suspect I'm going to be asking you for

          15       a break.  (Pause)

          16           I am going to be asking you for a break.

          17   THE ASSISTANT CORONER:  We have one more witness --

          18   MR UNDERWOOD:  We have indeed.

          19   THE ASSISTANT CORONER:  -- who has not quite arrived.  We'll

          20       have our afternoon break before that witness then.

          21   MR UNDERWOOD:  Thank you very much.

          22   THE ASSISTANT CORONER:  So there we are, members of the

          23       jury, if you would like to leave us for ten minutes.

          24       Thank you.

          
                                           138
 

 

 

           3   (2.49 pm)

           4                         (A short break)

           5   (3.06 pm)

           6   THE ASSISTANT CORONER:  We'll have the jury in then, please.

           7                  (In the presence of the jury)

           8   THE ASSISTANT CORONER:  Yes, then, Mr Underwood, who's the

           9       witness?

          10   MR UNDERWOOD:  Mr Clow, please.

          11   THE ASSISTANT CORONER:  Right.  We'll ask Mr Clow to come

          12       forward.

          13                     MR LUKE CLOW (affirmed)

          14   THE ASSISTANT CORONER:  Thank you very much, Mr Clow.  Come

          15       and have a seat, please.

          16   A.  Certainly.

          17   THE ASSISTANT CORONER:  Thank you.  Once you're comfortable

          18       Mr Underwood is going to ask you some questions.

          19   A.  Sure.

          20                    Questions by MR UNDERWOOD

          21   MR UNDERWOOD:  Good afternoon, Mr Clow, my name's Underwood

          22       and I'm counsel to the Inquest.  Can I ask your full

          23       names, please?

          24   A.  Luke Michael Clow.

          25   Q.  I want to ask you about events of 4 August 2011 at about


                                           139
 

 

 


           1       6.10 to 6.15 minutes in the evening.  Where were you

           2       then?

           3   A.  I was -- I'm not sure exactly -- the exact minutes of

           4       the time but I was leaving the Tottenham Hale train

           5       station and making my way back to my house which is on

           6       Bream Close, which is the other side of where the

           7       incident took place.

           8   Q.  Did you hear shots?

           9   A.  This is a difficult question for me to answer completely

          10       honestly -- completely accurately.  I had my earphones

          11       in and I'm fairly certain that I remember hearing large

          12       bangs as I was walking the stairs from the train station

          13       up towards the Ferry Lane roadway.  So I would say -- in

          14       hindsight, I put that together to be the shots.  So the

          15       answer is probably yes, although I'm aware that's not --

          16   Q.  Can you recall how many bangs you heard?

          17   A.  Pretty certain I heard more than one.  But any more

          18       accuracy on that, I'm afraid I couldn't give you.

          19   Q.  Were they close coupled or was there a gap between them?

          20   A.  I would say there was a gap, which is why I would say

          21       I had heard two, but not more than a couple of seconds

          22       apart, I wouldn't have thought.

          23   Q.  Did you hear sirens?

          24   A.  During that course of that events, yes, lots.  Whether

          25       I heard sirens at that moment, I would say no, and from


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           1       my best recollection.

           2   Q.  Did you hear shouting at about that time?

           3   A.  Once I approached the actual area, yes, there were

           4       plenty of Police Constables on the scene that were

           5       shouting to the public.  I can't say I heard shouting as

           6       I was mounting the stairs.

           7   Q.  I think you drew a sketch plan, did you, when you were

           8       interviewed --

           9   A.  That's right, I drew a little sketch.

          10   Q.  -- by the IPCC.  Can we have a look at the screen.

          11       We'll see CD2220.  Let's just run through this and

          12       enlarge it a little.  Keep the top in play.

          13           So number 1 is representing -- as we see on the

          14       plan, bottom right-hand corner -- the steps.  That's

          15       where you were when you heard the bangs, was it?

          16   A.  That's correct, yes.

          17   Q.  Number 2, which we see on the pavement towards the --

          18       pavement at the lower part here, towards the left-hand

          19       side of the plan; is that as far as you got towards the

          20       scene?

          21   A.  Yes.  That's the furthest down I went down the road.

          22   Q.  Then at number 3, to the right of that for us, you were

          23       posted back there, were you?

          24   A.  Yes, initially probably, for a period of maybe two

          25       minutes, I would think, before the police pushed us back


                                           141
 

 

 


           1       towards the train station.

           2   Q.  Then we see on the far left side of the road vehicles B

           3       and A, of which A is a police car, is it?

           4   A.  No, I believe A was not a police car.  I think that was,

           5       from my best recollection -- I've marked it as navy

           6       blue.  I think actually talking to a Police Constable

           7       later it was, in fact, silver, but it was a passenger

           8       taxi, I think.

           9   Q.  I see, all right.  There was a police car behind it, was

          10       there, at B?

          11   A.  Correct.

          12   Q.  Now, we have orientated ourselves.  What did you see?

          13   A.  Well, upon walking down the road, I'm afraid I was not

          14       in something of a daze until I got somewhere close to

          15       that first point where the Police Constable stopped me.

          16           The first thing that broke me aware was a policeman

          17       running towards me.  He was in plain clothes from my

          18       best recollection.  But I think he had a cap that

          19       signified him to be a police officer.  He was running to

          20       stop any pedestrians getting further closer to the

          21       scene.  That's where I sort of became aware of

          22       a situation occurring.

          23           I was stopped there.  I saw the police generally

          24       running around the area to try and keep people away from

          25       the area because there is the grass bank to -- as I was


                                           142
 

 

 


           1       facing the incident, on that side of the road where the

           2       cars were stopped, there is a grass bank down to where

           3       there is another road there.

           4           There were some people, I believe residents of that

           5       estate, congregating around that area and I think they

           6       were trying to keep people back from there.

           7           The first car closest to me that was parked with one

           8       wheel up on the kerb had the passenger front door open

           9       and, as far as I can recall, I can remember seeing some

          10       people around that door and some activity there.

          11           I believe much further down the road, towards the

          12       lights, there was another larger police vehicle, or

          13       possibly an ambulance, but certainly a marked emergency

          14       services vehicle that was parked there.

          15           What else did I see?  (Pause)

          16   Q.  What did you do after seeing these things?

          17   A.  My first reaction, I'm afraid, wasn't particularly

          18       helpful.  I just tried to say that I just lived the

          19       other side, could I not just walk on, was told "No, no

          20       you need to get back, please sir, please get back",

          21       which I duly did, and stood by the Tesco there.  I stood

          22       there for a couple of minutes sort of generally bemused

          23       as to what was going on, and then eventually the police

          24       pushed us further back towards the train station and

          25       I gradually made my way home from there.


                                           143
 

 

 


           1   Q.  Is that the last you saw of the scene?

           2   A.  Aside from more marked police cars arriving, I probably

           3       saw two or three police cars arriving, and definitely

           4       there was an ambulance that came and stopped in front of

           5       the silver car just before I left.  That was the last

           6       I saw of the actual scene itself.

           7   MR UNDERWOOD:  Right, thank you very much.  If you would

           8       wait there, there may be some more questions for you.

           9   THE ASSISTANT CORONER:  Yes, Mr Straw?

          10   MR STRAW:  No, thank you.

          11   THE ASSISTANT CORONER:  Mr Stern?

          12   MR STERN:  No, thank you.

          13   THE ASSISTANT CORONER:  Mr Keith?

          14   MR KEITH:  No, thank you.

          15   THE ASSISTANT CORONER:  Mr Butt?

          16   MR BUTT:  No, thank you?

          17   THE ASSISTANT CORONER:  Mr Glasson?

          18   MR GLASSON:  No, thank you.

          19   THE ASSISTANT CORONER:  Right, there are no more questions.

          20       Thank you very much for coming forward and assisting us.

          21       You are free now to go.

          22                      (The witness withdrew)

          23   MR UNDERWOOD:  That concludes the ten witnesses for today.

          24       I think we have three, possibly four for tomorrow and

          25       I will also need to tidy up the witnesses whose


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           1       statements I should have read, that I have not yet read

           2       tomorrow, but I would apprehend that's probably enough.

           3   THE ASSISTANT CORONER:  We have made good progress today and

           4       we are getting to that exciting moment whereby all the

           5       evidence is concluded.

           6   MR UNDERWOOD:  Yes.  As I say, I almost certainly will

           7       recall V59 fairly shortly.  If he's available tomorrow

           8       I'll do that tomorrow.  If not, it will be Wednesday.

           9   THE ASSISTANT CORONER:  We'll see how it goes.

          10           Well, members of the jury, thank you very much for

          11       your concentration today.  That concludes all the

          12       witnesses that are available for you.  We have made good

          13       progress today, so well done and let's all be here

          14       tomorrow morning at 10.30, please.

          18   (3.16 pm)

          19        (The Inquest adjourned until 10.30 am on Tuesday,

          20                        26 November 2013)

          21
               THE DAUGHTER OF MISS J (sworn) .......................1
          22
                   Questions by MR UNDERWOOD ........................1
          23
                   Questions by MR STRAW ............................5
          24
                   Questions by MR STERN ............................7
          25
               MISS Z (affirmed) ...................................16

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           1
                   Questions by MR UNDERWOOD .......................17
           2
                   Questions by MR STRAW ...........................21
           3
                   Questions by MR THOMAS ..........................24
           4
                   Questions by MR STERN ...........................25
           5
               MR VALENTINE MCGUIRE (sworn) ........................38
           6
                   Questions by MR UNDERWOOD .......................38
           7
                   Questions by MR STRAW ...........................44
           8
                   Questions by MR STERN ...........................45
           9
               MR KIERAN ELY O'CARROLL (affirmed) ..................47
          10
                   Questions by MR UNDERWOOD .......................47
          11
                   Questions by MR STERN ...........................55
          12
               MS GIEDRE TILINSKAITE (affirmed) ....................67
          13
                   Questions by MR UNDERWOOD .......................67
          14
               MR KIERAN ELY O'CARROLL (recalled) ..................70
          15
                   Questions by MR BUTT ............................70
          16
               MR DARREN BIGGS (affirmed) ..........................73
          17
                   Questions by MR UNDERWOOD .......................73
          18
                   Questions by MR STERN ...........................76
          19
               Housekeeping ........................................82
          20
               Video footage evidence (as per Miss .................82
          21             J's daughter's evidence)

          22   Discussion re legal submissions .....................85

          23   INTERPRETER (affirmed) .............................103

          24   MR EMIL DRZEWIECKI (sworn) .........................104

          25       Questions by MR UNDERWOOD ......................104


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           1       Questions by MR STRAW ..........................106

           2   MR NINO HAMADOUCHE (sworn) .........................107

           3       Questions by MR UNDERWOOD ......................107

           4       Questions by MR STRAW ..........................112

           5       Questions by MR STERN ..........................113

           6   MR FINBAR HANRAHAN (sworn) .........................115

           7       Questions by MR UNDERWOOD ......................115

           8       Questions by MR STRAW ..........................120

           9       Questions by MR THOMAS .........................123

          10       Questions by MR STERN ..........................125

          11       Questions by MR KEITH ..........................133

          12       Further questions by MR STRAW ..................134

          13   MR LUKE CLOW (affirmed) ............................139

          14       Questions by MR UNDERWOOD ......................139

          15

          16

          17

          18

          19

          20

          21

          22

          23

          24

          25


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