Transcript of the Hearing 1 October 2013

 

           1                                        Tuesday, 1 October 2013

           2   (10.30 am)


          13                  (In the presence of the jury)

          14   THE ASSISTANT CORONER:  Thank you very much, members of the

          15       jury.

          16           I'll ask for the witness, please.

          17                         ZZ17 (continued)

          18                   (The witness was anonymised)

          19   THE ASSISTANT CORONER:  Thank you very much then.  If you

          20       would like to be seated, you are still under the

          21       affirmation that you took yesterday.  We can have the

          22       cameras on upstairs, as I believe they now are.

          23       I apologise to you, members of the jury, and also to

          24       you, ZZ17, for not being able to go any further

          25       yesterday afternoon.  But we were able to use the time

 

 

 

 

 

 

 

 

 

 

 


                                             1
 

 

 


           1       usefully and we are now in a position to resume with the

           2       questioning that was then in mid-flow from Mr Mansfield.

           3   A.  Thank you, sir.

           4              Questions by MR MANSFIELD (continued)

           5   MR MANSFIELD:  Good morning, officer.

           6   A.  Good morning, sir.

           7   Q.  In preparation of the questions, if we can go back to

           8       the documents that you had yesterday because it's

           9       easier.

          10   A.  Yes, sir.

          11   Q.  First of all -- and the jury have this one -- it's

          12       document C9, divider 9, I think, in the jury's bundle.

          13       This is the A10 --

          14   A.  Yes, I have that one, sir, thank you.

          15   Q.  If you just open it up so you have it ready.

          16   A.  I've got it.

          17   Q.  That's fine.  The other document I was asking you to

          18       look at, just as we broke, the jury have and you have,

          19       it's tab 1, a diagram numbered 7: tab 1, 7.

          20   A.  The map, sir; is that right?

          21   Q.  The map, that's it?

          22   A.  Yes.

          23   Q.  If you have that open as well.  If you run out of space,

          24       please say.  The other document that we had yesterday,

          25       I want to just go back to it in one minute, was your


                                             2
 

 

 


           1       statement this year, quite recent.

           2   A.  Yes, I have that as well, thank you, sir.

           3   Q.  You have that as well.  We are really, at the moment, on

           4       pages 5 and 6.  The jury don't have that, so I will just

           5       pause to make sure everybody has the documents.

           6           May I make it clear that these are not questions

           7       framed by me, they are questions framed by others within

           8       a parameter which can be asked.

           9   A.  Yes, I understand, sir.

          10   Q.  They don't quite go as far as I would want, I make that

          11       clear at the moment, but I won't press further than

          12       these for the moment.

          13   A.  Yes.

          14   Q.  So I am going to read them so I don't make a mistake.

          15       Now, I'm dealing with -- sorry -- the context is this:

          16       it was concerning Burchell Road and the Trident officer

          17       ZZ37, who had parked up on the left-hand side, as you go

          18       down, just before Sophia Road, and how he came to be

          19       there.  Those were the initial questions.

          20   A.  Yes, sir.

          21   Q.  This is the question I ask you this morning, and you can

          22       look at the intelligence that's on A10's sheet.

          23   A.  Yes.

          24   Q.  When you received intelligence around 5.20 --

          25   A.  Yes.


                                             3
 

 

 


           1   Q.  -- from A10, was there any indication as to the intended

           2       destination of the minicab, other than that it was in

           3       the Vicarage Road area in Leyton?

           4   A.  None at all, sir.

           5   Q.  Right.  Now, I have a further question on that.

           6   A.  Yes.

           7   Q.  Did A10 say -- if you look at the A10 information that

           8       we have on the A10 sheet, C9, it was that the minicab

           9       would be travelling with Duggan, obviously, imminently

          10       to Vicarage Road; do you see that?  That's on the A10

          11       document.

          12   A.  Yes.

          13   Q.  Yes.  There's a reason for asking, because the question

          14       was framed for me, including the words "was in the

          15       Vicarage Road area".  Just pausing, if you wouldn't

          16       mind.

          17           If you look at your statement recently about these

          18       matters, the bottom of page 5 and the top of page 6,

          19       where you deal with this --

          20   A.  Yes.

          21   Q.  -- I will read it as a whole so you've got it, it's

          22       right at the bottom of page 5.  It's coming up on the

          23       screen, the jury can see it, it's the bottom four lines

          24       there:

          25           "At approximately 1720 I was at the Quicksilver


                                             4
 

 

 


           1       patrol base in Haringey ..."

           2           Then you indicate the others, ZZ37, ZZ75 and ZZ46:

           3           "... when I received a telephone call from A10 with

           4       intelligence which indicated that Mark Duggan was

           5       imminently taking a minicab to meet Kevin

           6       Hutchinson-Foster to take possession of a firearm.  No

           7       details of the minicab were known, but the destination

           8       was believed to be close to Vicarage Road in Leyton."

           9   A.  Yes.

          10   Q.  Now, there are reasons for asking you what exactly were

          11       you told by A10 about Vicarage Road or Vicarage Road

          12       area or Leyton; do you follow the questions?

          13   A.  I follow the question, sir.  I'm not sure how much more

          14       I can say than I've already said but I didn't have any

          15       more specific information about the final destination at

          16       5.20 than that it would be in the Vicarage Road area.

          17       I'm being very careful how I answer that, sir.

          18   Q.  I'm sorry to pause again, because I'm obviously not

          19       privy to the discussions that lead to this --

          20   A.  I understand, sir, yes.

          21   Q.  -- question and I don't want to compromise you; you do

          22       understand that?

          23   A.  Yes, I do, sir.  I'm trying my best to answer, sir, but

          24       there's a line that I cannot step over, I'm afraid.

          25   Q.  I appreciate that.  So may I put a marker down here --


                                             5
 

 

 


           1       I am not going to spend more time on it at the moment --

           2       that I would like to know what was said, if it can be

           3       more specific than "Vicarage Road area" or "close to

           4       Vicarage Road" or "Vicarage Road".  The reason -- again,

           5       so you can see the context for these questions, could

           6       you just go back to the plan, please?

           7   A.  Yes, sir.

           8   Q.  Plan number 7, in tab 1.  The jury haven't heard it yet

           9       but -- and I don't want to pre-empt it, but it appears

          10       to be this.  I have already indicated that ZZ37, who you

          11       had said "Go over to Vicarage Road" because he knew

          12       it --

          13   A.  Yes.

          14   Q.  -- he parks up, I have already indicated, just before

          15       Sophia Road as you're coming down in the one-way system.

          16           Now, the other two that went at the same time but in

          17       one vehicle, that's ZZ46 and ZZ75 --

          18   A.  Yes, sir.

          19   Q.  -- the jury are going to hear from them --

          20   A.  Yes.

          21   Q.  -- if you cast your eye down that plan, they park up in

          22       Farmer Road which is just on the edge of the plan; do

          23       you see that, further south?

          24   A.  Yes, I do, yes.

          25   Q.  It's, in fact, just off the next main junction which


                                             6
 

 

 


           1       leads into Park Road?

           2   A.  Yes.

           3   Q.  Did you know that that's where they were?

           4   A.  I don't believe I did, sir, no.

           5   Q.  All right.  I am not asking -- if you don't remember or

           6       don't believe you did, I'll leave it there.  So those

           7       two are there.  In addition to that, some other officers

           8       who you deployed, in other words Trident officers --

           9   A.  Yes.

          10   Q.  -- had also gone to this area, hadn't they?

          11   A.  Yes.  A little after the other officers, yes.

          12   Q.  I'll give you a couple of numbers for the moment, I'm

          13       sorry about so many acronyms: ZZ50 and ZZ63.

          14   A.  Yes, that's right, sir, yes.

          15   Q.  Now, they, we will hear, apparently, if you cast your

          16       eye above Capworth Street on the plan, they are parked

          17       up, by around the same time -- in other words somewhere

          18       around 5.30/5.35 --

          19   A.  Yes, sir.

          20   Q.  -- they are in -- I think, they are not quite sure which

          21       the roads were -- they are either in Whitney Road or the

          22       next one over; do you see that?

          23   A.  Whitney or Melbourne, sir.

          24   Q.  That's right.  Did you know that they were there?

          25   A.  Not precisely, sir, I sent them to that general area.


                                             7
 

 

 


           1       I do not think I knew exactly where they were.

           2   Q.  The question I want to ask you is, and you may not know

           3       the answer: you will see, if you look at all those

           4       officers, they very carefully have surrounded the area

           5       of Burchell Road, two to the north, two to the south and

           6       one in the middle of Vicarage; do you see that?

           7   A.  I see what you're saying, sir.  It seems to me that

           8       Vicarage Road, they have pretty much surrounded

           9       certainly the one-way section, as I understand it, of

          10       Vicarage Road, which is, as I understand it, not all of

          11       Vicarage Road but a large part of it.

          12   Q.  Well, I am not quibbling over whether it's a large or

          13       small part of it.  It's a part of it but the road goes

          14       off south quite a way to the south-east, if you look at

          15       this particular plan, in other words we don't see the

          16       full extent of Vicarage Road on here, do we?

          17   A.  No, I don't believe it goes much further but we don't

          18       see the end of it, sir.

          19   Q.  The jury have a bigger plan so -- but you can't help as

          20       to that?

          21           So, therefore, one other question, again one framed

          22       for me, so I'll read it, save for one passage in it

          23       because I don't need it at the moment: was there any

          24       further intelligence, that's after 5.20, received from

          25       A10 -- I'm leaving out a bit in parenthesis -- as to the


                                             8
 

 

 


           1       destination of the minicab before ZZ37 saw the minicab

           2       in Vicarage Road at whatever time that was?

           3   A.  No, none at all, sir.

           4   Q.  None at all.  I have a further question but I cannot ask

           5       it at the moment but I am just putting a marker down as

           6       to that aspect of it.

           7           Now, I want to, if I may, just stand back for

           8       a moment.  I'm dealing with the 4th.

           9   A.  Yes, sir.

          10   Q.  Before I get back to some of the deployments that day,

          11       I want to ask you, if you wouldn't mind, for your help

          12       about the general situation on the 4th.

          13           First of all, according to your most recent data,

          14       you actually come on duty on the morning of the 4th; is

          15       that probably right?

          16   A.  Certainly earlier in the 4th, sir.

          17   Q.  All right, I'm not quibbling about time.  So earlier on

          18       the 4th.  Now, if no more information or intelligence

          19       had come through in relation to the

          20       Duggan/Hutchinson-Foster pick up, collection, if nothing

          21       more had come through, what was the plan for the evening

          22       operation?

          23   A.  Sir, if no more information at all had come in --

          24   Q.  Yes.  On the -- because all the A10 -- we have just

          25       looked at the sheet.  All the A10 material that you've


                                             9
 

 

 


           1       got -- the specific highly reliable intelligence --

           2       concerns Hutchinson-Foster having a gun or guns -- I'll

           3       come back to that --

           4   A.  Yes.

           5   Q.  -- and passing it to Duggan.  So, if nothing more came

           6       through during the 4th, whenever you came on duty, what

           7       was the plan for the operation -- the preplanned

           8       operation -- for the evening of the 4th?  What were you

           9       going to do --

          10   A.  Sir, the plan would have been to start at 6.00 pm again,

          11       as the previous day.  In fact, the reason that I was

          12       effectively on duty earlier was because some other

          13       intelligence relating to somebody completely unrelated,

          14       or not one of the six subjects we were dealing with,

          15       came in regarding him potentially having a firearm that

          16       day, and the reason I was on duty earlier than 6 o'clock

          17       was in relation to that intelligence.  But in relation

          18       to the Duggan/Hutchinson-Foster intelligence the plan

          19       would have stayed, because all the intelligence

          20       indicated that nothing could happen with this until

          21       later in the evening anyway.

          22   Q.  I follow that.  I have to come back to it.  But what

          23       were you planning to do with the operation that night if

          24       there had been no more information about

          25       Duggan/Hutchinson-Foster?


                                            10
 

 

 


           1   A.  Well, sir, the plan would have been to brief again at

           2       6 o'clock and really to review what the intelligence

           3       picture was at that time.

           4   Q.  Yes, and if there was nothing more about

           5       Duggan/Hutchinson-Foster what were you going to do?  The

           6       reason I'm asking you is this is a nightclub parties

           7       operation, I'm putting it shortly.

           8   A.  Yes.

           9   Q.  So what were you planning to do on the 4th if nothing

          10       more had come through: go to the vicinity of a club or

          11       a party or target somebody?  How was it going to work on

          12       the 4th?

          13   A.  Sir, if I can try and explain: I was receiving, every

          14       day, all the time, intelligence from A10 around a number

          15       of subjects, these six and others.

          16   Q.  Yes.

          17   A.  This sort of snippet, if you like, about Duggan and

          18       Hutchinson-Foster has obviously been drawn out, but

          19       there was a lot of intelligence about other people,

          20       about other things that Mr Duggan may have been up to,

          21       about what all of these other people were up to, and it

          22       really was a question of wait and see what the

          23       intelligence is at that time, and then in consultation

          24       with the Tactical Firearms Commander, to respond to that

          25       intelligence.  There wasn't a plan in advance because


                                            11
 

 

 


           1       the intelligence changes so much and so quickly.

           2   Q.  I understand that.  The general picture is that you're

           3       fast response, as fast as you can be, you're flexible?

           4   A.  Flexible, sir, yes.

           5   Q.  Flexible, fast response to intelligence.  Assuming that

           6       it's credible and reliable --

           7   A.  Yes.

           8   Q.  -- you operate on that basis?

           9   A.  I think that's fair, sir, yes.

          10   Q.  That's fair.  Well now, during the day of the 4th,

          11       before we get to the briefing at 6 o'clock --

          12   A.  Yes.

          13   Q.  -- where intelligence comes through during the day,

          14       which is as reliable as the material coming through from

          15       A10, that Hutchinson-Foster's got a gun he's going to

          16       give or be collected by Duggan, a meet --

          17   A.  Sorry, sir, you've lost me there.

          18   Q.  If during the day of the 4th, before 6 o'clock, you get

          19       information that there's going to be a meet --

          20   A.  Yes.

          21   Q.  -- of some kind or another --

          22   A.  Yes.

          23   Q.  -- who's in charge before 6 o'clock, when the briefing

          24       takes place?

          25   A.  Sir, I would be receiving the intelligence.  As it


                                            12
 

 

 


           1       happens, in this case the intelligence came through

           2       fairly shortly before 6 o'clock and I was able to speak

           3       to Z51.

           4   Q.  So the question is: when intelligence comes through

           5       before 6 o'clock -- that's when everybody is supposed to

           6       be at Wood Green --

           7   A.  Yes.

           8   Q.  -- before night operation is 6 o'clock in the evening

           9       until 2 o'clock in the morning.

          10   A.  Yes.

          11   Q.  But obviously everything is unpredictable, isn't it?

          12   A.  Yes, sir.  What I was going to go on to say, sir, sorry

          13       was that, in this case, I was able to speak to Z51 who

          14       was already on his way to brief.  If it had come through

          15       some hours earlier, that's the kind of situation we deal

          16       with all the time in Trident when we haven't got one of

          17       these operations planned.  So on a daily basis I receive

          18       that kind of intelligence and we seek to respond to that

          19       as a spontaneous incident.

          20   Q.  Right.

          21   A.  So in that case, I would be receiving the intelligence

          22       and assessing whether it required some kind of response.

          23       If it needed a firearms response I would need to find

          24       a Tactical Firearms Commander, which may well be Z51, if

          25       he were not available it may be somebody else.


                                            13
 

 

 


           1   Q.  Right.  The decision that you take is you are not in

           2       charge but you have the intelligence which you can then

           3       allocate to whoever can take the decision as to what to

           4       do about it?

           5   A.  Yes, I would say I'm in charge, sir, up to the point

           6       that it's clear that some kind of armed operation, be it

           7       spontaneous or preplanned, is required, and then I need

           8       a Tactical Firearms Commander to be in charge of that

           9       operation.  But in terms of assessing the intelligence,

          10       prioritising it, that's my job.

          11   Q.  Right.  Now, I want you to deal with actually what

          12       happened on this day, now we know what the intelligence

          13       was.  Would you please have -- it's in the jury

          14       bundle -- you have it -- it's at C5.  It's a map of part

          15       of London.

          16   A.  This one, sir?  (Indicates)

          17   Q.  That's right.  In the patrol base at Wood Green --

          18   A.  Yes.

          19   Q.  -- did you have a map like this available to you?

          20   A.  I had a map book, sir.

          21   Q.  So, what, a sort of A-to-Z, do you mean --

          22   A.  Yes.

          23   Q.  -- or a Metropolitan Police set of maps?

          24   A.  A map book like you would buy in the shops, sir.

          25   Q.  Yes, fine.  I want to ask you a series of questions,


                                            14
 

 

 


           1       because you're getting the intelligence but it's coming

           2       through before 6 o'clock, it's coming through at 5.20.

           3   A.  Yes.

           4   Q.  As we've seen, the intelligence mentions Duggan and

           5       an imminent collection by him of a firearm, right?

           6   A.  Yes, sir.

           7   Q.  Now, that's a significant piece of the best intelligence

           8       you can have, isn't it?

           9   A.  Yes, sir.

          10   Q.  You agreed yesterday that what you want to do is get the

          11       gun?

          12   A.  Yes, absolutely.

          13   Q.  Right.  When it came through, did you know -- you've

          14       already indicated you didn't know where Vicarage Road

          15       was.

          16   A.  That's right, sir.

          17   Q.  So on this plan, the fact that it's marked up, you

          18       didn't actually know that precise road?

          19   A.  No, sir, I was told it was in the Leyton area.  I have

          20       an idea where Leyton is but I am not very familiar with

          21       that area.

          22   Q.  Did you look it up?

          23   A.  Yes, sir, at some point I did.

          24   Q.  No, did you look it up when the intelligence came

          25       through?


                                            15
 

 

 


           1   A.  I looked it up fairly shortly, I could not say exactly

           2       when, but fairly shortly after --

           3   Q.  We're dealing with -- I think the police vernacular is

           4       we are dealing with "fast time"; is that right?

           5   A.  Yes, I think that's fair, sir, yes.

           6   Q.  That's fair.  So you would need to know pretty sharpish

           7       where the area is that this imminent collection is going

           8       to take place.

           9   A.  Yes.

          10   Q.  You would need to know that.

          11   A.  Yes, sir.

          12   Q.  Yes.  So we can rely on the fact that you would have

          13       known within a few minutes where Vicarage Road was,

          14       because you would have looked it up; can we rely on

          15       that?

          16   A.  I think a few minutes is fair, sir, I cannot say exactly

          17       when, but yes, a few minutes.

          18   Q.  Now, at that point, so we're somewhere after 5.20 in the

          19       afternoon --

          20   A.  Yes.

          21   Q.  -- what you know is a minicab carrying Duggan is on its

          22       way there.

          23   A.  That's not quite right, sir, I don't think.  I knew that

          24       Mark Duggan was planning to take a cab imminently.

          25   Q.  Yes, of course it could change.  He might not take it.


                                            16
 

 

 


           1   A.  Yes, sorry sir, I thought you said that he was in the

           2       cab.

           3   Q.  No, sorry.  That was the intention, he was getting in it

           4       imminently -- I'm just reading off the A10 material

           5       which you have in front?

           6   A.  I may have misheard you, sir.

           7   Q.  No, it's all right, don't worry.  You are not given

           8       an address for him but you did know addresses for

           9       Duggan, didn't you?

          10   A.  Yes.

          11   Q.  Now, if you cast your eye down the plan, you will see on

          12       these that there are boxes indicating a time: 17.15,

          13       Hutchinson-Foster was in Vicarage Road --

          14   A.  Okay.

          15   Q.  -- and 17.15, that's when Mark Duggan took a minicab

          16       from, in fact, Micawber Court.

          17   A.  Yes, sir.

          18   Q.  There's no secret about that.  If you cast your eye

          19       further down, you see Leman Street; do you see that?

          20   A.  Yes, sir.

          21   Q.  I want to ask you about that.  Did you know when the

          22       CO19 officers had come on duty that day?

          23   A.  No, sir.  I knew that, for a briefing at 6 o'clock, they

          24       would be on duty some time before that but I couldn't

          25       tell you exactly when.


                                            17
 

 

 


           1   Q.  So you had had no communication from them that they had

           2       come on at 4 o'clock, and we can see it -- I do not ask

           3       you to look at the timeline but the jury can see it as

           4       the first entry on the timeline -- they are on duty at

           5       4 o'clock --

           6   A.  Yes, sir.

           7   Q.  -- at Leman Street, you knew that as a place?

           8   A.  I knew Leman Street, sir.  I had not spoken to them that

           9       day but it would be entirely normal for them to be there

          10       a couple of hours or so before.

          11   Q.  What normally happens when they come on a couple of

          12       hours before is they have a briefing of their own, don't

          13       they --

          14   A.  Yes, sir.

          15   Q.  -- and they get whatever weaponry they are taking ready

          16       to take?

          17   A.  I imagine so, yes.

          18   Q.  It's standard procedure, isn't it?

          19   A.  Yes.

          20   Q.  Did you know that they had, CO19 team -- I'll leave out

          21       Z51 for the moment -- the CO19 team; did you know when

          22       they left Leman Street?

          23   A.  No, sir.

          24   Q.  Did you make contact yourself with the team leader?

          25   A.  Yes, I did.  By that stage, I was aware they'd left.


                                            18
 

 

 


           1   Q.  Yes.  Did you know where they were?

           2   A.  They were en route, sir.

           3   Q.  Where were they?

           4   A.  I don't know, sir, I know they were -- they said to me

           5       they could be at Quicksilver fairly shortly, I didn't

           6       ask them where they were.

           7   Q.  In fact they could have been at any of these

           8       destinations on this map fairly quickly, couldn't they?

           9   A.  They could be anywhere quickly, sir, yes.

          10   Q.  Yes, because that's the whole point of the exercise,

          11       isn't it?

          12   A.  Well, yes sir, they are obviously advanced drivers in

          13       police cars with blue lights and sirens.  They could get

          14       anywhere in that sort of range fairly quickly, yes.

          15   Q.  Yes.  You make contact -- V59 is the team leader; is

          16       that right?

          17   A.  I think that's right.

          18   Q.  You talked to him at some point, you don't know where

          19       they are.

          20   A.  He may have told me, sir, I can't remember now.

          21   Q.  Do you ever remember saying to yourself "Where are

          22       they?" and getting the map out and discover they are

          23       actually not far away, for example, from Kingsland Road

          24       going north; you didn't do that?

          25   A.  I don't think so, sir, no.


                                            19
 

 

 


           1   Q.  No, all right.  Now, in addition to the team itself, did

           2       you know where the Tactical Firearms Commander, Z51,

           3       was?

           4   A.  Not until I spoke to him, sir.  I spoke to him, I do not

           5       think I found out -- again, I had no reason to ask

           6       people exactly where they were.  I simply told them what

           7       was happening and to see how quickly they could get

           8       together at Quicksilver.

           9   Q.  Yes, I want to come to this.

          10   A.  Yes.  Again, I would have a idea of what part of London

          11       he may be coming from.

          12   Q.  You know they are coming from Leman Street?

          13   A.  The firearms team, sir, not the Silver Commander.

          14   Q.  You know the firearms team is coming from Leman Street.

          15   A.  Yes.

          16   Q.  I think you said yesterday that when you spoke for the

          17       first time to Z51 he was buying a sandwich.

          18   A.  I think so, sir, yes.

          19   Q.  Did he say that or you guessed it or what?

          20   A.  I think he must have said it, sir.

          21   Q.  Must have said it.  Did you say "Where on earth are

          22       you?"

          23   MR BUTT:  I'm sorry to rise.  There is sensitivity on my

          24       client's part about revealing the location of where he

          25       was.  I'm sure that is not going to be revealed.


                                            20
 

 

 


           1   THE ASSISTANT CORONER:  Where he was buying the sandwich?

           2   MR BUTT:  It's not where he buys his sandwiches, it's where

           3       he lives.

           4   MR MANSFIELD:  I'm not going to ask that.

           5   MR BUTT:  I thought we were heading towards that area.

           6   THE ASSISTANT CORONER:  Are we?  Please continue,

           7       Mr Mansfield.  If you feel there's any sensitivities

           8       about this you'll obviously let us know as you did

           9       yesterday.

          10   MR MANSFIELD:  It's really only whether you asked him on the

          11       phone, you know, "Where are you at the moment?"

          12       something like that.

          13   A.  Sir, perhaps I can answer it like this.  I was aware he

          14       was coming from where he lives, I know what part -- what

          15       area of London that's in.  I think he indicated to me

          16       that he wasn't far from there buying a sandwich and then

          17       he was going to be coming.  But he was still some

          18       distance away, if that answers your question.

          19   Q.  Well, not exactly.  I don't want to know where he lives.

          20       You see, what I'm coming to is this: if you look at the

          21       plan, now you have had a chance, the actual position, it

          22       seems -- leave out Z51 in case there's some sensitivity

          23       about where exactly he's buying his sandwich -- CO19 had

          24       left at 5.15, you see it's on the plan --

          25   A.  Okay, sir.


                                            21
 

 

 


           1   Q.  -- so that the call to you is at 5.20, it's only five

           2       minutes later.

           3   A.  Okay.

           4   Q.  So the CO19 officers, by 5.20, won't have got -- they

           5       will have got some way towards Wood Green but, you know,

           6       they are more south than north; do you follow?

           7   A.  It sounds logical, sir, yes.

           8   Q.  I'm trying to be fair about exactly where they were.

           9   A.  Yes.

          10   Q.  I just want to ask you this single question: did you, at

          11       about 5.20, or 5.25, consider saying to Z51, in whatever

          12       language you use, "Get over to the Vicarage Road area"?

          13   A.  Sir, I was considering all the options all the time, if

          14       you see what I mean.  That wouldn't seem to me to be

          15       a particularly sensible thing to do.

          16   Q.  I want to go through it with you.

          17   A.  Yes.

          18   Q.  You see, that's why I was wanting to know who's in

          19       charge.  You are in charge of the intelligence.

          20   A.  Yes.

          21   Q.  Of course, people cannot do much unless they know what

          22       the intelligence is.

          23   A.  Yes.

          24   Q.  Did you tell Z51 about Vicarage Road?

          25   A.  I'm not sure, sir.


                                            22
 

 

 


           1   Q.  You don't have a record, obviously, we've been through

           2       your records --

           3   A.  Yes.

           4   Q.  -- now you are having to rely on memory --

           5   A.  Yes.

           6   Q.  -- as to what you said.

           7   A.  I told him what the intelligence was, I'm pretty sure

           8       I would have said Leyton, whether I would have mentioned

           9       a particular road that would not have meant much to him,

          10       I don't know.

          11   Q.  Of course it wouldn't but they do have means of

          12       discovering places in their vehicles, don't they?

          13   A.  A map, you mean, sir?

          14   Q.  Well, a basic map, but I think these days possibly sat

          15       nav?

          16   A.  Possibly, sir, I don't know.

          17   Q.  Do you not know what they've got in their cars?

          18   A.  I don't know what Z51 has in his car, sir.  But I'm sure

          19       he would have a map or satellite device or some way he

          20       could find where Vicarage Road was.

          21   Q.  I suggest to you that of prime importance at this point

          22       is this nugget of intelligence about Duggan intending

          23       imminently to collect a firearm.  That's a nugget, isn't

          24       it?

          25   A.  Yes, sir, but if I can put it in context: I knew that


                                            23
 

 

 


           1       much.  I didn't know at that stage precisely where

           2       Mr Duggan was going to go.  I didn't know precisely when

           3       he was going to meet Mr Hutchinson-Foster.  I didn't

           4       know what vehicle he was in.  There are a lot of things

           5       we didn't know at that stage.  We weren't in a position

           6       to respond with a firearms team at that stage.

           7   Q.  I'm sorry, I'm going to pursue this a little bit if you

           8       don't mind.

           9   A.  No.

          10   Q.  You knew enough to get surveillance officers from your

          11       team, Trident team, placed all around Vicarage Road and

          12       Burchell Road; you managed that all right, didn't you?

          13   A.  Around the Vicarage Road area, yes, sir.

          14   Q.  Yes, the area.  Now, the procedure -- I want to ask you

          15       in relation to CO19 -- is that if you are having to

          16       respond spontaneously to information, they are used to

          17       that, aren't they?

          18   A.  Yes, sir.

          19   Q.  The way they do it, I suggest to you, is that if they

          20       haven't managed to get to a briefing in Wood Green, they

          21       can have a dynamic briefing as they move, can't they --

          22   A.  To a certain extent, sir, yes.

          23   Q.  -- over the radios?

          24   A.  Yes.

          25   Q.  There are special channels for them.


                                            24
 

 

 


           1   A.  I can talk to them on the radio, yes, sir.

           2   Q.  They have channels between themselves, don't they?

           3   A.  Yes.

           4   Q.  So if Z51, not with them but buying a sandwich, wants to

           5       get from wherever he is to where they are, the common

           6       practice is to organise an RV or a rendez-vous point

           7       near Vicarage Road, isn't it?

           8   A.  I wouldn't want them too close to Vicarage Road because,

           9       as I say, I didn't know exactly where things were going

          10       to happen.

          11   Q.  Of course you didn't at that point --

          12   A.  Yes.

          13   Q.  -- anymore than you did for the surveillance officers

          14       that went.  The usual practice would be a rendez-vous

          15       point, not in Vicarage Road, not in Burchell Road, but

          16       somewhere nearby.

          17   A.  Yes, sir.

          18   Q.  Four vehicles, because the vehicles that are in fact in

          19       the convoy of the team, the CO19 officers, are the three

          20       the jury have seen that do the hard stop, and a control

          21       vehicle.

          22   A.  That's right, yes.

          23   Q.  V59, the team leader, he's in the control vehicle.

          24   A.  He is, sir, yes.

          25   Q.  Z51, may be -- I don't want to know what vehicle he's


                                            25
 

 

 


           1       in -- but he is in another vehicle.

           2   A.  Yes.

           3   Q.  It couldn't be simpler, could it, for you to suggest, if

           4       you cannot direct them, to Z51 rendez-vous near

           5       Vicarage Road, not in Vicarage Road but near

           6       Vicarage Road; that's a simple request, isn't it?

           7   A.  Sir, it could have been done but, as I say, I was

           8       already at Quicksilver, some of the surveillance team

           9       were already at Quicksilver, this was a place that we

          10       had arranged to meet.  It does not seem to me

          11       an unreasonable place.

          12   Q.  But it's --

          13   A.  It's easy with hindsight now to look back and say "Could

          14       we have found somewhere slightly nearer?" maybe we

          15       could, maybe we couldn't, but it seems to me to be

          16       a reasonable place to carry on with the plan we already

          17       had for everybody to meet at Quicksilver.

          18   Q.  The problem, I suggest to you, is that you were locked

          19       into a plan you already had, which was a rostered plan

          20       of 6.00 in the evening until 2.00 in the morning and

          21       when something else came up you failed to reconsider

          22       sending the officers who were already geared up across

          23       to Vicarage Road area ready -- and I'm going to suggest

          24       to you that they could have got there at about the same

          25       time as surveillance, around 5.30/5.35, easily got


                                            26
 

 

 


           1       there -- in order to be prepared for what I called the

           2       "running commentary" on what was going on.

           3           Now, did you suggest that to Z51?

           4   A.  Sorry, did I suggest what, sir?

           5   Q.  Going to the Vicarage Road area.

           6   A.  No.  Like I said, sir, it wouldn't seem to me to be the

           7       sensible thing to do.  I think we had a short discussion

           8       "Have we got time to get officers to Quicksilver?"

           9       "Yes, we think we probably have".  But I would not

          10       suggest to him to send officers to Vicarage Road

          11       because --

          12   Q.  Because what?

          13   A.  Because it did not seem to me --

          14   Q.  Instead, you have officers going all the way to

          15       Wood Green and leaving Wood Green at about the time the

          16       gun is being collected; is that a sensible approach?

          17   A.  Yes, I think so, sir.

          18   Q.  You do?  Because what I want to suggest to you: the

          19       result of the way you did it -- one does not want to be

          20       clever with hindsight, I am just dealing with -- you

          21       have dealt with many of these situations, haven't you --

          22   A.  Yes, sir.

          23   Q.  -- all right -- is that CO19 were having -- I'm going to

          24       call it "catch up", you know what I mean, they were

          25       playing catch up for the rest of the afternoon, trying


                                            27
 

 

 


           1       to find where the convoy was and catch it up eventually

           2       in Ferry Lane; do you follow what I'm putting to you?

           3   A.  I do, sir, but that's what's supposed to happen and I do

           4       not see what would have happened differently on your

           5       account.

           6   Q.  Right.  What would have happened differently, I suggest

           7       to you, with minimising the risk of the use or recourse

           8       to lethal force -- that's the question --

           9   A.  I understand that sir.

          10   Q.  -- is if CO19 plus Z51 had got to the Vicarage Road

          11       area --

          12   A.  Yes.

          13   Q.  -- and had got the kind of intelligence that you were

          14       getting, because they had surveillance in the road and

          15       you had A10 intelligence telling you when the car

          16       arrived, yes --

          17   A.  Yes, sir.

          18   Q.  -- and you had ZZ37 telling you he had seen the car?

          19   A.  Yes, sir.

          20   Q.  You had intelligence that the car had stopped or

          21       turned -- I leave that to one side -- yes?

          22   A.  Yes, sir.

          23   Q.  You knew that it was the -- the minutes were ticking by

          24       when the car wasn't moving for about four minutes,

          25       that's the minicab.


                                            28
 

 

 


           1   A.  If you say so, sir, okay, yes.

           2   Q.  Well, either it's moved slightly into Burchell Road or

           3       it's stayed in Vicarage Road.

           4   A.  Yes.

           5   Q.  That would have enabled your CO19 officers, who had been

           6       briefed at 4 o'clock --

           7   A.  Yes.

           8   Q.  They had had a briefing the previous day as well, hadn't

           9       they?

          10   A.  Yes.

          11   Q.  You were there?

          12   A.  Yes, sir.

          13   Q.  These were pretty well briefed officers, weren't they?

          14   A.  Yes, sir.

          15   Q.  Thank you.

          16   A.  But obviously not about the specifics of what was

          17       happening in Vicarage Road or Burchell Road, sir.

          18   Q.  Officer, they are constantly, aren't they, having to

          19       deal with roads and places they've never been to before

          20       because you have suddenly got intelligence about it;

          21       that's a commonplace situation, isn't it?

          22   A.  Sorry, sir, I am not talking about the layout of the

          23       roads, I'm saying that the -- as you say, it was fast

          24       time.  What was developing in Vicarage Road and Burchell

          25       Road, obviously they could not have been briefed about


                                            29
 

 

 


           1       that in advance.

           2   Q.  No, I appreciate that.  They are responding, as you are,

           3       to intelligence that's coming through.  What I want to

           4       suggest to you is that this was a good area for an armed

           5       containment where there weren't loads of pedestrians,

           6       cyclists, buses, underground stations, shopping

           7       precincts; do you follow?

           8   A.  I follow, sir.  If that's your characterisation of the

           9       stop in Ferry Lane, I don't agree with it at all.

          10   Q.  All right.  I am characterising what happened --

          11   A.  Sorry, if you are casting whether Vicarage Road would

          12       have been a better place to do the stop than Ferry Lane,

          13       then I don't agree at all, sir.

          14   Q.  I'm going to suggest to you that yes, it would have

          15       been.  Just look at the plan for a moment since you are

          16       proffering that view.  The plan is tab 1, number 7.

          17   A.  Yes, I have that, sir.

          18   Q.  If the firearms officers, just for example, had been

          19       where some of the surveillance were -- I am not

          20       suggesting they sit on top of them, but they are in

          21       Farmer Road -- there were four cars, there's the control

          22       car, which normally would just be in control; is that

          23       right?

          24   A.  Yes, sir.

          25   Q.  It's not necessarily going to be used as part of


                                            30
 

 

 


           1       an intervention or does it get used?

           2   A.  It would depend on the circumstances.

           3   Q.  It could get used?

           4   A.  Potentially.

           5   Q.  Right.  Given the timings that were available and the

           6       intelligence that you had, because although it's not on

           7       the A10, you knew, just before 6 o'clock that the

           8       minicab was in Vicarage Road --

           9   A.  Yes.

          10   Q.  -- and you knew, just after 6 o'clock, that a gun had

          11       been picked up --

          12   A.  Yes, I believe that was the case, sir, yes.

          13   Q.  -- you would have been able to convey that to the CO19

          14       officers if, for example, at least one of their cars was

          15       parked up in Farmer Road.

          16   A.  I would have been able to tell them that, sir, yes.

          17   Q.  So that's one car.  Of course, if another car by this

          18       time had moved into a position to the north of Burchell

          19       Road, say, for example in Capworth Street -- do you see

          20       Capworth?

          21   A.  I see Capworth Street, sir.

          22   Q.  That's the second car.  Then we still have a third car

          23       which could be placed at an intervening road, but not

          24       obviously, for example it could be in Byron Road or in

          25       Sophia Road.


                                            31
 

 

 


           1   A.  Sorry, I apologise, I am not trained in firearms tactics

           2       I'm not sure how much I can say about whether that would

           3       be the way they would conduct a stop like that.

           4   Q.  I'm going through it in a practical way because you are

           5       so adamant that where it happened in Ferry Lane was

           6       a much better place.

           7   A.  I understand, sir, but if you are going to ask me where

           8       particular firearms vehicles -- whether they would have

           9       split up in that way, it's not something I've ever seen

          10       done, perhaps the firearms officers could answer that

          11       for you, I don't know.

          12   Q.  I certainly have to ask them.  What I am going to

          13       suggest, so it's very clear from this stage onwards, one

          14       possible intercept place, because you need -- one of the

          15       advantages is to hit something early -- do you follow

          16       what I'm saying -- while people are unaware.

          17   A.  No, sir.

          18   Q.  You don't agree?

          19   A.  I don't necessarily agree with that, no.

          20   Q.  You don't necessarily agree?

          21   A.  Sir, what I would say is that, in my experience, at --

          22       certainly at the point of any kind of deal or

          23       transaction going down, that's when people are at their

          24       most alert, if you see what I mean.

          25   Q.  I am not suggesting --


                                            32
 

 

 


           1   A.  Whether it's a gun being handed over or a drug deal,

           2       it's at that point that people are looking about for

           3       other criminals, the police, whatever it may be.

           4   Q.  If they are inside a house?

           5   A.  Potentially not, sir.

           6   Q.  One of the things --

           7   A.  Again, somebody who's just picked up a gun, I would

           8       think, would perhaps be more alert.

           9   Q.  One appreciates that they might be.

          10   A.  Yes.

          11   Q.  If they are inside the house -- that's why I want to

          12       know whether Burchell Road was known and when it was

          13       known, all right, for the purposes of a firearms

          14       operation.

          15   A.  Yes.

          16   Q.  If they are inside the house where it's handed over and

          17       it's not handed over in the street, that's actually

          18       really a prime situation for a firearms containment,

          19       isn't it?

          20   A.  Possibly, sir, possibly not.

          21   Q.  Right.  I cannot ask you more about the deployment of

          22       firearms and an interception but, just so that it's

          23       clear, I'm suggesting that the intercept -- one of the

          24       points of an intercept could have been as the car comes

          25       down the one-way system in Vicarage Road and gets to


                                            33
 

 

 


           1       Park Road/Farmer Road, where it has to turn -- or may

           2       turn one of several ways, obviously, but at that

           3       junction; do you follow what I'm putting to you?

           4   A.  I follow what you are putting, sir.  I think, perhaps,

           5       when you are coming down to those specifics of

           6       a firearms interception, that question would be better

           7       addressed to some of the CO19 officers.

           8           What I would say is what I saw of the place where

           9       the stop was conducted in Ferry Lane, that struck me as

          10       as good a place you are going to find in London on

          11       a Thursday evening to put in an interception as I have

          12       ever seen.

          13   Q.  I see.  I am going to leave the question of stops and

          14       where is the best place to the firearms officers.

          15   A.  Yes, sir.

          16   Q.  I am not pursuing about that, you have seen the film.

          17       These are all issues about what happened on the 4th --

          18   A.  Yes.

          19   Q.  -- and I suggest to you what another possibility was, in

          20       relation to the intelligence that you had.

          21           Now, can we go back a stage to the 3rd?

          22   A.  Yes, sir.

          23   Q.  For these purposes, I would like you again to have the

          24       A10 intelligence in front of you.

          25   A.  Yes, I have that.


                                            34
 

 

 


           1   Q.  So the jury have it, it's C9.  Would you also have that

           2       statement in front of you, the recent one.  We are going

           3       back to an earlier page.  The jury don't have this, it's

           4       page 4.  But also, I would like you to have, and

           5       I gather they are available now but weren't yesterday,

           6       hard copies of the briefing at 6 o'clock on the 3rd.

           7   THE ASSISTANT CORONER:  Yes.  I think these are documents

           8       which have been referred to quite a lot on the screen

           9       and we now have hard copies so the jury can put them in

          10       their bundle.  (Handed)

          11   MR MANSFIELD:  C12, please.

          12   THE ASSISTANT CORONER:  Right, yes.  Thank you.  All right,

          13       members of the jury, if you put this in your jury bundle

          14       behind a divider at C12.

          15   MR MANSFIELD:  I want to, in fact, go to your statement

          16       first.

          17   A.  Yes, sir.

          18   Q.  What you did in this recent statement is to sort of do

          19       a resume.  I will make clear that what I wanted to ask

          20       you about is Kevin Hutchinson-Foster.

          21   A.  Yes.

          22   Q.  That's one of the key elements of the A10 intelligence.

          23       The paragraph begins, if we could have it on screen so

          24       the jury can see what I'm reading from, page 4,

          25       page 780, and it's the paragraph under the heading


                                            35
 

 

 


           1       "Build up to the 4 August"; do you have that?

           2   A.  I have that, sir, yes.

           3   Q.  "In the days leading up to 4 August 2011, intelligence

           4       from SOCA identified that somebody was looking after

           5       more than one firearm on behalf of Mark Duggan and that

           6       Duggan intended to take possession of one of these

           7       firearms."

           8           I am going to pause there.

           9   A.  Yes.

          10   Q.  Now, would you look at the A10 intelligence and tell us

          11       where you got that from?

          12   A.  I got it from A10, sir, but I'll have a look through and

          13       see what -- (Pause)

          14           Sir, I cannot see it in that document.  Obviously

          15       A10 has created his wording as carefully as he can

          16       around what he's allowed to say and I have created mine

          17       as carefully as I can.

          18   Q.  Yes.  We had this yesterday and I'm just looking for, if

          19       I may put it this way, the truth of what was known.

          20   A.  I understand, sir.  All of the intelligence that I refer

          21       to from there is from A10.

          22   Q.  That's why I'm asking you.  Can we just go on in your

          23       statement:

          24           "As a result of careful research ..."

          25           I'll come back to that:


                                            36
 

 

 


           1           "... the person believed responsible for storing the

           2       firearms ..."

           3           Do you see that?

           4   A.  Yes.

           5   Q.  "... was identified as Kevin Hutchinson-Foster."

           6   A.  Yes.

           7   Q.  Where is there any indication in the A10 intelligence

           8       that Kevin Hutchinson-Foster was storing firearms,

           9       plural, for Mark Duggan?

          10   A.  Sir, you have obviously had time to read it more

          11       carefully than I do.  I will take it from you that

          12       perhaps it doesn't say that.

          13   Q.  I do not want you to -- you have plenty of time to read

          14       it.  It doesn't say that.

          15   A.  I'll take your word for that.

          16   Q.  All right.  You are not claiming better intelligence

          17       than A10, are you?

          18   A.  Not at all, sir, no.

          19   Q.  Just so you see how it fits in, if you just turn to the

          20       briefing -- the jury have just got it now, at C12 --

          21       there's one page -- it's CD0276 at the bottom, so it's

          22       the third page in -- if I can put it to you, this is

          23       another expression of much the same.  If you look about

          24       halfway down:

          25           "There's nothing specific to say ..."


                                            37
 

 

 


           1           Do you see that?

           2   A.  Yes, sir.

           3   Q.  It's just above the reference to Kevin

           4       Hutchinson-Foster:

           5           "There's nothing specific to say that any of them

           6       keep firearms at their home addresses or that they're

           7       armed today.  There is intelligence to suggest that

           8       Mark Duggan is currently in possession or control of

           9       about 3 firearms and that he is looking to take

          10       possession of a firearm perhaps this evening, he's been

          11       trying to do it for a few days."

          12   A.  Yes.

          13   Q.  "There's some more photos coming round, these are black

          14       and white ones which is a guy called Kevin

          15       Hutchinson-Foster.  Intelligence would suggest that he's

          16       got control of the firearms and from 9 o'clock this

          17       evening [the 3rd] there may well be a plan for Duggan to

          18       somehow get those firearms from Hutchinson.  Hopefully

          19       at some stage we'll have more information about where

          20       that's going to happen, how it's going to happen but the

          21       intelligence at the moment is that Hutchinson has got

          22       control of at least 1 firearm which he's going to pass

          23       to Mark Duggan possibly at some point this evening."

          24           So you see all of it in the statement and in the

          25       briefing is expressed in the plural.


                                            38
 

 

 


           1   A.  Yes.

           2   Q.  Essentially, the implication of what you're telling the

           3       officers in the briefing and in your statement, for the

           4       reader, is that Hutchinson-Foster is basically

           5       a quartermaster, if you know what I mean, for Duggan --

           6   A.  I do.

           7   Q.  -- storing guns for Duggan.

           8   A.  I hadn't thought of it that way, sir, yes, but you could

           9       put it that way.

          10   Q.  I could, yes.  Which makes him a prime target, doesn't

          11       it --

          12   A.  Yes, sir.

          13   Q.  -- which means that either on the 3rd or the 2nd,

          14       because you knew his name the day before, in fact, you

          15       would want to do quite a bit of research on this man,

          16       wouldn't you?

          17   A.  A fair bit, sir, yes.

          18   Q.  Who did it?

          19   A.  I think it was mostly done -- I'm sure there was some

          20       essentially done by SOCA -- from my team, ZZ46.

          21   Q.  ZZ46.  You see, what was available on the 3rd,

          22       I suggest, and the 2nd, had you done it -- and I want to

          23       know whether you know the results and if you don't

          24       obviously say so -- well, I can ask it generally or

          25       compendiously to start with: did you know the results of


                                            39
 

 

 


           1       the trawl of information on Kevin Hutchinson-Foster?

           2   A.  Broadly speaking, yes, sir.

           3   Q.  So we'll go through it in stages.  You obviously knew

           4       his name.  You knew he had a criminal record?

           5   A.  Yes.

           6   Q.  You knew he had been released from prison quite

           7       recently?

           8   A.  Yes.

           9   Q.  You knew that, as a result, having been released a bit

          10       early, he was basically under the supervision of the

          11       probation service?

          12   A.  I believe so, sir, yes.

          13   Q.  I want to go carefully here.  Did you know that?  Did

          14       anybody find out that that's what the situation was?

          15   A.  I think so, sir, I'm trying to remember but I think so.

          16   Q.  You think so.  All right, and that he was in a hostel --

          17   A.  I think so.

          18   Q.  -- which has an address.

          19   A.  Yes, sir.

          20   Q.  Yes, and I don't know whether you call it Crimint or

          21       Met-tel, or whatever you call it, there would be a file

          22       on Hutchinson-Foster, wouldn't there?

          23   A.  There would be a number of references to him on

          24       different systems, sir, yes.

          25   Q.  Different systems, but they are not difficult to call up


                                            40
 

 

 


           1       once you get onto the trail?

           2   A.  No.

           3   Q.  In addition to, therefore, an address and recent release

           4       and a criminal record, those files, however you access

           5       them in different ways, will reveal associates, won't

           6       they?

           7   A.  Yes, sir, if those associates are known, obviously.

           8   Q.  Yes.  Do you know what associates were dug up for Kevin

           9       Hutchinson-Foster?

          10   A.  I can't recall specifically now, I'm afraid, sir,

          11       I probably would have known some at the time.

          12   Q.  Right.  A car for Kevin Hutchinson-Foster?

          13   A.  I believe there was a car found that had some links to

          14       him.  Again, I cannot remember the specific details.

          15   Q.  We know now that he went to this address at Vicarage

          16       Road -- Burchell Road more precisely -- much earlier in

          17       the day of the 4th in a car; do you now know that?

          18   A.  I don't, sir, no.

          19   Q.  You don't know that even now that that's what happened?

          20   A.  Not really, sir, no.

          21   Q.  Right.  But you think there's something about a car

          22       coming out of the intelligence on Hutchinson-Foster.

          23       How about a phone?

          24   A.  I believe there's a chance that a phone number, perhaps

          25       a phone number that he had used in the past, would have


                                            41
 

 

 


           1       been found, sir.  Whether it was a current one, I don't

           2       know.

           3   Q.  These are all rather important enquiries to be made

           4       about him, for the reason I'm just about to come to.

           5       But do you remember now whether it was a landline number

           6       or a mobile phone?

           7   A.  Not specifically, sir, no.

           8   Q.  Now, the question I want to put to you, it's the same as

           9       I put to you on the 4th, but it's a different -- I think

          10       you probably realise what the question is.  The question

          11       I want to ask you is: on the 3rd, did you consider --

          12       consider -- suggesting/recommending that armed directed

          13       surveillance take place on the quartermaster for Mark

          14       Duggan?

          15   A.  Sir, I think as I said to you before, I was considering

          16       what intelligence I had all the time and what would be

          17       the best way to respond to that.  It wasn't a question

          18       of me sitting down and at one point considering this but

          19       I'm sure it's something I would have given thought to.

          20       But all of the direct intelligence that I was receiving,

          21       and likely to receive, was directly in relation to Mark

          22       Duggan.  Any intelligence I was getting, if I can put it

          23       this way, in relation to Hutchinson-Foster, was only

          24       indirectly through the intelligence I had around Mark

          25       Duggan.


                                            42
 

 

 


           1   Q.  Well, I'm going to ask the question again: did you

           2       consider mounting a directed surveillance armed

           3       operation -- armed surveillance officers -- for

           4       Hutchinson-Foster?

           5   A.  Sir, I think the best way I can put it is what I said.

           6       I was considering all the time what the best thing to do

           7       was --

           8   Q.  I want to go through it.  Did you consider that and, if

           9       so, where is that recorded, who did you talk to, and so

          10       forth?  So did you consider it as an option or not?

          11   A.  Yes, I think I probably did, sir, yes.

          12   Q.  You probably did?  Will we find any records of where you

          13       probably considered it as an option?

          14   A.  Not written down, sir, no.

          15   Q.  Who did you talk to about it on the 3rd as a probable

          16       option?

          17   A.  On the 3rd to Z51, the Tactical Firearms Commander.  We

          18       had a conversation about what the intelligence was.

          19   Q.  Yes.

          20   A.  We had several conversations about what the intelligence

          21       was and the best way to respond to that intelligence.

          22   Q.  Yes.  When you discussed the best way, did you in fact

          23       discuss, as an option, the surveillance on

          24       Hutchinson-Foster?

          25   A.  I think, sir, it's probably something that would have


                                            43
 

 

 


           1       occurred but, as I said, in my experience that wouldn't

           2       be the way to go because, were we to follow

           3       Hutchinson-Foster, we would be following him blind, if

           4       you like.  We wouldn't know what it is he was doing.

           5       I wasn't receiving any intelligence about Kevin

           6       Hutchinson-Foster other than that that I received --

           7   Q.  You were receiving --

           8   A.  -- about Mark Duggan.

           9   Q.  The A10 -- we only have to look at the sheet.

          10       50 per cent of what you were receiving over the days

          11       leading up to the 4th -- 50 per cent of it related to

          12       Hutchinson-Foster, didn't it?

          13   A.  50 per cent of what's recorded there, sir.

          14   Q.  Well, that's the most reliable information you can get,

          15       isn't it?

          16   A.  Yes, sir.  But obviously the intelligence that's been

          17       sought for this Inquest is the intelligence relating to

          18       what Mark Duggan and Kevin Hutchinson-Foster were doing.

          19   Q.  The Inquest is looking at a broader picture.

          20   A.  Yes.

          21   Q.  I just want to ask you whether, in relation to the 3rd,

          22       you were really locked into Mark Duggan and that's how

          23       you approached this case?

          24   A.  Not locked in, sir, no.  As I say, the intelligence that

          25       I had, and intelligence I was likely to receive, was


                                            44
 

 

 


           1       about Mark Duggan.  Had we followed Kevin

           2       Hutchinson-Foster, I would have no way of knowing, for

           3       example, whether he had a gun.

           4   Q.  No, of course not.

           5   A.  So it would be fairly pointless to follow him.

           6   Q.  Is that your considered answer, that it would be

           7       pointless to follow Kevin Hutchinson-Foster, the very

           8       man who's looking after guns not at his home address but

           9       some other addresses in Leyton?  It would be pointless

          10       to follow him in case he went to Leyton, would it?

          11   A.  Sir, even if we followed him to Leyton, I still wouldn't

          12       know what he was doing.  I still wouldn't know whether

          13       he had a gun until such time as I received intelligence

          14       about Mark Duggan taking the gun from him.

          15   Q.  That is precisely what you got on the 4th but you

          16       weren't there; do you follow?  You got that information

          17       on the 4th, that he, Duggan, was intending to go and

          18       collect a gun from Hutchinson-Foster.  The very thing he

          19       had been trying to do for the previous days -- and

          20       I will just finish the lead up to it.

          21           If you had followed him, let's say, on an operation

          22       starting at 12.00 noon on the 4th, what would have

          23       happened is you would have followed him all the way to

          24       Burchell Road and you would have known that he was in

          25       that address, you could have it staked out with


                                            45
 

 

 


           1       surveillance officers, not in the road but nearby; do

           2       you follow the point?

           3   A.  Sir, I follow the point.  Firstly, all the intelligence

           4       we had was that any handover was going to be late into

           5       the evening.  There was no intelligence reason to start

           6       earlier in the day.  In fact, on 4 August -- the

           7       intelligence, as I said earlier, that I was receiving on

           8       4 August, was about a seventh individual.  Had I had

           9       surveillance officers available during the day on

          10       7 (sic) August, I imagine I would have had

          11       a conversation with the TFC and we would have

          12       concentrated on that individual, because the

          13       intelligence picture about all six or seven of these

          14       individuals was changing on such a fast basis that this

          15       intelligence about Mr Hutchinson-Foster was just one

          16       piece of the intelligence that I was receiving about

          17       a number of people, and there was no reason for me to

          18       think that we would follow him during the day on the

          19       4th.  Even if we had done, I wouldn't have known, as we

          20       have agreed, where the gun was until it was in Mark

          21       Duggan's hands.

          22   Q.  You knew what you were being told was that it was in the

          23       Leyton area --

          24   A.  Yes, sir.

          25   Q.  -- thought to be, and then you got more precise.  Just


                                            46
 

 

 


           1       in terms of resources, you've got Trident officers

           2       available to do surveillance.

           3   A.  Yes, sir.

           4   Q.  Roughly how many?

           5   A.  On duty on my team, sir, sorry?

           6   Q.  Yes, roughly.

           7   A.  Maybe eight, nine, I'm not sure.

           8   Q.  Eight or nine?

           9   A.  Something like that, I'm not sure.

          10   THE ASSISTANT CORONER:  On this day.

          11   A.  Yes, sir.  I could check the number but something of

          12       that order.

          13   MR MANSFIELD:  We only need a rough estimate.

          14   A.  Sorry, when I say that, that's eight or nine Trident

          15       officers on duty, not all of those would be trained to

          16       carry out surveillance and obviously none of them are

          17       armed.

          18   Q.  No.  So you might have them on surveillance duty

          19       unarmed, as you did do this day.

          20   A.  For a short period, sir.  That would not be something

          21       I would plan to do if I had the alternative.

          22   Q.  Of course not.  This is responding quickly to

          23       intelligence.

          24   A.  Yes.  That's what the Trident officers are really there

          25       for, sir, to respond in the interim until the armed


                                            47
 

 

 


           1       surveillance officers are in a position to take over.

           2   Q.  There's another serious crime directorate division that

           3       deals with surveillance, armed surveillance.

           4   A.  Yes, SCD11, yes.

           5   Q.  How many of those officers would have been available to

           6       you that day, that's the 4th or some time on the 3rd

           7       even?

           8   A.  Sir, I'm not sure I follow the question, sorry.

           9   Q.  If it's a question of resources --

          10   A.  Yes.

          11   Q.  -- and I don't know whether you are saying that -- how

          12       many armed specialist surveillance officers could have

          13       been available to you on the 4th had you mounted

          14       an armed directed surveillance operation?

          15   A.  Sir, I could have put in a bid to the surveillance

          16       department and asked for another armed surveillance

          17       team.

          18   Q.  How many did you have already?

          19   A.  One team.

          20   Q.  How many?

          21   A.  Again, I would have to check the numbers.

          22   Q.  Roughly.

          23   A.  11 or 12 people.

          24   Q.  11 or 12; do they go paired up?

          25   A.  Sir, I do not want to go too much into the specifics,


                                            48
 

 

 


           1       I think sometimes yes, sometimes no.

           2   Q.  All right.  So it's a number of vehicles available?

           3   A.  Yes.

           4   Q.  If you want more armed surveillance you don't have to do

           5       a massive amount of paperwork if you are responding

           6       quickly, do you?

           7   A.  No, sir.  It's not really about paperwork.

           8   Q.  No, it isn't, right.  So really coming back to the

           9       3rd --

          10   A.  Yes.

          11   Q.  -- is this a fair summary: there's no record anywhere of

          12       any consideration given by you or Z51 to mounting

          13       an armed surveillance operation on Hutchinson-Foster, is

          14       there?

          15   A.  No, sir, no.

          16   Q.  Now, just one other adjunct to this: as you yourself

          17       have said, what people intend to do isn't always quite

          18       what they do do.

          19   A.  No.

          20   Q.  So you have to be able to, as it were, anticipate; is

          21       that fair?

          22   A.  Yes, sir.

          23   Q.  What has happened here is the inability of people to

          24       meet and pass over a gun over the previous days.  That's

          25       not to say, of course, that Kevin Hutchinson-Foster


                                            49
 

 

 


           1       hadn't got the gun, over these days, available to him.

           2       So do you appreciate that?

           3   A.  Sorry, sir, there was a noise that distracted me.

           4   Q.  There was a noise, all right.  Because people's

           5       behaviour isn't always as predictable as you would like

           6       it to be, you have to be ready and anticipate something

           7       different happening.

           8   A.  Yes.

           9   Q.  As the collection hadn't happened on the previous

          10       evenings, there's just the possibility that it might

          11       happen during the day.

          12   A.  Sir, the intelligence picture that I had at that time

          13       was that, on the preceding days, it had not been

          14       possible to carry out this handover of the firearm until

          15       after 9 o'clock in the evening and I had no reason to

          16       think that anything would be different on the 4th.

          17   Q.  Where did you get 9 o'clock from?

          18   A.  From A10, sir.

          19   Q.  Did you?

          20   A.  Yes.

          21   Q.  Just look through the page.

          22   A.  Yes.

          23   Q.  Is it an anticipated time by you because you were told

          24       mid-evening and you wrote 9 o'clock down or were you

          25       told 9 o'clock?


                                            50
 

 

 


           1   A.  I think I was told 9 o'clock, sir, yes.

           2   Q.  You were told 9 o'clock?

           3   A.  Yes.

           4   Q.  You've got the summary there and certainly that's not

           5       what we've been told that A10 ever said to you.  So you

           6       were told 9 o'clock in the evening.  Well then, we are

           7       still on the 3rd for a moment.

           8   A.  Yes.

           9   Q.  What was the point of this armed surveillance operation

          10       that you did mount on the 3rd?

          11   A.  Sorry, I'm not sure I follow the question.

          12   Q.  The intelligence coming through, you say, was that it

          13       wasn't going to happen until after 9 o'clock in the

          14       evening.

          15   A.  Yes.

          16   Q.  In fact, you mounted an operation that evening.

          17   A.  Yes.

          18   Q.  Whose decision was it?

          19   A.  Do you mean the general operation, sir, or specifically

          20       to put the surveillance team around Mark Duggan?

          21   Q.  Specifically around Mark Duggan on the 3rd in the

          22       evening.

          23   A.  In charge during the evening of the 3rd was Z51, the

          24       Tactical Firearms Commander.

          25   Q.  Whose decision was it?


                                            51
 

 

 


           1   A.  His, sir.

           2   Q.  His?  So Z51, he knows the same intelligence as you,

           3       does he?

           4   A.  Yes.

           5   Q.  Would you look at the A10 intelligence sheet again, C9.

           6   A.  Yes.

           7   Q.  That's why I asked yesterday carefully about when you

           8       received information.

           9   A.  Yes, sir.

          10   Q.  As you received a bit of information, under the heading

          11       "3 August", which is at the end of the paragraph:

          12           "I subsequently received ..."

          13           That's A10:

          14           "... intelligence that indicated that Mark Duggan

          15       would not be in a position to collect the firearm as he

          16       was attending a family barbeque."

          17           When did you receive that?

          18   A.  Sorry, was that "when" sir?

          19   Q.  Yes, when on the 3rd?

          20   A.  I am not precisely sure.

          21   Q.  Because I want to ask you, if you can help us, why on

          22       earth a surveillance operation went out at 8.30, we know

          23       that from other documents --

          24   A.  Yes.

          25   Q.  -- to watch Mark Duggan at a barbecue?


                                            52
 

 

 


           1   A.  I don't know what time I received that intelligence,

           2       sir, I'm sorry, I can't help you there.

           3   Q.  In fact, what appears to have happened, I don't know

           4       whether you can help, is that he leaves the premises --

           5       in fact it's his mother's -- he leaves --

           6   A.  I don't believe it was his mother's, sir.

           7   Q.  Okay, some other address.  He leaves the address --

           8       sorry, I may have made a mistake -- he leaves

           9       an address, gets in a car --

          10   A.  Yes.

          11   Q.  -- and he's lost within minutes.

          12   A.  Yes, sir.

          13   Q.  So the decision to do that on that day was Z51's.  Did

          14       it occur to you, I don't know, some time that evening,

          15       that it might be useful, since you've lost Duggan, there

          16       has not been any collection, let's bring the briefing

          17       forward the next day in case things begin to accelerate

          18       and don't let's just stick to the 6 o'clock; did that

          19       occur to you?

          20   A.  Again, sir, I think I'm considering things all the time

          21       but I had no reason to think anything -- if I had

          22       thought there was a likelihood of something happening,

          23       as it transpired it did on the 4th, any earlier than

          24       6 o'clock, then yes, I would have thought to do that.

          25       I had no reason to think that, and this operation, as


                                            53
 

 

 


           1       you know, was set up around six individuals potentially

           2       going to nightclubs and things later on, and there was

           3       the prospect of that intelligence as well.

           4           So there was no reason to bring it forward any

           5       earlier and that may have meant that we weren't in

           6       a position to cover something that happened later in the

           7       evening.

           8   Q.  Well, is the problem resources or something?  Is that

           9       why you don't tend bring -- in case you cannot cover

          10       anything else; is that the problem?

          11   A.  Sir, if I could run this kind of operation 24/7 every

          12       day, then that would be an ideal world.  I cannot do

          13       that, sir.  Ultimately, yes, there comes a point, if we

          14       have specific intelligence that says there's a reason

          15       that we need to seek more resources, then we can do that

          16       but there is obviously a limited number of very

          17       specialist resources that a lot of departments are

          18       trying to use.  I cannot just say "Can I have another

          19       team to come on earlier in the morning, I have no reason

          20       to think anything's going to happen but just in case?"

          21   Q.  The actual point I am making is -- I have dealt with the

          22       armed surveillance, I am dealing with just bring the

          23       briefing the next day forward, not 6 o'clock, make it

          24       earlier so we are all on the boil, as it were, he having

          25       not collected it, he having been keen to collect from


                                            54
 

 

 


           1       Hutchinson-Foster, it's a meet that's going to happen

           2       it's not runners, it's Hutchinson-Foster/Duggan.  So

           3       bring the thing forward to, I don't know, 2 o'clock in

           4       the afternoon; would that have been a problem for you?

           5   A.  I am not sure there was intelligence to say it was

           6       definitely going to be Hutchinson-Foster/Duggan, but

           7       obviously at any point if we bring that team on earlier,

           8       the earlier you bring them on, if I bring them on at

           9       midday, I don't necessarily -- we don't necessarily want

          10       that team then working through until 4 or 5 or 6 o'clock

          11       in the morning.

          12   Q.  No, I quite agree.

          13   A.  So it's a balancing act.  If there was a reason to bring

          14       them on earlier we would look to bring them on earlier.

          15       There wasn't a reason to bring them on earlier that day.

          16       If I had known in advance I was going to get that call

          17       at 5.20, of course I would have sought to bring them on

          18       but I didn't know that.

          19   Q.  You never know when intelligence is going to come

          20       through, do you?

          21   A.  No, sir, but it could be earlier it could be later.  So

          22       we try to strike the best balance we can on the

          23       information we have at the time.

          24   Q.  What I suggest, if you just go back to the A10

          25       intelligence --


                                            55
 

 

 


           1   A.  Yes.

           2   Q.  -- it's sitting there in front of you --

           3   A.  Yes.

           4   Q.  -- the A10 intelligence, good as it is, is telling you

           5       that the collection of a firearm is going to be done

           6       between Hutchinson-Foster himself and Duggan himself.

           7   A.  Sorry, where is that in the document, sir?

           8   Q.  Just read through it again if you wouldn't mind.

           9       (Pause)

          10           Once you have -- have you had a chance to read it?

          11   A.  Not yet, sir.  (Pause)

          12           Can you direct me to a particular paragraph?

          13   Q.  I certainly can.  I will pick one:

          14           "On 2 August I received intelligence that Kevin

          15       Hutchinson-Foster would not be in London in the evening

          16       so Mark Duggan would not be able to meet with him to

          17       collect the firearm."

          18   A.  Yes.

          19   Q.  That's the thrust of this intelligence, isn't it?

          20   A.  On the 2nd, sir.

          21   Q.  Yes.  I don't want to go through it all again, but

          22       essentially, by the 3rd, he still wished to collect the

          23       firearm from Kevin Hutchinson-Foster -- whom he now

          24       believed to be, and so on; you see that?

          25   A.  Bear with me, sir, sorry.  (Pause)


                                            56
 

 

 


           1           Sorry, you've lost me.

           2   THE ASSISTANT CORONER:  Start at the second paragraph, at

           3       the top there.  We heard that the background information

           4       was that the firearms was stored:

           5           "... at the premises of an unidentified female and,

           6       due to [her] absence at work each day, he would not be

           7       able to gain entry to the premises to retrieve a firearm

           8       until she returned from work ..."

           9           That was the basic pattern that you were operating

          10       to?

          11   A.  Yes, sir.

          12   MR MANSFIELD:  Then in the paragraph -- I'm obliged, sir --

          13       in the paragraph headed the 3rd -- just read it again,

          14       because I want to suggest to you that you have just

          15       overlooked what I suggest is the most important bit:

          16           "On [the 3rd] I received further intelligence that

          17       Mark Duggan still wished to collect the firearm from the

          18       male ... now believed to be Kevin Hutchinson-Foster.

          19       There was still insufficient intelligence to identify

          20       where the firearm was being stored beyond the premises

          21       of a female associate probably in the Leyton area.  The

          22       intelligence indicated that Kevin Hutchinson-Foster

          23       intended to travel out of London later that evening.

          24       I subsequently received intelligence that indicated that

          25       Mark Duggan would not be in a position to collect the


                                            57
 

 

 


           1       firearm as he was attending a family barbecue."

           2           So it goes on.

           3           So the thrust of this prime intelligence, I suggest

           4       to you, was that a firearm was going to be, as it were,

           5       conveyed between Mr Hutchinson-Foster himself and

           6       Mr Duggan himself and that it didn't happen if either of

           7       them were inconvenienced because they were out of London

           8       or doing other things; that's the thrust of it, isn't

           9       it?

          10   A.  Sir, I would agree that certainly the thrust of the

          11       intelligence was that Mark Duggan personally wanted to

          12       take possession of the firearm.  I would agree that

          13       there was a good likelihood that Mr Hutchinson-Foster

          14       would do that personally, but that may not have been the

          15       case.

          16   Q.  Of course not.  But that's enough to mount surveillance

          17       on Hutchinson-Foster, isn't it?

          18   A.  I don't see the point, sir, I'm sorry.

          19   MR MANSFIELD:  Thank you very much.

          20                      Questions by MR THOMAS

          21   MR THOMAS:  Sir, I just look at the clock, I don't know

          22       whether you wanted to have the comfort break now before

          23       I continue or not?

          24   THE ASSISTANT CORONER:  Well, let's start hearing from you

          25       and then we'll see how discomforted we are.


                                            58
 

 

 


           1   MR THOMAS:  Morning, ZZ17.

           2   A.  Good morning, sir.

           3   Q.  My name's Mr Thomas and I represent the loved ones of

           4       Mark Duggan.

           5   A.  Yes, I understand, sir.

           6   Q.  Can I just take you to some of the evidence that you

           7       gave yesterday afternoon?

           8   A.  Yes, sir.

           9   Q.  It's touching a little bit of the evidence that you gave

          10       this morning.

          11   A.  Yes.

          12   Q.  I'm looking at the evidence, for those who wish to

          13       follow, in yesterday's transcript at page 54 line 24.

          14       I am going to read it to you because I appreciate you do

          15       not have it in front of you?

          16   A.  Okay, sir.

          17   Q.  In fact these were questions that you were asked about

          18       the receiving of intelligence, okay --

          19   A.  Okay, sir.

          20   Q.  -- and the reliability of the intelligence?  You made it

          21       absolutely clear yesterday that this intelligence that

          22       you were receiving was very reliable intelligence, and

          23       I think you described it as being B2.

          24   A.  Yes, sir.

          25   Q.  But then you said this:


                                            59
 

 

 


           1           "Answer: Sir, if I could just say on that: the

           2       intelligence at the time I receive it, I would say, is

           3       reliable, however the people the intelligence is about

           4       aren't always as reliable as the intelligence, if you

           5       see what I mean."

           6   A.  Yes.

           7   Q.  Do you remember saying that?

           8   A.  Yes, I do, sir, yes.

           9   Q.  It was put to you this:

          10           "Question: They don't always do what the

          11       intelligence say they might be doing.

          12           "Answer: Yes.  Even if the intelligence were

          13       reliable, they don't always do it."

          14           Yes?

          15   A.  Yes.

          16   Q.  When you approach your planning of the operation --

          17   A.  Yes.

          18   Q.  -- that is something you have to take into account, that

          19       you might have reliable intelligence, but the subjects,

          20       the subject matters of your intelligence, might not

          21       always do what they say; you've got to factor that into

          22       your plans, agreed?

          23   A.  Yes, it's very difficult, sir, but we try and be as

          24       flexible as we can to account for that, but obviously it

          25       makes it difficult.


                                            60
 

 

 


           1   Q.  I appreciate it might be difficult, but that's not my

           2       question.  My question is: you've got to factor that

           3       into your plans; do you agree or disagree?

           4   A.  I agree that in an ideal world that's what we try to do,

           5       sir.

           6   Q.  All right.  I know we don't live in an ideal world --

           7   A.  We have to base it on the intelligence that we're

           8       receiving but, bearing in mind that, as reliable as that

           9       intelligence may be --

          10   Q.  I do not want to dance round on the head of a pin.  Let

          11       me ask you direct.

          12   A.  Yes, sir.

          13   Q.  On this occasion, bearing in mind you have just told us

          14       that the -- or despite the fact that the intelligence is

          15       reliable, but the subject matters don't always do as

          16       they say, let me ask you direct: did you factor that

          17       into your plans, yes or no?

          18   A.  As well as I could, sir, yes.

          19   Q.  Thank you.  Let me move on.  Now, you've got to take it

          20       on board, it cannot be ignored, in fact you would agree,

          21       would you not, ZZ17, inflexibility would be foolish,

          22       wouldn't it?

          23   A.  Sorry, sir, say that again?

          24   Q.  You would agree, having a plan that was inflexible,

          25       would be foolish, wouldn't it?


                                            61
 

 

 


           1   A.  Yes.  As I've said, sir, we try to be as flexible as we

           2       can.

           3   Q.  All right.  Let me just take you back a little bit.

           4       I don't want to deal with 4 August.  I want to go back

           5       a little bit beyond 4 August because you were involved

           6       at an earlier stage in looking at mounting

           7       a surveillance operation on Mark Duggan on 22 June; do

           8       you remember that?

           9   A.  I do.  I do, sir, yes.

          10   Q.  Would I be right in thinking -- and we heard from

          11       Mr Foote in relation to this -- that historically what

          12       was believed about the subjects that you were following,

          13       who were seeking to take possession of firearms, was

          14       that the exchange was thought to be taking place in

          15       nightclubs, parties and things like that, correct?

          16   A.  That was a particular problem, yes.

          17   Q.  That was a particular problem.  In fact, that was the

          18       historic context that Mr Foote explained to us.

          19   A.  Okay, sir.

          20   Q.  I would be right in thinking that, on 22 June, it was

          21       understood that Mr Duggan was seeking to take possession

          22       of firearms on that occasion --

          23   A.  Yes, sir.

          24   Q.  -- and it was later on in the day -- you didn't know the

          25       time, did you?


                                            62
 

 

 


           1   A.  No, sir.

           2   Q.  No.  It's got to be looked at in the context that this

           3       was, you know, these gangs, taking possession of

           4       firearms, in nightclubs, parties, that sort of thing, in

           5       the evening, yes?

           6   A.  Sorry, sir, I didn't quite follow the question.

           7   Q.  I'll break it down.  Forgive me, the question was too

           8       long.  On 22 June --

           9   A.  Yes.

          10   Q.  -- you didn't have the specifics about the time in which

          11       Mr Duggan was going to take possession of firearms.

          12   A.  That's fair to say, yes.

          13   Q.  But the context was that these gangs were going to be

          14       taking possession in the context of parties, nightclubs.

          15       In other words, the likelihood is that it was going to

          16       be in the evening.

          17   A.  Sir, the background context of this particular problem

          18       we've talked about is there was a problem with

          19       nightclubs.  As I recall, the intelligence on 22 June

          20       was not in relation to nightclubs, it was a different

          21       matter.

          22   Q.  But it wasn't specific.  You had no idea when, correct?

          23   A.  I think that's fair to say, yes.

          24   Q.  Now, you told us yesterday that -- I think this was in

          25       answer either to a question from Mr Underwood or


                                            63
 

 

 


           1       a question from the learned Coroner -- in terms of

           2       trying to plan, you would have liked to have had three

           3       to four hours in terms of the planning, yes?

           4   A.  Something like that, sir, yes.

           5   Q.  Just help me with this: on 22 June, I'm going to

           6       suggest, a similar situation, what time did you have

           7       your briefing, with you and your team?

           8   A.  I would have to check, sir.  I think --

           9   Q.  Will you take it from me that you had your briefing at

          10       2.25 in the afternoon?

          11   A.  That sounds about right, sir, yes.

          12   Q.  That would be on an occasion where you had no specifics

          13       about timings --

          14   A.  Yes.

          15   Q.  -- but you have this historical context.

          16   A.  Sir, there was a historical context about clubs but, as

          17       I say, the intelligence on 22 June was not -- if I can

          18       say this much -- it was not about Mark Duggan -- it was

          19       nothing to do with nightclubs, if I can put it that way,

          20       sir.

          21   Q.  All right.  Now, you had your briefing on 4 -- sorry,

          22       you had your briefing on 3 August --

          23   A.  Yes.

          24   Q.  -- at 6 o'clock.

          25   A.  Yes, that's right, sir.


                                            64
 

 

 


           1   Q.  I think you just told Mr Mansfield that certainly the

           2       intelligence that you had was that this gun exchange was

           3       going to take place at about 9 o'clock.

           4   A.  After 9 o'clock, sir.

           5   Q.  Well, from 9 o'clock.

           6   A.  From 9 o'clock, yes.

           7   Q.  If that was right, why did you only give yourself three

           8       hours, bearing in mind the evidence you told us

           9       yesterday, that ideally you would need about four hours

          10       in terms of, you know, properly preparing; why did you

          11       only give yourself three hours?

          12   A.  Sir, I think what I was saying was about three or four

          13       hours, starting from scratch for some new piece of

          14       information.  In this case, we had set up some

          15       preplanned information to deal with exactly this.  We

          16       had the intelligence in place, we had the resources in

          17       place to deal -- not this particular piece of

          18       information, but to deal with somebody seeking to take

          19       possession of a firearm that evening, if you see what

          20       I mean.

          21   Q.  Perhaps the jury understand what you're saying.  Let me

          22       ask you this: you see, I'm going to suggest to you the

          23       following, see if you agree or disagree with the

          24       following propositions.

          25   A.  Yes, sir.


                                            65
 

 

 


           1   Q.  Firstly, subjects are not always reliable, so you cannot

           2       rely on what they say for the reasons you have already

           3       explained, agreed?

           4   A.  I agree they are not always reliable, sir.  We have to

           5       go with the best intelligence we have.

           6   Q.  Secondly, the second proposition: the intelligence that

           7       you had on 2 and 3 August, that Mark Duggan wanted to

           8       obtain the firearm from Kevin Hutchinson-Foster in the

           9       evening --

          10   A.  Yes.

          11   Q.  -- for those two days, for whatever reasons, that meet

          12       had not taken place and you knew that.

          13   A.  Yes, sir.

          14   Q.  Thirdly, you knew, by the 4th, that Kevin

          15       Hutchinson-Foster and Mark Duggan still wanted to meet.

          16   A.  Sorry, when was that that I knew that, sir?

          17   Q.  By the 4th, by 4 August.

          18   A.  Yes, sir, potentially, yes.

          19   Q.  Fifthly, despite that, you had not reviewed whether or

          20       not that meet, because it hadn't taken place two days

          21       previously, might have been brought forward.

          22   A.  Sir, as I said, we have to base our decisions on the

          23       best intelligence we have, and I had no intelligence to

          24       suggest that it had been brought forward.

          25   Q.  Well, the intelligence that you had by 4 August, was


                                            66
 

 

 


           1       there any repetition that the meeting was going to take

           2       place at 9 o'clock?

           3   A.  Sir, the intelligence in A10's document, if I could

           4       refer you to that here, says that the firearm was

           5       stored:

           6           "... at the premises of an unidentified female and,

           7       due to the female's absence at work each day he would

           8       not be able to gain entry to the premises to retrieve

           9       the firearm until she returned from work some time

          10       mid-to-late evening."

          11           I'm saying 9 o'clock.  There was no change in that

          12       intelligence picture, as far as I understood it.

          13   Q.  That intelligence initially came through when, what day?

          14   A.  On 1 August.

          15   Q.  Right.  My question is a different question.  By

          16       4 August, bearing in mind that this meet hadn't taken

          17       place on the 2nd, hadn't taken place on the 3rd, had

          18       that intelligence, in relation to the timings, been

          19       repeated, that the meet was going to take place at

          20       9 o'clock?  Simple question: had it?

          21   A.  I am not sure whether it had been repeated, sir,

          22       certainly it hadn't been changed.

          23   Q.  Was it reviewed?

          24   A.  Sir, I was constantly reviewing the intelligence I was

          25       receiving and, as I say, had I known that it was likely


                                            67
 

 

 


           1       to happen earlier, things may have been different but

           2       I had no reason to think that.

           3   Q.  You see, I'm going to suggest to you the reason why you

           4       and your team -- and if you pardon the expression, I'm

           5       sure you understand what I mean -- were caught with your

           6       pants down, was because there had been no review.

           7       Nobody had stopped and thought about this and thought

           8       "Hang on a second, do you think we ought to meet up

           9       slightly earlier, is it likely that, you know -- what's

          10       the evidence that the meet is going to be at 9 o'clock?"

          11       There had been no discussion about this, had there?

          12   A.  Sir, it was something we were thinking about all the

          13       time.  As I have tried to explain to Mr Mansfield, this

          14       was just one piece of a much bigger intelligence

          15       picture, which we are not talking about here, around all

          16       these other individuals.  There was a reason why we had

          17       chosen to run this operation late in the evenings,

          18       because generally that's when the intelligence indicated

          19       we needed to be on duty and there was no reason to be on

          20       any earlier on that day.

          21   Q.  Let me carry on with this theme in relation to your

          22       inflexibility --

          23   THE ASSISTANT CORONER:  Let me suggest that we are now

          24       becoming discomforted, so I think we will have that

          25       break that we mentioned earlier on.


                                            68
 

 

 


           1           So, members of the jury, I'll ask, firstly, for the

           2       cameras upstairs to be turned off.  If you would like to

           3       just have a ten-minute break at this point.  Thank you

           4       very much.

          16   (12.00 pm)

          17                         (A short break)

          18   (12.16 pm)

          21                  (In the presence of the jury)

          22   THE ASSISTANT CORONER:  Thank you.  We will have the witness

          23       then, please.

          24                (The witness returned into court)

          25   THE ASSISTANT CORONER:  Thank you very much, ZZ17.  We are


                                         

 

                                                69
 

 

 


           1       back.  We have the cameras back on now, you are still

           2       under the affirmation that you took and Mr Thomas has

           3       a few more questions.

           4   MR THOMAS:  I am not going to be much longer, just a couple

           5       of areas.

           6           You knew roughly at about 5.20-ish that the meet was

           7       in the process of happening; is that right?

           8   A.  It depends what you mean by "the process", I'm sorry,

           9       sir.

          10   Q.  Well, you were receiving fast time intelligence that

          11       Duggan had been identified, he was in the minicab, he

          12       was going to the Leyton area.

          13   A.  That he was going to be going imminently, sir, yes.

          14   Q.  Yes.  That was roughly at about 5.20-ish; is that

          15       correct?

          16   A.  That's right, sir, yes.

          17   Q.  Now, you said that it wasn't unreasonable to continue

          18       with the proposed briefing that you had scheduled at

          19       6.00 pm at Quicksilver.

          20   A.  If I said that, sir, that's not quite what I meant,

          21       sorry.  What I meant was it wasn't unreasonable for the

          22       briefing to happen at Quicksilver as soon as possible,

          23       not at 6.00 pm.

          24   Q.  Well, let me ask you this: all of the teams that you

          25       wanted to assemble at Quicksilver, did they meet at


                                            70
 

 

 


           1       Quicksilver?

           2   A.  What do you mean, sir, sorry?

           3   Q.  Well, the planned meeting at 6.00 pm at Quicksilver --

           4   A.  Yes.

           5   Q.  -- you had various members of teams who were going to

           6       meet there --

           7   A.  Yes.

           8   Q.  -- my question is: did they actually meet at

           9       Quicksilver?

          10   A.  Sir, the firearms team came there, I was there, the

          11       Tactical Firearms Commander came there, the armed

          12       surveillance team came there.  There may have been one

          13       or two members of the Trident team who didn't come there

          14       or weren't there by the time we left, but, yes,

          15       effectively, yes.

          16   Q.  What time was that?

          17   A.  What time was what, sorry, sir?

          18   Q.  What time was this meeting?

          19   A.  Sorry, sir, there wasn't a meeting as such.

          20   Q.  Well, let's break it down.

          21   A.  Yes.  The firearms team got there --

          22   Q.  The question is, a simple question: what time did they

          23       arrive?

          24   A.  They all arrived at different times so, sorry sir, you

          25       would have to be more specific as to what time who


                                            71
 

 

 


           1       arrived.

           2   Q.  What time did the last in the group arrive so that you

           3       were all assembled?

           4   A.  Sir, as it happened, the firearms team got there very

           5       quickly.  Z51, I think, arrived shortly after them.

           6       There was some delay in waiting for at least some of the

           7       SCD11 surveillance team.  I think by the time I left

           8       there, shortly before 6 o'clock, the last members, one

           9       or two members of the surveillance team, were either

          10       about to arrive or just arriving at about that time.

          11   Q.  So let's get this clear: the team that you wanted to be

          12       assembled didn't all arrive before you left, correct?

          13   A.  Not everybody that you would have in an ideal world,

          14       sir, no.

          15   Q.  No.  Can I just be clear and come back because --

          16   A.  Yes.

          17   Q.  -- I don't think you quite answered my question.  If you

          18       did, I apologise.

          19   A.  Sorry, sir, I may have missed it.

          20   Q.  Again, it's a simple question: the team that you wanted

          21       assembled, that you have now just told us not everybody

          22       arrived --

          23   A.  Yes.

          24   Q.  -- but the last person to arrive in that team before you

          25       left, am I right in thinking that was just before


                                            72
 

 

 


           1       6 o'clock?

           2   A.  I left there just before 6 o'clock, sir, yes, and the

           3       surveillance team were not quite ready to leave at that

           4       point.  They weren't quite all there and ready to go.

           5   Q.  Fine.  Next question: did you in fact have a briefing?

           6   A.  Not in the sense that we had a briefing on the previous

           7       night, sir.  We were able to brief the firearms team

           8       briefly as to what was going on.  We were able to brief

           9       the surveillance team leader and most of his team as to

          10       what was going on.  There wasn't, in the way there had

          11       been on the previous nights, a full recorded briefing.

          12   Q.  Let's break it down.  Let's turn to the firearms team.

          13   A.  Yes.

          14   Q.  Tell us, please, the briefing you gave the firearms

          15       team -- sorry, there's a question before that and the

          16       question is this: you said that the firearms team were

          17       the first to arrive; is that right?

          18   A.  Obviously, I was already there, sir, and some of the

          19       Trident officers had arrived and left.  Of the people

          20       that then arrived, yes, they were the first.

          21   Q.  Did you start your briefing of the firearms officers

          22       before the other members of the assembled teams arrived?

          23   A.  Sir, I spoke to -- the firearms team were in the yard

          24       area, the car park, if you like, getting their equipment

          25       ready and their vehicles ready.


                                            73
 

 

 


           1   Q.  Let's just pause.  I understand the jury now have the

           2       briefing of 3 August.

           3   THE ASSISTANT CORONER:  They do and we've all got it behind,

           4       now, divider number 12.

           5   MR THOMAS:  Let's have a quick look at that.

           6   A.  Yes, sir.

           7   Q.  So this is the briefing -- or this is the type of

           8       briefing that you would have wanted to have occurred but

           9       for the fast moving information that was coming in,

          10       correct?

          11   A.  Yes, that's right, sir, yes.

          12   Q.  Just so the jury are clear about this, when we look at

          13       this briefing note, which runs to six or seven pages,

          14       something like that, just help the jury with this: if we

          15       look at the very last page of that note, we've got -- we

          16       can see you're there.  Do you see that, ZZ17?  We can

          17       see Z51, we can see "ALL".

          18   A.  Yes.

          19   Q.  Just so we are clear, who is "ALL"?

          20   A.  Well, it's everybody, sir.

          21   Q.  I know "all" is everyone.

          22   A.  I was going to go on, sir, sorry.  It's the firearms

          23       team, the surveillance team and the Trident officers.

          24   Q.  Right.  So the normal briefing that you would have would

          25       involve everybody being briefed at the same time,


                                            74
 

 

 


           1       correct?

           2   A.  Yes.

           3   Q.  I'm not going to go through the briefing note, the jury

           4       can look at that themselves and see the sort of

           5       information that you impart.  So that's what you were

           6       planning to do on the 4th.

           7   A.  Yes, sir.

           8   Q.  Okay.  Question: this didn't happen?

           9   A.  Not in that form, no, sir.

          10   Q.  No.  In relation to what did happen, and I'm focusing

          11       only on the firearms officers to start with --

          12   A.  Okay.

          13   Q.  -- would I be right in thinking that when the firearms

          14       officers arrived, you and the rest of the -- who else

          15       was there?  Was Z51 there?

          16   A.  I think he arrived just after the firearms team, sir.

          17   Q.  Okay.  So you are there.  Did you start the briefing

          18       process with the firearms officers before Z51 arrived?

          19       (Pause)

          20   A.  I'm not sure, sir.  I'm sure I would have spoken to the

          21       firearms team leader and filled him in briefly that the

          22       intelligence is Mark Duggan is going to go and collect

          23       a gun.

          24   Q.  Why would you not have started the briefing process,

          25       bearing in mind this is all meant to be moving fast time


                                            75
 

 

 


           1       with the type of intelligence that we're talking about;

           2       can you help us with that?

           3   A.  What I'm trying to say, sir, is that, as soon as the

           4       firearms team arrived -- in fact, I think I spoke to the

           5       firearms team leader on the way and gave him a gist of

           6       why I needed them to get there.  When they arrived

           7       I gave him what the intelligence picture was.  As

           8       I recall -- I may be slightly wrong on this, as

           9       I recall, Z51 arrived very shortly after them, so I had

          10       begun the process of telling them what the information

          11       was.

          12   Q.  Sorry, you have just changed your evidence slightly in

          13       this regard.  Initially you just said that you gave --

          14       you gave a briefing to the firearms leader as opposed to

          15       all of the firearms officers; which is it?

          16   THE ASSISTANT CORONER:  You give your evidence but I don't

          17       think that that's particularly accurate.  You tell us.

          18   A.  Sir, I spoke to the firearms team leader on the

          19       telephone to ask him to come.  I gave him at least some

          20       of the information at that time.

          21           When they arrived, the firearms team were all

          22       together in the car park, the yard.  I spoke to the

          23       firearms team leader and his team were with him --

          24   Q.  Right.

          25   A.  -- if that makes that clear.


                                            76
 

 

 


           1   Q.  So you started the briefing with the firearms team when

           2       they were all assembled in the car park?

           3   A.  If you want to call that a briefing, sir.

           4   Q.  Well, I don't want to call it a briefing, I want to know

           5       what you call it.

           6   A.  It's not a briefing, as we have established, in the way

           7       we had the previous day.  I gave them the information,

           8       very shortly the TFC arrived --

           9   Q.  How long were the firearms officers there?

          10   A.  How --

          11   Q.  Forgive me, sorry, two questions.  The first question is

          12       this -- I don't think you have quite answered the first

          13       question: when did the firearms officers arrive and how

          14       long were they there for?

          15   A.  I would have to estimate, sir.  I stand to be corrected

          16       if somebody has a better record or recollection.

          17   THE ASSISTANT CORONER:  Don't worry about that, do the best

          18       you can.

          19   A.  I think they probably arrived around about 25 to,

          20       something like that, a little after 5.30.

          21   THE ASSISTANT CORONER:  Right, and you left as you told us?

          22   A.  We left there just before 6 o'clock.

          23   THE ASSISTANT CORONER:  This is maybe the main question

          24       here --

          25   A.  Yes, sir.


                                            77
 

 

 


           1   THE ASSISTANT CORONER:  -- looking at it, in all the

           2       circumstances, could you reasonably have left, in the

           3       convoy of the four cars that we know happened in the

           4       end, any earlier than those few minutes before

           5       6 o'clock?

           6   A.  I think it was a balance, sir, between trying to get all

           7       of the resources into place that we would like to have,

           8       the surveillance team and so on, and when we needed to

           9       leave.  I think the decision to leave Quicksilver was

          10       made once it became apparent that Mark Duggan had

          11       arrived at his destination to pick up the firearm.  At

          12       that point the decision was taken by the TFC that we

          13       needed to leave.  Had that situation arisen earlier, I'm

          14       sure we would have been in a position to leave

          15       Quicksilver earlier.

          16           It was a balance between trying to get ready as

          17       quickly as possible and trying to get as many of the

          18       resources into place as possible, if I can put it that

          19       way.  I think we left once it became apparent that would

          20       be the best thing to do and we were then in a position

          21       to catch up with the minicab and stop it.

          22   THE ASSISTANT CORONER:  Thank you very much.

          23   MR THOMAS:  The briefing you gave wasn't the full type of

          24       briefing, it was more of a dynamic briefing; would that

          25       be fair?


                                            78
 

 

 


           1   A.  Yes, I think that's fair, sir, yes.

           2   Q.  That is a type of briefing that takes place regularly,

           3       last minute, on the scene at many destinations, isn't

           4       it?

           5   A.  All kinds of different briefings take place, sir, yes.

           6   Q.  Sorry, my question is specific.  If you disagree with it

           7       then say you disagree with it but please answer the

           8       question.  My question is: what you've accepted was

           9       a dynamic briefing -- it's not a full briefing --

          10   A.  Yes.

          11   Q.  -- that sort of briefing regularly takes place with

          12       firearms officers at the scene or on the plot of where

          13       incidents occur, not outside, but, you know, firearms

          14       officers might be a few roads back.  That sort of

          15       briefing regularly takes place with firearms officers

          16       day in, day out when they cover these sorts of things

          17       that happen in fast time; do you accept that?

          18   A.  Yes, sir.

          19   Q.  There is no reason, is there, ZZ17, why that dynamic

          20       briefing needed to take place at Quicksilver?  It could

          21       have taken place in the Leyton area.  You could have

          22       directed the officers, the firearms officers, to go to

          23       Leyton and you and Z51 meet them there and have the

          24       dynamic briefing there.

          25   A.  We could have done, sir, but I don't see what difference


                                            79
 

 

 


           1       that would have made to the outcome, I really don't.

           2   Q.  You say you don't know what difference it would have

           3       made to the outcome.  I am not going to repeat the

           4       points Mr Mansfield has already put to you, but it would

           5       have given you -- you would have been -- it would have

           6       given you more time and you wouldn't have been playing

           7       catch up.  That's the first point; do you accept that?

           8   A.  No, sir.

           9   Q.  Let me move on to a completely different topic, one

          10       Mr Mansfield has not covered with you at all.

          11   A.  Yes.

          12   Q.  Okay.  I want to take you, if I can, to the immediate

          13       aftermath of the shooting.

          14   A.  Yes.

          15   Q.  Okay, so we're in Ferry Lane, Mark Duggan has just been

          16       shot.

          17   A.  Yes.

          18   Q.  I think at that point in time individuals are trying to

          19       assist him --

          20   A.  Yes.

          21   Q.  -- and I think you were one of the senior officers

          22       there.  I think you indicated yesterday that Z51 was in

          23       charge, is that correct --

          24   A.  Yes.

          25   Q.  -- until other officers --


                                            80
 

 

 


           1   A.  Initially he was in charge, sir, yes.

           2   Q.  Would I be right in thinking that you, in effect, would

           3       have been one of the second in command?

           4   A.  One of them, yes, sir.

           5   Q.  Yes.  Mr Mansfield mentioned a term yesterday, I'm going

           6       to mention it -- in French, I'm going to mention it in

           7       English because that's the language I speak -- and that

           8       is keeping a cordon around -- a sterile cordon, around

           9       the incident, yes?

          10   A.  Yes.

          11   Q.  You understand --

          12   A.  I do, yes.

          13   Q.  Would you agree that, bearing in mind the type of

          14       operation that you and your colleagues were conducting,

          15       such a cordon was of the utmost importance for a number

          16       of reasons; would you agree?

          17   A.  Yes, sir.

          18   Q.  Can I just look at some of the reasons with you very

          19       briefly -- there may be more, but these are the ones

          20       that just come to my mind -- and see if you agree?

          21   A.  Of course.

          22   Q.  Firstly, a man had just been shot dead.  He may have

          23       been being worked on but, to all intents and purposes,

          24       it was looking likely, would you agree, that he wasn't

          25       going to survive; would you agree?


                                            81
 

 

 


           1   A.  I would accept that, sir, yes.

           2   Q.  So the actual vicinity around where he had been shot,

           3       would you agree that you knew -- you certainly knew --

           4       that there was likely to be an investigation into what

           5       happened and how Mark Duggan was shot?

           6   A.  Yes, sir.

           7   Q.  Yes.  Secondly why it was important to keep this area

           8       sterile, you had been investigating very serious

           9       offences, firearms offences, where, on the face of it,

          10       there had been an exchange --

          11   A.  Yes.

          12   Q.  -- of a firearm from one person to another person and

          13       that firearm was said to be either in the possession of

          14       Mark Duggan or in the immediate vicinity.

          15   A.  Yes.

          16   Q.  Thirdly, you would have appreciated that the last thing

          17       that you or your colleagues would want to do, being

          18       experienced officers, police officers, would be to

          19       contaminate the scene.  So, for instance, would you

          20       agree that one factor would be firearms residue: it

          21       would be important not to try to contaminate the scene

          22       with firearms residue, more than need be?

          23   A.  More than need be, sir, yes.

          24   Q.  Yes, more than need be.  On that theme: secondly,

          25       fingerprint evidence.  It would be important not to


                                            82
 

 

 


           1       contaminate the scene or disturb fingerprint evidence

           2       more than need be; would you agree?

           3   A.  I would say there are a number of other considerations

           4       perhaps more important but more than need be, sir, yes.

           5   Q.  You tell us some of the other considerations that you

           6       had in your mind that you would prioritise more than

           7       this?

           8   A.  Well sir, firstly, safety.  Obviously, initially, until

           9       it became apparent what had happened, this was

          10       a firearms operation.  The measures needed to be put in

          11       place to make sure everything was safe.

          12           Secondly, obviously medical treatment for Mark

          13       Duggan and the officer that was shot --

          14   Q.  Yes.

          15   A.  -- and things like that.  But then, yes, I would accept

          16       obviously more than need be to try to reduce any

          17       contamination of the scene, yes.

          18   Q.  I can mention a number of other things: DNA, et cetera,

          19       et cetera, I am not going to go through the whole list.

          20       But you accept the general propositions that I'm putting

          21       forward about keeping the area sterile, bearing in mind

          22       that, in effect, this was a crime scene -- and I say

          23       a "crime scene" because -- and I'm not making reference

          24       to the shooting --

          25   A.  I understand.


                                            83
 

 

 


           1   Q.  -- I'm making reference to the transportation of the

           2       gun, yes?

           3   A.  I understand, sir.

           4   Q.  With that in mind, bearing in mind that it became

           5       apparent very quickly, and we can watch the -- I don't

           6       ask for it, but we could watch the BBC footage for

           7       ourselves again, where we can see Mark Duggan is under

           8       control, he's no longer a threat, he's on the pavement

           9       and he's being worked on, yes?

          10   A.  Okay, sir.

          11   Q.  Right.  We can see that there aren't members of the

          12       public who were walking into the area because you've got

          13       officers holding them back.

          14   A.  Yes.

          15   Q.  Okay, we can see that?

          16   A.  Yes, sir.

          17   Q.  There is no suggestion at this time that there is any

          18       threat to the officers from firearms.

          19   A.  Okay.

          20   Q.  We can see that.

          21   A.  Yes, I accept that, sir, yes.

          22   Q.  Bearing all of that in mind, you would agree, would you

          23       not, that there could be no possible good reason for

          24       officers to go into and contaminate the minicab; do you

          25       follow?


                                            84
 

 

 


           1   A.  I follow, sir, yes.

           2   THE ASSISTANT CORONER:  Do you agree?  You follow the

           3       question but do you agree with the proposition being

           4       put: was there any good reason for any officer to go

           5       into the minicab?

           6   A.  Not that I'm aware of, sir, but I cannot account for

           7       what other people might have thought necessary.

           8   MR THOMAS:  Firstly, can I make my question clear: I am not

           9       asking you to account for what other people may have

          10       done, I am only asking you to account for your own

          11       actions.  But you have accepted, bearing in mind that

          12       Mark Duggan, and I'm talking -- the snapshot of time

          13       that I'm talking about is more or less very shortly

          14       after, on your evidence, you say that you saw

          15       Mark Duggan come out of the minicab, he's shot, he's on

          16       the ground, the area is contained; do you follow?

          17   A.  Yes.

          18   Q.  That's the point in time I'm talking about.

          19   A.  Yes.

          20   Q.  Can you help us with this, ZZ17, and this does concern

          21       you: there you are, you are one of the -- I put it to

          22       you -- second in command, until other officers come who

          23       are (aren't?) involved?

          24   A.  Yes.

          25   Q.  Did you see officers going into the minicab?


                                            85
 

 

 


           1   A.  No, sir.

           2   Q.  If you saw officers going into the minicab, would you

           3       have stopped them?

           4   A.  Well, it's a hypothetical, sir, but I suppose I probably

           5       would have done, yes.

           6   Q.  Because you accept this: it would be quite wrong because

           7       it could affect your investigation; would you agree?

           8   A.  Yes, sir.

           9   MR THOMAS:  That's all I ask.

          10   THE ASSISTANT CORONER:  Thank you.  Yes, Mr Stern, I think.

          11                      Questions by MR STERN

          12   MR STERN:  You've been asked a number of questions about the

          13       location of Vicarage Road and Burchell Road.

          14   A.  Yes, sir.

          15   Q.  If armed officers from CO19 had been ordered to that

          16       location, then obviously they would have gone there.

          17   A.  Yes, sir.

          18   Q.  That is a decision made by yourself and, I think, Z51,

          19       the officers in charge of the operation.

          20   A.  Really -- I gave him the intelligence, sir.  The

          21       decisions are made by Z51, ultimately, but yes.

          22   Q.  Based on the intelligence given by you?

          23   A.  Yes.

          24   Q.  Are we to understand from everything you've told us --

          25       I'm only dealing with 4 August -- that on each occasion


                                            86
 

 

 


           1       on 4 August you exercised your best judgement as to

           2       where it is that any particular forces should actually

           3       go?

           4   A.  Yes, sir.

           5   Q.  Do you say that you would have done any different now?

           6   A.  No, sir.

           7   Q.  Your role, as I understand it, was as the intelligence

           8       officer, as you have told us.

           9   A.  On the 4th, sir, yes.

          10   Q.  I'm only dealing with the 4th, unless I specifically say

          11       otherwise.

          12   A.  Then yes.

          13   Q.  So far as you are concerned, you were the sole link to

          14       SOCA.

          15   A.  Yes.

          16   Q.  SOCA is an entirely separate organisation from the

          17       Metropolitan Police.

          18   A.  Yes, the Serious Organised Crime Agency.

          19   Q.  Thank you.  The purpose of keeping the information to

          20       yourself, or just coming from one organisation to

          21       another, is obviously to avoid leakage of that

          22       information, or one of the --

          23   A.  One of the key reasons, certainly, sir, yes.

          24   Q.  The other is, obviously, to ensure that there is some

          25       safeguarding for other individuals who may be involved


                                            87
 

 

 


           1       in that.

           2   A.  Sorry, I don't quite follow, sir.

           3   Q.  Well, anybody who may have given information, anybody

           4       who may have informed some of the decisions that led to

           5       the information that was given to you.

           6   A.  Yes, I follow.  I would agree with that, sir, yes.

           7   Q.  Also, it's important to have a separation, is there not,

           8       between the intelligence and those actively involved in

           9       the operation.

          10   A.  Yes.

          11   Q.  Now, on 3 August, so I am in fact moving back a day --

          12   A.  Yes, yes.

          13   Q.  -- we do have the briefing that we've looked at in part.

          14   A.  Yes, I have it here, sir.  (Indicates)

          15   Q.  Thank you very much.  I know the jury have it, and it's

          16       in C12 in their bundle.  It's page 274, if anybody wants

          17       to put it up on the screen, otherwise I think everybody

          18       has the document to hand.

          19           Now, we haven't looked at this in detail but can

          20       I ask you a few questions about the process that was

          21       involved here?

          22   A.  Of course, yes.

          23   Q.  The jury will see when they look at this briefing, which

          24       is recorded --

          25   A.  Yes, it's audio recorded, sir, yes.


                                            88
 

 

 


           1   Q.  It is given by three individuals --

           2   A.  Yes.

           3   Q.  -- and they each have separate roles.

           4   A.  Yes.

           5   Q.  First of all, there's Z51, and we can see at page 274

           6       Z51 right at the top.

           7   A.  Yes.

           8   Q.  As you have already told us, he's in charge -- I'm

           9       putting it very generally -- of the operation

          10       effectively --

          11   A.  Yes.

          12   Q.  -- involved in the investigation of offences and the

          13       like.

          14   A.  That's what the operation is for, sir, yes.

          15   Q.  That's what Z51's role was, he's involved in the

          16       investigation.

          17   A.  He's the Tactical Firearms Commander, sir, he's not

          18       directly involved in Operation Dibri, as such.  But he

          19       is in charge of the armed operation on that day.

          20   Q.  Armed operation, yes, thank you.  Then there's yourself,

          21       ZZ17, and you're the intelligence officer and so you

          22       provide the intelligence to the firearms officers.

          23   A.  Yes.

          24   Q.  Then we'll see a little further on, although we don't

          25       need to turn it up, V59, who is the team leader for CO19


                                            89
 

 

 


           1       on this particular occasion.

           2   A.  Yes.

           3   Q.  He gives the tactics for the particular day to the

           4       firearms officers.

           5   A.  Yes.

           6   Q.  So three individuals, separate functions, separate

           7       roles, each giving their briefing to the armed

           8       officers --

           9   A.  That's right, sir, yes.

          10   Q.  -- because the armed officers effectively come, on

          11       3 August in this case, afresh to the whole matter.

          12   A.  Entirely, yes.

          13   Q.  Now, the purpose of a briefing is in order that the

          14       firearms officers and indeed, I think, the surveillance

          15       officers in this case --

          16   A.  Yes.

          17   Q.  -- are briefed on the nature of the operation --

          18   A.  Yes.

          19   Q.  -- and the intelligence available and the tactics to be

          20       employed.

          21   A.  Yes.

          22   Q.  Officers, of course, have a right to expect the best

          23       information to be given to them at a briefing.

          24   A.  Yes.

          25   Q.  That information may affect how they act later on --


                                            90
 

 

 


           1   A.  Yes, I would accept that, sir.

           2   Q.  -- and it may protect them, it may save their life.

           3   A.  Yes.

           4   Q.  Of course, they have rights, like everyone else, as do

           5       their families.

           6   A.  Of course.

           7   Q.  Now, in relation to the briefing --

           8   A.  Yes.

           9   Q.  -- could we just look at what it was that was being said

          10       by you?  I am not obviously going to look at what

          11       everyone says at this stage.  At page 274, we can see

          12       initially there's the briefing by -- the start of it by

          13       Z51, just giving the time and saying that we are on

          14       Operation Dibri.

          15   A.  Yes.

          16   Q.  At the briefing here are firearms officers employed in

          17       this operation and other officers from SCD8; who are

          18       they?

          19   A.  That's Trident, sir.

          20   Q.  So they are the unarmed surveillance officers?

          21   A.  They are unarmed -- they are not really there on that

          22       day to conduct surveillance, they are there to support

          23       the surveillance but, yes, potentially, as happens on

          24       the 4th, they may get involved in some surveillance.

          25   Q.  Yes.  Then we have the command structure set out.  The


                                            91
 

 

 


           1       fact that it's been authorised, an armed operation has

           2       been authorised --

           3   A.  Yes.

           4   Q.  -- and the roles are explained.

           5   A.  Yes.

           6   Q.  Then you take over and you say:

           7           "Thank you boss ... Operation Dibri as some of you

           8       may know is a long running Trident investigation into

           9       the activities of the Tottenham Man Dem, the TMD.  There

          10       are a large number of subjects and associates on this

          11       operation.  There are I think 6 that have been put on

          12       the briefing for tonight who may become relevant for

          13       tonight or for the rest of the week, I'll go briefly

          14       through those but it may well be that as intelligence

          15       develops we'll pass out more relevant information to

          16       you.  If you look at your briefing packs ..."

          17           I don't think you've actually dealt with that but

          18       you have produced the briefing packs and I'll look at

          19       that with you in a moment or to two:

          20           "... and the photographs, just rattling through

          21       those ..."

          22           Then, do you set out the six subjects that are

          23       referred to?

          24   A.  Yes.

          25   Q.  So what you've set out there, just on that first page,


                                            92
 

 

 


           1       if I am to understand it correctly, is that there are

           2       six individuals who may become relevant on that evening.

           3   A.  Yes.  There could be others but those are the six that

           4       this operation is set up to look at.

           5   Q.  Well, the whole purpose of this, isn't it, is to give

           6       the intelligence at the time that you have it, which, as

           7       has already been pointed out, obviously may change from

           8       minute to minute, hour to hour.

           9   A.  Yes, sir.  It changes regularly.  This was really the

          10       first briefing of the week, to set out to everybody

          11       involved, as you say, this is why we're here, and really

          12       just a brief summary of the six subjects of this

          13       operation, without wanting to overload people with too

          14       much information in this briefing, just to set out

          15       "These are the people who may become relevant".

          16   Q.  The reason I am looking at it is because obviously, if

          17       you were sitting in the position of an armed officer

          18       sitting listening to this briefing, this is the

          19       information they would receive.

          20   A.  Yes.

          21   Q.  Look at page 275, and I am not going to read it all, but

          22       you then go through various subjects, U8, U13, U14 and

          23       then you say, about two thirds of the way down:

          24           "Again we've got in vehicle for him at this stage.

          25       Mark Duggan I'll come back to in a minute because he may


                                            93
 

 

 


           1       well become more relevant for this evening's activity."

           2   A.  That's right, sir, yes.

           3   Q.  Then we go into U15.

           4   A.  Yes.

           5   Q.  Then at the last seven or eight lines of that page:

           6           "If I come back to Mark Duggan.  The picture on

           7       there is quite a good likeness."

           8           By which you mean the photograph that had been

           9       handed out as part of the briefing pack.

          10   A.  Yes, so that the surveillance officers would recognise

          11       him, sir, yes.

          12   Q.  "There's a number of addresses associated with him."

          13           Then it sets out his addresses and his connections

          14       and I won't read those out.  Over the page, you say:

          15           "We believe where he's staying at the moment ...

          16       Micawber Court ..."

          17           You say:

          18           "... he's disqualified from driving, doesn't always

          19       stop him but he tends not to drive so we haven't got

          20       a vehicle for him."

          21           Then there's the vehicle on the briefing sheet, it

          22       says, which is associated with a certain address:

          23           "... but again he tends to be run around by various

          24       associates in their vehicles."

          25           So nothing specific about the vehicle or indeed the


                                            94
 

 

 


           1       associate at this stage?

           2   A.  No, sir.

           3   Q.  "All of the subjects on here have got access to

           4       firearms.  There's nothing specific to say that any of

           5       them keep firearms at their home addresses or that

           6       they're armed today."

           7   A.  Yes.

           8   Q.  You say:

           9           "There is intelligence to suggest that Mark Duggan

          10       is currently in possession or control of about

          11       3 firearms and that he is looking to take possession of

          12       a firearm perhaps this evening, he's been trying to do

          13       it for a few days."

          14   A.  Yes, sir.

          15   Q.  "There's some more photos coming round, these are black

          16       and white ones ... a guy called Kevin Hutchinson-Foster.

          17       Intelligence would suggest that he's got control of the

          18       firearms and from 9 o'clock this evening there may well

          19       be a plan for Duggan to somehow get those firearms from

          20       Hutchinson."

          21   A.  Yes.

          22   Q.  Was that really the extent of the information that you

          23       had on that evening?

          24   A.  Yes, sir.

          25   Q.  So there were six individuals and there was a possible


                                            95
 

 

 


           1       plan for a firearm to be transferred or not?

           2   A.  Exactly, yes.

           3   Q.  Can I just -- just trying to cross reference it, if we

           4       can, please, to C9, just for a moment --

           5   A.  Yes.

           6   Q.  -- looking at the information that people had -- sorry,

           7       that A10 had --

           8   A.  Yes.

           9   Q.  -- if we look at the 3 August entry, we can see that it

          10       deals with the point of Kevin Hutchinson-Foster:

          11           "... still insufficient intelligence to identify

          12       where the firearm was being stored beyond the premises

          13       of the female associate probably in the Leyton area.

          14       The intelligence indicated that Kevin Hutchinson-Foster

          15       intended to travel out of London later that evening."

          16           Then it's got:

          17           "I subsequently received intelligence ..."

          18           This is, I think, Mark Duggan going off to

          19       a barbecue.

          20   A.  Yes.

          21   Q.  Can we take it that at the time at which briefing was

          22       given at 6.10 in the evening, it was not known he was

          23       going off for a barbecue that evening?

          24   A.  That's right, sir.

          25   Q.  What would have been the effect, had you had that


                                            96
 

 

 


           1       intelligence, on this operation for the evening?

           2   A.  Well, I wouldn't have given the intelligence we have

           3       just discussed there at that time, sir.

           4   Q.  Right.  Then, just going back, if we can, to page 276,

           5       about eight lines up:

           6           "Hopefully at some stage we'll have more information

           7       about where that's going to happen, how it's going to

           8       happen but the intelligence at the moment is that

           9       Hutchinson has got control of at least 1 firearm which

          10       he's going to pass to Mark Duggan possibly at some point

          11       this evening.  As I say there's a lot more intelligence

          12       around and a lot more subjects and associates, I'll try

          13       and keep it simple for now.  As I say Mark Duggan is

          14       perhaps for today the most likely subject we're going to

          15       be looking at.  Boss, I'll hand back to you then."

          16           That is the end of your briefing and the

          17       intelligence that's provided to the CO19, the armed

          18       officers at that time.

          19   A.  Yes.

          20   Q.  Could we look at the briefing pack, just so that

          21       everybody has the documents, as it were, that they were

          22       looking at, so we have the full picture.  It's CE283.

          23           Now, what happens, just so people understand, is

          24       that not only do you give this intelligence briefing,

          25       but there's a small pack in order to try to give some of


                                            97
 

 

 


           1       the information in relation to the officers who are

           2       present: the surveillance officers and indeed the armed

           3       officers.

           4   A.  Yes.  In fact, sir, on this occasion there were

           5       basically three small packs.  There was the pack we have

           6       here, a pack of photographs of the subjects, and a pack

           7       of maps of the addresses that were relevant.

           8   Q.  In fact, I think, we have them all here, so we'll be

           9       able to see them, so we'll be able to go through them.

          10       But we can do it, I think, fairly briefly.

          11           The first page, as we can see, just sets out the

          12       information.

          13   A.  Yes.

          14   Q.  It sets out Operation Dibri being a pro-active operation

          15       and the purpose of it is to target an organised criminal

          16       network known as the Tottenham Man Dem.  Then it sets

          17       out that they are involved in class A drugs supply,

          18       robbery, kidnap and the like --

          19   A.  Yes.

          20   Q.  -- and they've been responsible and instrumental in

          21       numerous fatal and non-fatal shootings in the past

          22       12 years and they have a propensity to use firearms and

          23       extreme violence.

          24   A.  Yes, sir.

          25   Q.  Then the various subjects are set out.  As we can see,


                                            98
 

 

 


           1       the only one that's not been blocked out is obviously

           2       Mark Duggan, otherwise the other names are not included.

           3   A.  Yes.

           4   Q.  Then over the page, page 284, it says:

           5           "The intention is for SCD8 to respond to

           6       intelligence, SCD11 to conduct surveillance and once

           7       there is a sufficiency of evidence to confirm offences

           8       have been committed, officers from CO19 will carry out

           9       an intervention."

          10   A.  Yes.

          11   Q.  Because obviously an individual who is carrying a gun,

          12       or may be carrying a gun, must of course be arrested --

          13       it's called an intervention, but effectively it's an

          14       arrest?

          15   A.  Yes.

          16   Q.  By armed officers?

          17   A.  Yes, sir.

          18   Q.  In order to ensure the safety of others.

          19   A.  Yes.  It wouldn't really be safe for unarmed officers to

          20       seek to do that, sir.

          21   Q.  Exactly.  And the method there:

          22           "Officers will respond to intelligence."

          23           "Admin" I think we can move across.  "Risk

          24       assessment"; we have already looked at that to some

          25       extent?


                                            99
 

 

 


           1   A.  Yes.

           2   Q.  It does say that the subjects of this operation are

           3       strongly believed to be involved in the supply of class

           4       A drugs and the possession and use of firearms.

           5   A.  Yes, sir.

           6   Q.  There is no current intelligence to suggest that any of

           7       the subjects are routinely armed, but they do have ready

           8       access to firearms.

           9           Then it says the risk assessment has been completed.

          10           Communications will be by radios and mobile phones.

          11   A.  Yes.

          12   Q.  I think if you look over the page you'll see, although

          13       obviously it's redacted, it's been cut off, it has not

          14       been copied -- because it's one of the individuals who

          15       were obviously given a U number in this briefing pack.

          16   A.  Yes.

          17   Q.  So we have then got a series of photographs --

          18   A.  Yes.

          19   Q.  -- or not in our case, of individuals that would have

          20       been given to the armed officers and surveillance

          21       officers at the time.

          22   A.  Yes.

          23   Q.  If we turn to page 288, I think if we keep -- there are

          24       three pages, I think, before that of photographs.  We

          25       come eventually to Mark Duggan and I'm sure -- I don't


                                           100
 

 

 


           1       know if it was a photocopy or a photograph --

           2   A.  I think this is -- because it's been blocked out, sir,

           3       in the process of doing that, the photocopying has made

           4       that much worse.  I think originally it would have been

           5       printed quite clearly.

           6   Q.  Okay.  Then we have more associates.  Then we look at

           7       289 and we have maps.  If we follow those -- again,

           8       they've been cut off because presumably they relate to

           9       addresses of individuals whose names have been removed

          10       from our view?

          11   A.  Exactly, sir, yes.

          12   Q.  All right.  So 290 is the same, 291 is the same,

          13       et cetera, through to 296.  296, 297 and 298 are --

          14       well, they are just downloaded from the Internet, aren't

          15       they?  They are Google Maps relating to addresses that

          16       we've already seen --

          17   A.  Yes.

          18   Q.  -- relating to Mark Duggan.

          19   A.  Yes.

          20   THE ASSISTANT CORONER:  Is that the system, just Google

          21       Maps?

          22   A.  Sorry, sir?

          23   THE ASSISTANT CORONER:  You just use Google Maps?

          24   A.  I think some of the ones covered up are from other

          25       sources.  I think these three happen to be from Google


                                           101
 

 

 


           1       Maps, and mostly, obviously, people have map books

           2       anyway.  It's mostly to show where on a particular road

           3       a particular house might be, at which junction and so

           4       on.

           5   MR STERN:  Then could we go to page 300.  Just help us: was

           6       this part of the brief?  Obviously nobody can see the

           7       photograph, but it is, I think, a photograph of

           8       Kevin Hutchinson-Foster?

           9   A.  It is, sir.  That's the photograph that's referred to in

          10       the briefing that we just read through.  Obviously,

          11       again, the photocopier has not done it any good here,

          12       but yes.

          13   Q.  It may not matter very much, but this is the photograph

          14       anyway.  So they were shown a photograph of

          15       Mr Hutchinson-Foster?

          16   A.  Yes.

          17   Q.  Or Hutchinson or whatever name he goes under.  At 301, I

          18       think there's another one as well?

          19   A.  Yes, sir.  I think those two, you probably can't see it,

          20       there are one looking forwards and one to the side.

          21   Q.  I see.  So same photograph but different sides of the

          22       same face.

          23   A.  Yes.

          24   Q.  302.  This is who's seen the --

          25   A.  Yes.  That sheet is handed down at the briefing, sir,


                                           102
 

 

 


           1       and the surveillance officers and the firearms officers

           2       sign that to say they have seen those photographs.

           3       Really so that, you know, any prosecution later they can

           4       say, "The person I saw was the person whose photograph

           5       I saw on the briefing and I recognised him to be

           6       Mark Duggan", or whoever it may be.

           7   Q.  I see.  That's very helpful, thank you.

           8           Then we have some photographs afterwards, and

           9       I don't know whether these were part of the briefing or

          10       not: 303 to 309?

          11   A.  In fact, sir, those are, I think, bigger versions of the

          12       same photographs we have just seen that went with that

          13       signing sheet, to be signed up.

          14   Q.  Thank you very much, that's very helpful.  That was the

          15       briefing pack that the armed officers and the

          16       surveillance armed officers had?

          17   A.  Yes.

          18   Q.  Thank you.  Can I just ask you, please, about this.  We

          19       heard from Mr Foote --

          20   A.  Yes.

          21   Q.  Do you know who Mr Foote is?

          22   A.  I do, sir, yes.

          23   Q.  He informed us of a number of pieces of intelligence in

          24       relation to Mark Duggan --

          25   A.  Yes.


                                           103
 

 

 


           1   Q.  -- some of which were historic?

           2   A.  Yes.

           3   Q.  Let me divide it into historic and more recent.

           4   A.  Okay.

           5   Q.  So far as historic information about Mark Duggan; that

           6       was not and did not feature in your briefing?

           7   A.  No, sir.  I was trying to focus on the current picture.

           8   Q.  I am not criticising you, I am just trying to

           9       understand.  Because the jury have heard this

          10       information and they may wonder why it was that that

          11       information was not imparted to the firearms officers.

          12   A.  Yes, sir.  As I said before, really I was conscious of

          13       information overload with these six people to go

          14       through.  If we went through extended histories on each

          15       of them, there's only so much people could take in.  So

          16       it was really just to set out, "This is what this gang

          17       are about", and, briefly, "This is what the current

          18       picture is with these six individuals", and try to keep

          19       it that simple.

          20   Q.  I see.  There's one other thing that we heard about,

          21       in July 2011, which is obviously recent.

          22   A.  Yes.

          23   Q.  Or would have been to that briefing: the intelligence

          24       indicated that Mark Duggan had possession of a firearm

          25       and that he had shot somebody at a party.  But the


                                           104
 

 

 


           1       intelligence did not assist with where the firearm was

           2       currently being stored.

           3   A.  Yes.

           4   Q.  Again, did you make a decision not to include that or

           5       was that just something of an oversight?

           6   A.  I think I probably made a decision not to include that,

           7       sir.  I was really just trying to focus on what the

           8       position was for that day.  Obviously we have set out

           9       that all these individuals have got access to firearms,

          10       they are linked to the use of firearms and so forth, and

          11       not to try and go into too much detail on each person

          12       for people to take in.

          13   Q.  Right.  So the position so far as the firearms officers

          14       was concerned was a very general picture of six

          15       individuals all at various times in possession of and

          16       using firearms and involved in drugs?

          17   A.  Yes.  And just at that time Mark Duggan was, as I think

          18       I put it, perhaps the "most likely for today" to be in

          19       possession of a firearm.

          20   Q.  Yes, you did make that absolutely clear.

          21           Thank you very much.

          22   A.  Thank you, sir.

          23   THE ASSISTANT CORONER:  Mr Butt?

          24   MR BUTT:  About five minutes, sir.

          25   THE ASSISTANT CORONER:  Let's have your five minutes and


                                           105
 

 

 


           1       we'll see if it is.

           2                       Questions by MR BUTT

           3   MR BUTT:  I ask questions on behalf of Z51.

           4   A.  Yes, sir.

           5   Q.  The intelligence in relation to

           6       Kevin Hutchinson-Foster --

           7   A.  Yes, sir.

           8   Q.  -- before 3 August was quite general; do you agree with

           9       that?

          10   A.  Yes.

          11   Q.  Mark Duggan wanted a gun.  The supplier might be Kevin,

          12       and that firmed up as time went on, but there was no

          13       plan for a handover before 3 August; is that fair?

          14   A.  I think initially there was some intelligence to suggest

          15       there may be a handover, and then there was intelligence

          16       to say that that handover wasn't going to happen.  So,

          17       yes, I would agree with you.

          18   Q.  That of course changed on 3 August when, for the first

          19       time, it looked like you might need to respond to a plan

          20       for a firearm to be handed to Mark Duggan; is that

          21       right?

          22   A.  Yes, I think, as I have just said to Mr Stern, sir,

          23       there was this intelligence that he was -- most likely

          24       this plan may come about later this evening.

          25   Q.  Because the intelligence on 3 August was now more


                                           106
 

 

 


           1       specific, you updated Z51 then with the intelligence

           2       that you now had about Mr Hutchinson-Foster; is that

           3       right?

           4   A.  Yes, sir.  We were starting the firearms operation that

           5       was planned to run over a few days.  So I sat down with

           6       Z51 and that was the intelligence picture at that time,

           7       yes.

           8   Q.  That would have been a little before the briefing on the

           9       3rd, would it have been?

          10   A.  Exactly, yes.

          11   Q.  Is it right that before 3 August, because of the more

          12       general nature of the intelligence, you didn't in fact

          13       update Z51 with details about Kevin or

          14       Kevin Hutchinson-Foster?

          15   A.  I think that's right, sir, yes.

          16   Q.  In terms of the intelligence you had on 3 August --

          17   A.  Yes.

          18   Q.  -- that Mr Hutchinson-Foster was going to be involved

          19       in, and then was not going to be involved in, handing

          20       over a firearm, was that sort of intelligence very

          21       unusual for you in your line of work on Operation Dibri?

          22   A.  Not at all, sir, no.  I think, as I said to somebody

          23       earlier -- I cannot remember who -- I was getting this

          24       kind of intelligence all day, every day about people who

          25       may have firearms, may not have firearms, may be seeking


                                           107
 

 

 


           1       to get firearms, maybe not, and -- the nature of the

           2       gangs that we deal with is that -- I think it's been

           3       said they are chaotic, they are unpredictable.  It would

           4       be entirely normal for something to be planned and then

           5       not happen or postponed; it's of that nature, sir.

           6   Q.  Would it be vaguely practical to send directed

           7       surveillance out, armed or unarmed, to follow someone

           8       like Mr Hutchinson-Foster based upon the intel you had

           9       on 3 August that he was going to and then was not going

          10       to hand over the gun?

          11   A.  No, sir.  I mean, we try and balance it that when we've

          12       got something reliable and specific, we seek to respond

          13       to that and, nine times out of ten, that doesn't happen.

          14       So to seek to send a team out on that basis just

          15       wouldn't be practical at all.

          16   Q.  All the intelligence we have heard about all the

          17       particular intelligence came from SOCA and you would

          18       pass it on to Z51 if appropriate; is that right?

          19   A.  Yes, sir.

          20   Q.  I think, on 4 August, virtually all of the intelligence

          21       was appropriate for you to pass on to Z51 and you did

          22       so; is that right?

          23   A.  Virtually all of this intelligence, sir, yes.  There

          24       would have been intelligence about other things going on

          25       but, yes, with this intelligence, yes.


                                           108
 

 

 


           1   Q.  Z51 wasn't getting that particular intelligence from

           2       anyone else, was he?

           3   A.  No, just from me, sir.

           4   Q.  It wasn't until 17.20 that you received the intel that

           5       Mark Duggan was going to take possession of a firearm

           6       imminently in the Leyton area; is that right?

           7   A.  That's right, yes.

           8   Q.  You passed that on to Z51 shortly after 17.20; is that

           9       right?

          10   A.  Yes.

          11   Q.  It wasn't until after 6 o'clock in the evening that you

          12       received intel that Mark Duggan had the gun and that he

          13       was going to Broadwater Farm, was it?

          14   A.  That's right.

          15   Q.  Nobody from the police could possibly have known before

          16       6 o'clock that Mark Duggan had the gun or that he was

          17       going to Broadwater Farm with it, could they?

          18   A.  No, sir.

          19   Q.  When you received that intelligence, after 6 o'clock,

          20       that Mark Duggan had the gun, you pass that on to Z51

          21       and he went to amber very shortly afterwards, didn't he?

          22   A.  Immediately, yes.

          23   Q.  You say immediately?

          24   A.  Yes.

          25   Q.  There was obviously no time for Z51 to update the


                                           109
 

 

 


           1       Strategic Firearms Commander in between getting the

           2       update that Mr Duggan has the gun to going to amber and

           3       the interception, was there?

           4   A.  No, it was immediate, sir, like I say.

           5   Q.  You were in the car with him?

           6   A.  I was sat next to him, sir, yes.

           7   Q.  Can I just finally go back to the video that you were

           8       shown yesterday?

           9   A.  Yes.

          10   Q.  We saw, with a blue arrow over his head, Z51 in the

          11       vicinity of where Mr Duggan had been shot.

          12   A.  Yes.

          13   Q.  Did you actually see him at the time and what he was

          14       doing?  (Pause)

          15           So when you were there at the scene on 4 August,

          16       were you able to see what we can now see on the scene?

          17   A.  I could see him some of the time, sir, and not some of

          18       the time, sir.  I would have to see the video, sir.

          19   Q.  Do you recall that around the time of the video that we

          20       saw he was on the phone?

          21   A.  Yes.

          22   Q.  Were you able to recognise -- and if you cannot possibly

          23       say, simply say -- from that video at times that that

          24       was the period when Z51 was on the phone?

          25   A.  I think it would be, sir.  I might have to look at the


                                           110
 

 

 


           1       video to be precise but I think certainly throughout

           2       that time he was very busy on the phone.

           3   MR BUTT:  Thank you very much.

           4   THE ASSISTANT CORONER:  Ms Leek?

           5                       Questions by MS LEEK

           6   MS LEEK:  Sir, I just have a couple of very short points.

           7           Officer, I represent the Serious Organised Crime

           8       Agency.

           9   A.  Yes.

          10   Q.  I just want to deal with a couple of matters that you

          11       were asked about which were not in the A10 gist.

          12   A.  Yes, okay.

          13   Q.  I think it's fair to say that difficulties can arise

          14       because of gisting --

          15   A.  Yes.

          16   Q.  -- because you can't record specific intelligence that

          17       was passed on to you --

          18   A.  I think that's fair, yes.

          19   Q.  -- and you gist the intelligence so that it can be

          20       disclosed to people in this court room.

          21   A.  Yes.

          22   Q.  Your statement was gisted with the assistance of your

          23       lawyers --

          24   A.  Yes.

          25   Q.  -- and A10's statement was gisted with the assistance of


                                           111
 

 

 


           1       his lawyers.

           2   A.  I'm sure, yes.

           3   Q.  So the precise way in which those statements have been

           4       gisted may not be exactly the same?

           5   A.  Yes.

           6   Q.  The first matter that you were asked about was the

           7       intelligence passed to you on 31 July.  Do you remember

           8       that?

           9   A.  I know the intelligence you are referring to, I am not

          10       sure I received it on 31 July.

          11   Q.  Sorry, the intelligence on 31 July that was passed on to

          12       you after that?

          13   A.  Yes.

          14   Q.  You indicated that you were given intelligence that Mark

          15       Duggan was looking to take possession of one of a number

          16       of firearms.

          17   A.  Yes.

          18   Q.  But in the A10 gist, it simply says that Mark Duggan

          19       wished to collect a firearm.

          20   A.  Yes.

          21   Q.  Can you take it from me that A10 did in fact pass

          22       information on to you but that has gisted it in such

          23       a way that it only refers to picking up a firearm rather

          24       than one of a number of firearms?

          25   A.  That's certainly what I recall him passing to me, yes.


                                           112
 

 

 


           1   Q.  The second related to information on 1 August --

           2   A.  Yes.

           3   Q.  -- and the timings of being able to collect a firearm.

           4   A.  Yes.

           5   Q.  You were read a section from A10's gist --

           6   A.  Yes.

           7   Q.  -- which says that:

           8           "... due to the female's absence at work each day,

           9       he would not be able to gain entry to the premises to

          10       retrieve the firearm until she returned from work some

          11       time mid-to-late evening."

          12   A.  Yes.

          13   Q.  Your recollection was that that was after 9 o'clock each

          14       day.

          15   A.  Yes, that's right.

          16   Q.  Can you take it from me also that A10's statement has

          17       been gisted from 9 o'clock to mid-to-late evening.

          18   A.  I'm sure that's right.  I remember being told 9 o'clock

          19       and that's what I said in the briefing on 3 August.

          20   MS LEEK:  Thank you.  I have no further questions.

          21   THE ASSISTANT CORONER:  Thank you.  Right.  Have you got

          22       many questions at all?

          23   MR KEITH:  I have no questions at all.

          24   THE ASSISTANT CORONER:  That will assist, I know, Mr ZZ17.

          25           Ms Dobbin, anything from you?


                                           113
 

 

 


           1   MS DOBBIN:  Yes.

           2   THE ASSISTANT CORONER:  Unless Mr Glasson has some

           3       questions?

           4   MR GLASSON:  I don't have any questions.

           5   THE ASSISTANT CORONER:  In which case, Mr Underwood, any

           6       other matters to raise?

           7   MR UNDERWOOD:  No, thank you.

           8   THE ASSISTANT CORONER:  Does that conclude ZZ17's evidence?

           9   MR UNDERWOOD:  It does indeed.

          10   THE ASSISTANT CORONER:  Thank you, members of the jury, for

          11       sitting a little bit later but obviously we are now able

          12       to allow ZZ17 to conclude his evidence.

          13           As I say to all the witnesses, please do not discuss

          14       your evidence until this hearing is all completed.

          15       Thank you very much indeed.

          16           We will now turn off the cameras for upstairs.  We

          17       will sit again at 2.15 and, firstly, we will let the

          18       jury then leave.  2.15 then, members of the jury.


         

          25   (1.14 pm)


                                           114
 

 

 


           1                     (The short adjournment)

           2   (2.16 pm)

   

           8                  (In the presence of the jury)

           9   THE ASSISTANT CORONER:  Thank you very much, members of the

          10       jury.

          11           I'll ask Mr Underwood then to call the next witness.

          12   MR UNDERWOOD:  Can I recall Detective Superintendent Mallon,

          13       please?

          14            DETECTIVE SUPERINTENDENT MALLON (recalled)

          15   THE ASSISTANT CORONER:  Please have a seat.  You are still

          16       under the oath or affirmation you took before, you do

          17       not need to be resworn.

          18   A.  Yes.

          19                    Questions by MR UNDERWOOD

          20   MR UNDERWOOD:  Detective Inspector, there was this

          21       apparently very mysterious piece of Post-it note stuck

          22       over a page of your notebook last week and we have now

          23       managed to find a copy that does not have a Post-it note

          24       on.  Do you have a copy of that in front of you now?

          25   A.  Yes, thank you, yes.


                                           115
 

 

 


           1   Q.  We can put that up on screen.  I think this is

           2       a left-hand, is it, page from your book?

           3   A.  Yes, that is, yes.

           4   Q.  Can I just get you to read out what is in fact the entry

           5       after the darker ink entry for the jury, please?

           6   A.  On the left-hand side it says:

           7           "MM call.  5.30 pm.  Entered update.  Picked gun up

           8       and bringing it to Farm.  Gave address and picked him

           9       up.  Continue op.  Authority ongoing.  Tactics and TA

          10       review."

          11   Q.  Right.  Did you make that entry at 5.30 or did you make

          12       it later on?

          13   A.  No, I made it when I found out that Mark Duggan had been

          14       shot.  I made it as part of the phone call at 6.20 pm.

          15   Q.  What was the purpose of making this note?

          16   A.  As Strategic Firearms Commander, it's my responsibility

          17       to make a record and be accountable for what happens on

          18       my operation that I'm in charge of.  So I was in the

          19       position of having to make a record of what had happened

          20       but also managing the restrictions around intelligence

          21       and how to be record it.  So I decided that from 6.20

          22       onwards I made a record of the conversation with the

          23       TFC, Z51.  I gave more detail on the left-hand page and

          24       put the reference to the phone call at 5.30 as a record.

          25   Q.  Right.  Of course, we've heard that the intelligence


                                           116
 

 

 


           1       that was passed on at 5.20 which reached Z51 at about

           2       5.25 was that Mr Duggan was planning to pick up a gun

           3       and that steps were in place to get surveillance on him

           4       at that point.

           5           This says "picked up gun", so the tense is

           6       different.  What was the reason for that?

           7   A.  It's intelligence, it's gisting it, it's -- my recall

           8       was that he was actively trying to get possession then

           9       of a firearm and I gisted it to make sure it was safe.

          10   Q.  Were you being told what Z51 was being told, that the

          11       intelligence said that Mr Duggan was proposing to pick

          12       up the gun rather than that he had picked it up?

          13   A.  Yes.

          14   Q.  Thank you very much.  In terms of where that was going

          15       to happen, you used the word "address" there, did you

          16       actually have an address?

          17   A.  No, no.

          18   MR UNDERWOOD:  Very well.  That's all I want to ask about

          19       that, unless there are any other questions.

          20   THE ASSISTANT CORONER:  Yes, Mr Mansfield?

          21                    Questions by MR MANSFIELD

          22   MR MANSFIELD:  Yes, please, just one matter.  You have

          23       a 5.30 time there, the "5.30" time near the "Z51", you

          24       see --

          25   A.  Yes.


                                           117
 

 

 


           1   Q.  -- on the document there.  You've indicated that you did

           2       have a phone call at 5.30.

           3   A.  (Nods)

           4   Q.  What you originally said about the phone call at 5.30,

           5       and it's in your statement -- do you have your statement

           6       still there?

           7   A.  I have a copy, yes.

           8   Q.  Could you just look at it.  This was essentially your

           9       evidence the other day.  It's page 10 of your statement.

          10       At approximately 5.30 -- sorry, I'll wait until you've

          11       got the page.

          12   A.  Yes.

          13   Q.  I just want to clarify this.  It's just in relation to

          14       the jotting at the side of the page, just to check with

          15       you:

          16           "The phone call with Z51 at 5.30 ..."

          17           This is how you put it in your statement:

          18           "... was to inform me that the operational team had

          19       just received intelligence that Mark Duggan was in

          20       possession of a gun and they were trying to locate him."

          21           That's what your statement says.  Is that 5.30

          22       reference there to that piece of information?

          23   A.  Yes.  That's reflected in the 5.30 -- it's an ongoing

          24       record from 6.20 --

          25   Q.  Yes, I follow that, but that's what it refers to?


                                           118
 

 

 


           1   A.  Yes.

           2   MR MANSFIELD:  Thank you.

           3   THE ASSISTANT CORONER:  Other questions at all?

           4   MR KEITH:  No thank you.

           5   THE ASSISTANT CORONER:  Mr Butt?

           6                       Questions by MR BUTT

           7   MR BUTT:  Just so we are clear, there was only one phone call

           8       from Z51 at around about 5.30, wasn't there, to you?

           9   A.  Yes.

          10   Q.  Do you think that could have been, in fact, at 5.40

          11       rather than 5.30?

          12   A.  Give or take a minute realistically, yes.  Yes, it could

          13       have been.

          14   Q.  What he told you was something like:

          15           "Mark Duggan intends to take a gun imminently in the

          16       Leyton area."

          17   A.  My recollection was it was imminent and he was actively

          18       taking possession at that time.

          19   Q.  That he was going to do that not that he had done that?

          20   A.  That he was going to do it, actively trying to do it,

          21       yes.

          22   MR BUTT:  Thank you very much.

          23   THE ASSISTANT CORONER:  Yes, Ms Dobbin?  Ms Leek?  Mr Keith?

          24       Mr Stern?  No, no one else.

          25   MR UNDERWOOD:  Nothing arising.


                                           119
 

 

 


           1   THE ASSISTANT CORONER:  I'm sorry, you've been waiting

           2       around all morning for a short reappearance.  But anyway

           3       thank you very much for coming back and clarifying that

           4       matter for us.  That's very important that we do so.

           5       Thank you very much indeed.

           6   A.  Thanks.

           7                      (The witness withdrew)

           8   MR UNDERWOOD:  Sir, the next witness is ZZ46 who is

           9       anonymised and we will need to --

          10   THE ASSISTANT CORONER:  We will need to go through the

          11       procedures whereby the jury and I leave court for

          12       a short time and then come back into the court.  I'm

          13       sorry about this, members of the jury.  It may be we can

          14       do this comparatively quickly.  It may be you wouldn't

          15       need to go right back down to your room but simply stand

          16       outside court for a short time.  Thank you very much.

          17       Let's turn the cameras off, please.

 

 

 

 

 

 

 

 

 


                                           120
 

 

 


          

           2   (2.26 pm)

           3                         (A short break)

           4   (2.30 pm)

          

           7                  (In the presence of the jury)

           8   THE ASSISTANT CORONER:  I will ask for the witness to come

           9       into court then, please.

          10                         ZZ46 (affirmed)

          11                   (The witness was anonymised)

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

          13       and we will put the cameras on upstairs.  I think you

          14       are being provided with a list of the other officers who

          15       have anonymity.  Can I just ask you to confirm against

          16       your number, ZZ46, does your true name appear?

          17   A.  Yes, sir.

          18   THE ASSISTANT CORONER:  Good, thank you very much.

          19           Over to Mr Underwood then.

          20                    Questions by MR UNDERWOOD

          21   MR UNDERWOOD:  Good afternoon, my name is Underwood, I'm

          22       counsel to the Inquest and I have some questions for you

          23       to start with.

          24           I think you are a Detective Constable, or at least

          25       you were, in 2011.


                                           121
 

 

 


           1   A.  Yes, I still am.

           2   Q.  Working in Trident?

           3   A.  Yes, that's correct.

           4   Q.  I want to ask you about events of 4 August, but before

           5       I do that I want to ask you whether you did some

           6       research into individuals who may potentially have been

           7       involved --

           8   A.  Yes, I did.  I did, sir.

           9   Q.  Thank you very much.  In relation to research in

          10       relation to Mr Duggan, when did you start doing that?

          11   A.  Sorry, in what respect?

          12   Q.  We know that there was an operation that was going to

          13       run from 3 to 6 August in relation to six TMD people,

          14       one of whom was Mr Duggan.  What I'm interested in is

          15       whether you did any research which related to Mr Duggan;

          16       do you follow?

          17   A.  Yes.

          18   Q.  When did you start doing that?

          19   A.  On 2 August, it would have been.

          20   Q.  Thank you.  Can we have on screen CD32787.  I don't know

          21       whether you have a hard copy of this.

          22   A.  I do, may I refer to it?

          23   Q.  Please.

          24   A.  Thank you.

          25   Q.  First of all, what is this?


                                           122
 

 

 


           1   A.  This is a copy of my day book, it's a handwritten note

           2       of a book I would have kept at the time.

           3   Q.  Right.  Does it have in it material which you wrote down

           4       as a result of research that you did from 2 August on?

           5   A.  Yes, that's correct.

           6   Q.  We have black lines and we have written in things like

           7       "reg plate", "DoB", and so on.  Do you understand we

           8       have done that because a whole lot of names were thrown

           9       up of perfectly innocent people who have nothing to do

          10       with anything --

          11   A.  I understand that.

          12   Q.  -- and we are just keeping those out of the public eye?

          13   A.  Yes.

          14   Q.  Start from the top left.  You have "MD" there and then

          15       "Kevin", and then under that you've got "Juv" who we

          16       later see is Juvanne Miller.  What was the starting

          17       point for your research?

          18   A.  The starting point was from ZZ17.  He asked me to see if

          19       I could do some research to find a Kevin that may or may

          20       not be an associate of a Juv Miller; that was my

          21       starting point.

          22   Q.  Did you have a phone number for Juvanne Miller?

          23   A.  I didn't.

          24   Q.  Your only starting point was two names, one of which was

          25       "Kevin"?


                                           123
 

 

 


           1   A.  Two names -- yes, that's correct.

           2   Q.  What were you supposed to do with that?

           3   A.  Just use the systems that were available to me and see

           4       if I could find either/or on our systems and see if

           5       I could find any tie between "Kevin" and "Juv Miller".

           6   Q.  With a view to finding out who Kevin was or what?

           7   A.  Yes.  That was what I was asked by ZZ17 to do --

           8   Q.  Right.

           9   A.  -- to conduct research to see if I could identify these

          10       people.

          11   Q.  Okay.  Let's just track through and see where you got

          12       from that.  On the right-hand side, there's a number,

          13       "06/[et cetera et cetera]".  Can you recall what that's

          14       about?

          15   A.  That's a PNC ID number.

          16   Q.  For Juvanne Miller?

          17   A.  Yes, that's correct.

          18   Q.  That gives you then the house number, does it, in

          19       Broad Lane, N15?

          20   A.  That's correct, I would have got the address from that.

          21   Q.  You have then got the full name --

          22   A.  Yes --

          23   Q.  -- and then her date of birth.

          24   A.  -- and the date of birth.

          25   Q.  We then get to a car; is that to do with her or what?


                                           124
 

 

 


           1   A.  That's to do with him, and it's -- sorry -- I also use

           2       another system, which is called IIP, and on that system,

           3       I would have put in the same details and that is -- it's

           4       a Met-wide database that basically uses lots of

           5       different -- all the different things that we use to

           6       search upon.  I would have put that in and from that

           7       I would have found out that he was stopped in Chelmsford

           8       in August 2010 in a black Clio.

           9   Q.  Right.  By this stage you only knew he was Kevin though,

          10       did you, or had you --

          11   A.  Sorry, that is -- that relates to a stop of Miller.

          12   Q.  Right.  Okay.  So you have got her name, you have

          13       an address --

          14   THE ASSISTANT CORONER:  Is it him or her, is there confusion

          15       here: Juvanne?

          16   A.  It's a him.

          17   MR UNDERWOOD:  It's a him, I'm so sorry.  You've got his

          18       name, his address, his date of birth, a link to a car

          19       because he was stopped in it.

          20   A.  He was stopped in it, yes.

          21   Q.  Then you have the fact that was scrapped on the right,

          22       there.

          23   A.  Yes.

          24   Q.  Then you've got an associate to do with that car.

          25   A.  Yes.  It was the other person that was stopped in that


                                           125
 

 

 


           1       car in August 2010 with Mr Miller.

           2   Q.  Right.  That was a blank though, was it?  That was not

           3       the "Kevin".

           4   A.  That was completely unrelated.

           5   Q.  Right.  Then next we go down to VODS, what does VODS

           6       mean?

           7   A.  VODS is a system -- it's a check that we can do on the

           8       PNC.  You can put in the index -- sorry, correction --

           9       you can put in the postcode and what that does is that

          10       brings up all of the cars that are registered to that

          11       postcode and then you can search down for a door number.

          12   Q.  So here, having got Juvanne Miller's address, you have

          13       done a VODS search on that to see what cars were

          14       connected to that address?

          15   A.  Are registered at that address, yes, that's correct.

          16   Q.  Then we see some names against registration plates

          17       there.  No Kevins; is that right?

          18   A.  That's correct.

          19   Q.  Then underneath that "Voters"; is that voters for that

          20       house number?

          21   A.  That would also be, yes.  We can also conduct a voters

          22       search to see who's registered as a voter at an address,

          23       so I would have conducted that for the address above.

          24   Q.  We've got three names and then another name we have

          25       taken out, because it's nothing to do with us at all,


                                           126
 

 

 


           1       where you've got the word "Voter" in and, again, no

           2       Kevins there?

           3   A.  No, that's correct.

           4   Q.  Then over the page, 32788, you've got a reference top

           5       right "M356", et cetera, et cetera; what's that

           6       a reference to?

           7   A.  That was an index of a vehicle that Mr Miller had also

           8       been stopped in.

           9   Q.  Okay.  Then you've got "Hutchinson-Foster", "Kevin

          10       Hutchinson-Foster", and some more details; how did you

          11       get to that?

          12   MS LEEK:  Sorry, I wonder if I may stop for a moment.  Have

          13       you put up the wrong version, because the version we

          14       were given this morning was redacted.  (Pause)

          15           We've not been given the latest version then.  Okay,

          16       I shall sit down then.

          17   MR UNDERWOOD:  Panic over.

          18   THE ASSISTANT CORONER:  Hutchinson-Foster: how did you get

          19       to him, or her?

          20   A.  The way I got to him was as I was explaining, the IIP

          21       search that I can do.  I put in Kevin and Juvanne Miller

          22       as a combined search and from that I found that there

          23       was a Kevin Hutchinson was arrested with Juvanne Miller

          24       in 2007.  So from then, I wrote down the details of

          25       Kevin Hutchinson, with the date of birth and the address


                                           127
 

 

 


           1       on that report from that arrest.

           2   Q.  Right.  We've got "Hutchinson-Foster" in brackets; is

           3       this something you put in later?

           4   A.  Yes.

           5   Q.  So then you've got what was an address for, what, 2007,

           6       for Mr Hutchinson at that point?

           7   A.  Yes.  It would -- it was the address that was given when

           8       he was arrested in 2007.

           9   Q.  Right.  Then you've got a provisional licence for

          10       Juvanne Miller.

          11   A.  For Mr Miller, yes.

          12   Q.  Then "LKA"?

          13   A.  Last known address.

          14   Q.  For whom?

          15   A.  Mr Hutchinson.

          16   Q.  That's the 39 Blurton Road, is it, in E5?

          17   A.  That's correct.

          18   Q.  Then you have "numerous on voters"?

          19   A.  I do apologise for my writing.  "Numerous on voters",

          20       yes.  That would --

          21   Q.  We have doctors to come yet so don't apologise for your

          22       writing.

          23   A.  I would have done a voters check on that address and

          24       again have written "numerous on voters".

          25   Q.  Then there's a release date, is that 8 April 2011 and


                                           128
 

 

 


           1       "supervision ends"?

           2   A.  9 July 2013.  Yes, that's correct.

           3   Q.  So you knew by halfway down the second page then that

           4       you have a Kevin Hutchinson, who was released from

           5       prison on 8 April, still under supervision until 9 July,

           6       in fact, of this year?

           7   A.  Yes, that's correct.

           8   Q.  Then we go down, you've got a car, a silver Corsa,

           9       "DS04", and the rest of the number plate has been taken

          10       out --

          11   A.  Yes.

          12   Q.  -- registered to a Nadine White?

          13   A.  Yes, that's correct.

          14   Q.  How does that come about?

          15   A.  Kevin Hutchinson was stopped in that vehicle.  I believe

          16       it was an ANPR (?) operation, but he was stopped in that

          17       vehicle so, again, I did relevant research on that car.

          18   Q.  Right.  Do we have a date for that on here?

          19   A.  Not on here.  No.

          20   Q.  Right.  Then over on the right-hand side you have more

          21       information about what I take to be a lady, Nadine

          22       White?

          23   A.  Yes.

          24   Q.  Then a phone number again for that person --

          25   A.  Yes, that's correct.


                                           129
 

 

 


           1   Q.  -- from March 2011.

           2   A.  Yes, that's correct.

           3   Q.  Then another "Kevin" crops up with a date of birth --

           4   A.  Yes.

           5   Q.  -- is that a dead end?

           6   A.  Yes.  I -- yes, I haven't no idea where that came from

           7       or where it was going but, yes, I've obviously written

           8       it down for some reason.

           9   Q.  All right.  If we go over the page, 2008, is that "GD

          10       drugs squad"?

          11   A.  Yes.

          12   Q.  What is that a reference to?

          13   A.  "GD" is Golf Delta -- is what we would refer to Hackney.

          14   THE ASSISTANT CORONER:  Sorry, I missed that.  Refers to?

          15   A.  "GD" would be Golf Delta, which is Hackney borough.

          16   THE ASSISTANT CORONER:  Thank you.

          17   MR UNDERWOOD:  Then we have an address in E8, is that to do

          18       with a drugs operation?

          19   A.  This is -- yes.  That address there was where the drug

          20       squad did an operation in 2008.

          21   Q.  Has that to do with Mr Hutchinson-Foster?

          22   A.  It does.

          23   Q.  Then top right, you have done some work on Blurton Road

          24       and you found out there's a subsequent resident there

          25       now; is that right?


                                           130
 

 

 


           1   A.  Yes, that's correct.

           2   Q.  So then you checked that address, the 2008 address, have

           3       you?

           4   A.  Then, from the arrest at -- for room 6, I have then

           5       found that there were two other parties at that address

           6       on that date, as well as Hutchinson-Foster.

           7   Q.  One of whom was a minor, I see:

           8           "Minor at address."

           9   A.  That's correct, yes.

          10   Q.  The final entry on that page has a number, do you know

          11       what that is?

          12   A.  That's a CRIS report, a crime report number.

          13   Q.  That has Juvanne Miller and Kevin Hutchinson as cousins;

          14       is that correct?

          15   A.  That's correct, yes.

          16   Q.  Is that as far as your research was able to carry you?

          17   A.  Yes.

          18   Q.  Was all this done on the 2nd?

          19   A.  Yes this was done on the 2nd.

          20   Q.  Did you report that back up the chain?

          21   A.  Yes, I did.

          22   Q.  Was any other research facility available to you that

          23       you didn't use?

          24   A.  From -- most of the research that I would do would be

          25       using the IIP database or PNC.  The IIP, as I say, does


                                           131
 

 

 


           1       a Met-wide search of all of the databases available to

           2       me, and they were the ones that I used and, more often

           3       than not, used as opposed to anything else.

           4   THE ASSISTANT CORONER:  Does it include records held by

           5       probation?

           6   A.  No, it doesn't.

           7   THE ASSISTANT CORONER:  Because the probation if they are

           8       supervising him on licence would have an address for

           9       him, wouldn't they?

          10   A.  That's correct.  I didn't speak to probation I would

          11       have had to have spoken to probation to find that out.

          12       It wasn't held on PNC.  PNC generally has the most

          13       recent address on there.

          14   MR UNDERWOOD:  Your task was to look through the databases

          15       available to you, was it?

          16   A.  And to see if I could locate or find who "Kevin" was.

          17   Q.  We have already seen on that second page that when you

          18       found Kevin Hutchinson you later wrote in

          19       "Hutchinson-Foster".

          20   A.  Yes.

          21   Q.  When did you actually write that in; can you recall?

          22   A.  I can't recall without looking through some bits here,

          23       but it was later on, because, as I was searching for

          24       "Hutchinson", I then found a research docket which had

          25       "Hutchinson-Foster" written on it as an additional name.


                                           132
 

 

 


           1   Q.  Could you help us with what date that was?  Was it

           2       2 August?

           3   A.  Oh, it was still on 2 August, yes.

           4   Q.  By whatever time you clocked off on 2 August, this is

           5       how far you got: you had identified Kevin

           6       Hutchinson-Foster, hadn't identified a current

           7       address --

           8   A.  Yes, that's correct.

           9   Q.  -- you have identified a cousin --

          10   A.  Yes.

          11   Q.  -- and you had identified at least one car associated

          12       with him at some point?

          13   A.  Yes, that's correct.

          14   Q.  Then can we go to CD32790, please?  This is so heavily

          15       changed in order to protect people's names that you may

          16       not recognise it.

          17   A.  Yes.

          18   Q.  Do you have the original?

          19   A.  I have got the original, yes.

          20   Q.  Is this part of your work?

          21   A.  Yes, it is.

          22   Q.  What does it represent?

          23   A.  This was a list of initials that I wrote down relating

          24       to members of the TMD that we were looking at -- of the

          25       Tottenham Man Dem that we were looking at under


                                           133
 

 

 


           1       Operation Dibri.

           2   Q.  Has that got to do with this research or not?

           3   A.  No.  This was just an additional page.

           4   Q.  Right.  Can we move on then to the events of the 4th?

           5   A.  Yes.

           6   Q.  Sorry, before I do that, can I just deal briefly with

           7       the 3rd: were you on duty on the 3rd and part of the

           8       briefing?

           9   A.  Yes, I was.

          10   Q.  On the 4th, were you on duty at Quicksilver before 5.20?

          11   A.  Yes, I was.

          12   Q.  What were you doing there?

          13   A.  I was doing some research and preparation for that day.

          14   Q.  Did you become aware of the intelligence that ZZ17

          15       picked up at 5.20 or so?

          16   A.  Yes.

          17   Q.  What did you do?

          18   A.  I -- on the request of ZZ17, I went to the Leyton area

          19       of London.

          20   Q.  Who were you with?

          21   A.  I was with ZZ75.

          22   Q.  In what sort of vehicle?

          23   A.  A blue Volkswagen Passat.

          24   Q.  Did you know that ZZ37 was also en route to the same

          25       area?


                                           134
 

 

 


           1   A.  I did know that, yes.

           2   Q.  Did you know where you were going when you left?

           3   A.  No, I didn't, just to the Leyton area.

           4   Q.  Where did you go?

           5   A.  We drove over to Leyton and then, while we were en route

           6       to Leyton, I was updated by ZZ17 to go to the Vicarage

           7       Road area of Leyton, which is where I ended up.

           8   Q.  Right.  How specific was that in terms of the Leyton

           9       Road area -- sorry, the Vicarage Road area?

          10   A.  It was the Vicarage Road area.

          11   Q.  Where did you actually end up?

          12   A.  I parked in Farmer Road.

          13   Q.  Right.

          14   A.  Sorry, I should say we parked in Farmer Road.

          15   Q.  What were you anticipating was going to happen?

          16   A.  We were anticipating that there was going to be a car

          17       containing Mark Duggan in that area collecting -- or

          18       having collected a firearm.

          19   Q.  Before you got there, did you know the registration

          20       number of that?

          21   A.  I didn't, no.

          22   Q.  Were you in radio contact, while you were en route, with

          23       ZZ37 as well as ZZ17?

          24   A.  Yes, we would have been.

          25   Q.  Did you become aware of what turned out to be the


                                           135
 

 

 


           1       minicab from ZZ37?

           2   A.  Yes, I did.

           3   Q.  Did he tell you what it was doing?

           4   A.  Yes, he did.

           5   Q.  Can we look, please, at CD32791?  It's a further page of

           6       your day book, I think --

           7   A.  Yes, that's correct.

           8   Q.  -- is that right?

           9   A.  Yes, that is correct, sir.

          10   Q.  If I read it right it starts:

          11           "Into Burchell Road."

          12   A.  It's actually an L.  I don't know whether it's come

          13       across but that at the top is:

          14           "L into Burchell Road."

          15   Q.  Left into Burchell Road?

          16   A.  Yes.

          17   Q.  How did you come by that information?

          18   A.  I would have been told that by 37.

          19   Q.  Then "66" on the right; what's that about?

          20   A.  "66" would relate to -- as I went on to give commentary,

          21       if somebody -- while you are giving commentary, if

          22       somebody else wants to speak to you they would ask you

          23       for permission.  So it's asking for permission to cut in

          24       on what you are saying.  So they would have called up me

          25       and said "Permission 66".  I would have then written


                                           136
 

 

 


           1       that down so that when there was an opportunity for them

           2       to talk, I could have then remembered their call sign to

           3       call them back and say "Yes 66, ahead".

           4   Q.  Then you've got "R343 KPE, bronze Hiace"; how did you

           5       come by that information?

           6   A.  That was the index of the minicab that I followed that

           7       ZZ37 had put up.

           8   Q.  Have we got this picture then: you are parked up in

           9       Farmer Road --

          10   A.  Yes.

          11   Q.  -- ZZ37 says, in whatever order --

          12   A.  Yes.

          13   Q.  -- "Minicab turns left into Burchell Road and here is

          14       what it is and here is its index number"?

          15   A.  Yes, that's correct.

          16   Q.  Did there come a point when you started following that?

          17   A.  Yes, I did.

          18   Q.  What happened, how did that that come about?

          19   A.  The minicab travelled towards us -- Farmer Road is at

          20       the bottom of Vicarage Road and we were facing towards

          21       a mini roundabout.  The vehicle came down Vicarage Road

          22       towards us and it turned right into -- I think it was

          23       Park Road, and as it turned right into Park Road,

          24       obviously once it was safe in a surveillance capacity

          25       for us to do so, we started to follow it.


                                           137
 

 

 


           1   Q.  So your car was either directly or indirectly behind,

           2       but the first of the following vehicles; is that right?

           3   A.  Yes, that's correct.

           4   Q.  Were you aware that other Trident vehicles were

           5       following you?

           6   A.  I was aware that there were other people coming to us.

           7       I didn't know where they were, who they were or how --

           8       where they were in conjunction with where we were.

           9   Q.  Right.  Were you commentating on the follow, as it were?

          10   A.  I commentated during the follow, as I was the passenger

          11       in the car.

          12   Q.  As far as you were concerned, who were you communicating

          13       with, who were you telling this?

          14   A.  I was telling this to the other officers that were out,

          15       so other Trident officers, the surveillance team and

          16       also CO19.

          17   Q.  Right, and ZZ17 as well?

          18   A.  And 17, yes.

          19   Q.  Did you become aware that the rest of these teams were

          20       on the road somewhere?

          21   A.  Yes, I was aware that they were about or coming to us.

          22   Q.  Right.  Were you anticipating that the CO19 officers

          23       would catch you up and take over?

          24   A.  Yes.

          25   Q.  Is that what happened?


                                           138
 

 

 


           1   A.  Yes.

           2   Q.  So there came a point, did there, when amber was called?

           3   A.  Yes, that's correct.

           4   Q.  Where were you in relation to the minicab at that point?

           5   A.  Still following it.

           6   Q.  Can you recall where you were exactly?  (Pause)

           7   A.  I think we had crossed the junction with Lea Bridge Road

           8       into Markhouse Road and it was around about that

           9       location, before we went into St James's Street, that

          10       the state amber was called.

          11   Q.  Okay.  Were you aware of the CO19 cars behind you at

          12       that point?

          13   A.  No.

          14   Q.  Were you aware when red was called?

          15   A.  Yes, I was.

          16   Q.  Were you aware of the CO19 cars then?

          17   A.  Yes.

          18   Q.  Were they behind you or in front of you by that point?

          19   A.  They drive past -- as soon as state red is called, we

          20       get out the way.  From state amber, you enhance your

          21       commentary so that they know exactly where you are and

          22       exactly what's happening.  Then once state red is called

          23       you get out of the way and let the CO19 come through

          24       past you, which is what they did, they drove past us on

          25       our offside.


                                           139
 

 

 


           1   Q.  Did you see the stop?

           2   A.  I saw -- yes, I saw the minicab was stopped.

           3   Q.  How far were you from it?

           4   A.  Maybe from here to the back of the room.  (Indicates)

           5   Q.  Were the CO19 cars and the control car between you and

           6       it?

           7   A.  Yes.

           8   Q.  Were you on the same side of the road as the control

           9       car?

          10   A.  Yes.

          11   Q.  So did you see the Alpha car go past and pull in --

          12   A.  Yes.

          13   Q.  -- and the Bravo cargo on the outside?

          14   A.  (Nods) I was aware of four cars going past us.  As is

          15       protocol, we don't get in their way.  They have called

          16       state red.  That is our time, if you like, to get out of

          17       the way.  We've got them there, state red is called and

          18       you get out of the way.  So they had all gone past and

          19       then they blocked my view.

          20   Q.  Can I just understand what's supposed to happen in

          21       a MASTS operation that goes perfectly to plan.  The CO19

          22       officers will jump out and dominate the people in the

          23       vehicle; is that right?

          24   A.  Yes.

          25   Q.  Who formally conducts an arrest and reads people their


                                           140
 

 

 


           1       rights, all that sort of thing?

           2   A.  That would be us, so the team that are in support of

           3       CO19.  But we would only ever go forward once we were

           4       called forward by CO19.

           5   Q.  Right.  That didn't happen here, I take it, you were not

           6       called forward?

           7   A.  No.

           8   Q.  Sorry, I have taken that out of order --

           9   A.  That's --

          10   Q.  So you saw the vehicles do their manoeuvres for a hard

          11       stop.

          12   A.  Yes.

          13   Q.  Can you, in your own words now, please take us through

          14       what you saw and heard in terms of Mark Duggan and

          15       shooting?

          16   A.  I saw the firearms team get out of their vehicles.  They

          17       ran towards the pavement but, as I say, the control

          18       vehicle was blocking my view.

          19           I remained in my vehicle, so as passenger in my

          20       vehicle.  I then heard what I believed to be a number of

          21       gun shots, obviously remained in the car, and it wasn't

          22       until one of the firearms officers from that team

          23       were -- came running towards me, asking me to call

          24       an ambulance, because an officer had been shot.

          25   Q.  So you didn't see Mr Duggan at all --


                                           141
 

 

 


           1   A.  I didn't.

           2   Q.  -- at that stage at least?

           3   A.  No, I didn't.

           4   Q.  Did you go forward at any stage and see him?

           5   A.  No.

           6   Q.  Did you then assist in dealing with civilians and

           7       cordons and so on?

           8   A.  Yes, I did.

           9   MR UNDERWOOD:  Thank you very much.  That's all the

          10       questions I've got but you will be asked more questions.

          11   A.  Thank you.

          12   THE ASSISTANT CORONER:  Thank you very much.

          13           Yes, Mr Mansfield?

          14                    Questions by MR MANSFIELD

          15   MR MANSFIELD:  Good afternoon, my name is Michael Mansfield,

          16       I represent the Mark Duggan family.

          17   A.  Good afternoon.

          18   Q.  Just a few questions.  Can I just go back to the

          19       beginning a bit in terms of your intelligence work and

          20       research.  Were you in fact part of the intelligence

          21       unit at Trident?

          22   A.  No, I wasn't.

          23   Q.  You were not an intelligence officer --

          24   A.  No.

          25   Q.  -- alongside ZZ17?


                                           142
 

 

 


           1   A.  No, I was on ZZ17's team as a DC and I did the research

           2       as and when I was required to.

           3   Q.  Yes.  I just want you to glance at a document to see

           4       whether you can help about it.  If you look in the

           5       bundle that you have, the jury bundle, a red bundle,

           6       it's divider 9, C9.  This is a compilation of

           7       intelligence from somebody only known as A10, but

           8       working for SOCA, Serious Organised Crime Agency.  Now,

           9       that agency you are obviously familiar with.

          10   A.  Yes, I am.

          11   Q.  Before 2 August, that's when you say you were tasked,

          12       did you -- if you just run your eye down that page --

          13       were you aware of the intelligence relating to a man

          14       called Kevin or Kevin Hutchinson-Foster before 2 August?

          15       (Pause)

          16   A.  No, I wasn't.

          17   Q.  So when you were tasked by ZZ17 on 2 August, he didn't

          18       tell you what he already knew about Hutchinson-Foster?

          19   A.  No, he asked me to conduct research to see if I could

          20       find a "Kevin".

          21   Q.  "Find a 'Kevin'"?

          22   A.  "Kevin", as an associate of Juv Miller.

          23   Q.  Right.  Did he explain why that connection was being

          24       made with a man called Miller?

          25   A.  From recollection, no.


                                           143
 

 

 


           1   Q.  So would it be right to say when you conducted the

           2       research that you had no idea that the person "Kev" or

           3       "Kevin Hutchinson-Foster", was somebody who might be

           4       storing a gun or might be wanting to pass a gun to

           5       Mr Duggan?

           6   A.  Again, from recollection, no.

           7   Q.  No.  No, sorry, I am not suggesting --

           8   A.  No -- that's fine.

           9   Q.  I'm just wanting to get to what was actually the

          10       position.  So ZZ17 asked you to look at a "Kev" or

          11       "Kevin" in connection with a man called "Miller".  Now,

          12       did he ever say -- sorry to go through it in stages --

          13       did he ever say to you "Look we really need to know

          14       where Kevin is?"

          15   A.  He would have asked for -- what would normally happen

          16       was it would be, "Can you conduct research and see if

          17       you can find an address, associates, a vehicle", that is

          18       what I would normally be looking for when conducting

          19       research, which is exactly what I would have been

          20       looking for on this occasion.

          21   Q.  Just pause for a moment.  If you look at the documents

          22       you have, you don't have to go through them, that's all

          23       historic information, isn't it?

          24   A.  It was all historic, yes.

          25   Q.  Yes.  I want to be precise.  Did ZZ17 say to you "That's


                                           144
 

 

 


           1       all very interesting but I want to know is there any

           2       information about where this man is now?"  Did he ever

           3       say that to you?

           4   A.  He would have asked me and the answer would have been --

           5       and from reading through this -- I never found anything

           6       other than historical information on him.

           7   Q.  Can I put it this way: would it be for you to say to

           8       yourself, or ZZ17, "Look, this is all historic but there

           9       is a way of discovering where he is now"?

          10   A.  How would I have done that?

          11   Q.  Well, that's why I asked if you were in the intelligence

          12       unit there or other officers.  The learned Coroner has

          13       actually pointed it out to you.  This man had a criminal

          14       record, didn't he?

          15   A.  In relation to the probation?

          16   Q.  Yes.

          17   A.  I didn't ring probation.

          18   Q.  You could have done.

          19   A.  Yes, you're right, I could have done and I didn't.

          20   Q.  I am not suggesting it's your responsibility but you

          21       gave all of this information to ZZ17 --

          22   A.  Yes.

          23   Q.  -- so he could read through it --

          24   A.  Yes.

          25   Q.  -- and he never said "Look, ring probation, we can find


                                           145
 

 

 


           1       out where he is"?

           2   A.  He didn't, but to be fair to ZZ17, he didn't have to

           3       tell me to do something, I could have done that myself.

           4   Q.  But it didn't occur to you?

           5   A.  No, it didn't.

           6   Q.  Because you didn't know the context in which he needed

           7       to know about "Kevin" or "Kev", did you?

           8   A.  No.  But I still would have -- I would like to think

           9       that I would have searched all avenues.

          10   Q.  Yes.  I appreciate you might like to think that you

          11       would have but, you see, looking at the A10 information

          12       there is, as it goes through -- if you just look back on

          13       that sheet of paper, you'll see by this date, that is

          14       2 August -- we don't know the time yet, perhaps the next

          15       witness will be kind enough to tell us.  However, on

          16       2 August there was credible information that the person

          17       was likely to be Kevin Hutchinson-Foster and that he

          18       wasn't going to be in London that evening and so Mark

          19       Duggan couldn't meet with him.  This is all in the

          20       context of collecting a gun.  But you didn't know any of

          21       that, did you?

          22   A.  No.

          23   Q.  No.  You see, if somebody is acting as a store place --

          24       Kevin Hutchinson-Foster -- for guns -- not perhaps at

          25       his own address but somewhere else -- and there's likely


                                           146
 

 

 


           1       to be somebody passing a gun from one to the other, it's

           2       really rather imperative you find out as much as you can

           3       about the whereabouts of this "Kevin", isn't it?

           4   A.  I had found out as much as I could from the indices that

           5       were available to me.  There would have been an address

           6       on PNC and more often than not that would have shown the

           7       release address from prison.

           8   Q.  Right.  What was it?

           9   A.  There wasn't a release address from prison on the PNC.

          10       It would have been one of the addresses that I've

          11       written down.

          12   Q.  You would have written it down if there was --

          13   A.  In my notes.

          14   Q.  -- but the only other way of getting a release address

          15       is to ring up probation?

          16   A.  It would have been.

          17   Q.  In fact, he was at a hostel; do you know that now?

          18   A.  No, I don't.

          19   Q.  In addition to finding out about a hostel and

          20       an address, of course telephone numbers can be quite

          21       important, can't they?

          22   A.  Yes.

          23   Q.  Did you discover any telephone numbers related to this

          24       man?

          25   A.  No, I didn't.


                                           147
 

 

 


           1   Q.  Are you sure?

           2   A.  Yes.

           3   Q.  Mobile?

           4   A.  No.

           5   Q.  Landline of any kind?

           6   A.  No.

           7   Q.  Did you look for that?

           8   A.  I would have, again, looked for it in my research but,

           9       as I say, most of the research that I found on him was

          10       of a historical content.

          11   Q.  Yes, I appreciate that.  The reasons for asking you is

          12       in relation to how this whole matter was planned.

          13       That's why I'm asking you the questions.

          14           You see, another way of getting a number might be

          15       through the probation service, because they might have

          16       a number for him.

          17   A.  Yes, that's correct, they might have done.

          18   Q.  You didn't ring them up for that either?

          19   A.  I didn't ring them up, no.

          20   Q.  In addition to a number for him -- I mean a mobile

          21       number -- you have information about a car, but again

          22       it's historic.

          23   A.  Which car?

          24   Q.  Isn't there a registration number amongst the documents?

          25   A.  There was a couple, yes.


                                           148
 

 

 


           1   Q.  Yes, there was a couple.  But I put it in quick form,

           2       it's historic so it's not helping you about whether he's

           3       got a car upon his release?

           4   A.  No.  As I say, I only found historic intelligence from

           5       my research that I did on him.

           6   Q.  It might just be that the probation service knew about

           7       a car that he had.

           8   A.  You're correct, sir, they may well have done but

           9       I didn't ring probation.

          10   Q.  Somebody could have gone round to the address to survey

          11       the address without being too intrusive, couldn't they?

          12   A.  They could.

          13   MR MANSFIELD:  Thank you.

          14   THE ASSISTANT CORONER:  Thank you very much.  Mr Stern?

          15   MR STERN:  No, thank you, sir.

          16   MR MANSFIELD:  So sorry, there was one other question, I'm

          17       very sorry.  It's just for going to the particular set

          18       of roads.  Could you just look at tab 1, diagram

          19       number 7, sorry, an entirely different topic.  It's

          20       really only one question.  There's a plan there, that's

          21       all of the roads.

          22   A.  Sorry, tab 1 did you say?

          23   Q.  Tab 1, diagram number 7.

          24   THE ASSISTANT CORONER:  I think you need to look at the

          25       other --


                                           149
 

 

 


           1   A.  Is it the other book?  Thank you, sir.

           2   THE ASSISTANT CORONER:  It's also on the screen.

           3   A.  Lovely, thank you.  Yes.

           4   MR MANSFIELD:  Right.  These are the roads -- I appreciate

           5       you may not have seen this diagram before.  Take

           6       a minute to get your bearings -- Vicarage Road -- if you

           7       hold it across, you'll see that Vicarage Road runs from

           8       north to south there.

           9   A.  Yes.

          10   Q.  Farmer Road is, as you say, off to the right-hand side,

          11       as you look at the plan, marked; do you see it?

          12   A.  Yes, I do.

          13   Q.  In that road how close to the mini roundabout were you?

          14   A.  We were sat outside the school.

          15   Q.  The school that's marked?

          16   A.  Yes.

          17   Q.  You're there, that's two of you in one vehicle?

          18   A.  That's correct.

          19   Q.  Did you know where the others in your squad or team

          20       were?  There were others in the vicinity; did you know

          21       where they were?

          22   A.  No, I didn't.

          23   Q.  The single question I want to ask you is: is it by

          24       chance that you went there?  I mean, you just picked

          25       that road because -- why?


                                           150
 

 

 


           1   A.  Because Vicarage Road is one-way, north to south;

           2       Burchell and Byron are no-through-roads; Farmer was the

           3       first point, without -- is the first point of natural

           4       deviation in Vicarage Road.

           5   Q.  So the point is this, is it: that you came down Vicarage

           6       Road from the north --

           7   A.  Yes.

           8   Q.  -- is that right?

           9   A.  Yes.

          10   Q.  The first point of deviation is Capworth Street, isn't

          11       it?

          12   A.  But it's a one-way street.

          13   Q.  What is?

          14   A.  Vicarage Road.

          15   Q.  Yes.

          16   A.  So what I'm saying is we sat in Farmer Road because if

          17       you came down Vicarage Road you couldn't turn naturally

          18       left into Farmer Road because, from recollection, there

          19       was something blocking Farmer Road behind us.

          20   Q.  Behind you?

          21   A.  Yes.  So, in theory, it wouldn't have gone left, it may

          22       well have gone straight over as a continuation or it

          23       would -- it might have turned right into Park Road.  So

          24       Farmer Road seemed a sensible place to sit.

          25   Q.  Or it could have come up south --


                                           151
 

 

 


           1   A.  It could --

           2   Q.  -- because it's two-way beyond the mini roundabout.

           3   A.  Well, then if it had, we would have had it from Farmer

           4       Road as well.

           5   Q.  You parked there because it was a mid-position?

           6   A.  It was a sensible position.  We had cover while we were

           7       parked down there and, as I say, the vehicle couldn't

           8       have come down Farmer -- I cannot remember exactly what

           9       it was but I just remember there was some block in

          10       Farmer Road.

          11   Q.  The reason we are asking you is in relation to other

          12       officers.  Did you have time, having -- what time do you

          13       think you got there: 5.30-ish?

          14   A.  I couldn't be exact but --

          15   Q.  That's what -- you weren't driving, were you?

          16   A.  No, I wasn't.

          17   Q.  Your driver thinks it was around 5.30, would that be

          18       about right?

          19   A.  I cannot answer specifically, but I know it was

          20       around -- it was after 5.

          21   Q.  It's after 5.  Did you, having got there, have time to

          22       look around for this place to park?  In other words, you

          23       yourself --

          24   A.  Yes.

          25   Q.  -- reconnoited the streets, so you had a few minutes to


                                           152
 

 

 


           1       work out where would be the best place to park?

           2   A.  Yes.  We came down and I think we did the block and

           3       then, as I say, that seemed like a sensible out of the

           4       way place to sit.

           5   Q.  Yes, I understand that.  Knowing that the car had, what,

           6       turned into Burchell Road --

           7   A.  Yes.

           8   Q.  -- right -- you got that from whom?

           9   A.  ZZ37.

          10   Q.  Right.  You didn't know where ZZ37 was?

          11   A.  No.

          12   Q.  No.  Did you know when it had left Burchell Road?

          13   A.  Yes.

          14   Q.  Right.

          15   A.  That would have been from 37 saying "It's travelling

          16       south, Vicarage Road".

          17   Q.  Right.  So would this be fair: you are getting a running

          18       commentary of the movements of this car?

          19   A.  Yes.

          20   MR MANSFIELD:  Thank you very much.

          21                      Questions by MR THOMAS

          22   MR THOMAS:  I wonder if we can just have the map up again,

          23       please?

          24   THE ASSISTANT CORONER:  Back on that same map, all right.

          25   MR THOMAS:  Just this: you were parked near the school; is


                                           153
 

 

 


           1       that right?

           2   A.  Yes, that's correct.

           3   Q.  I think as has already been indicated to you, you will

           4       have been in position at about 5.30 -- ish.

           5   A.  Again, I cannot be specific about the time but --

           6   Q.  No, but if that's what your driver says, the person you

           7       were with, you had no reason to dispute that, did you?

           8   A.  No, absolutely none.

           9   Q.  So about 5.30.  This was 4 August, as we know.

          10   A.  Yes, that's correct.

          11   Q.  The one thing that would have been part of your role

          12       would have been to keep your eyes out?

          13   A.  Yes.

          14   Q.  Obviously anything that you see that is an obvious risk

          15       you would communicate that?

          16   A.  Yes.

          17   Q.  I would be right in saying, particularly around where

          18       the school is, it would have been particularly quiet

          19       because 4 August, this is, what, three weeks into the

          20       school holidays; that is right, isn't it?

          21   A.  Yes.

          22   Q.  Not only would this have been three weeks or so into the

          23       school holiday -- two or three weeks into the school

          24       holidays -- it's also right that we're talking about,

          25       what, as I said, 5.30 in had the evening, yes?


                                           154
 

 

 


           1   A.  Yes, that's correct.

           2   Q.  I'm right in saying -- I have seen your witness

           3       statement -- you don't radio across and say to your team

           4       leader or anybody else that, you know, this is

           5       a particularly risky scene in terms of having

           6       pedestrians about, do you?

           7   A.  No, I don't.

           8   MR THOMAS:  No.  That's all I ask, thank you very much.

           9   THE ASSISTANT CORONER:  Can I just ask you out of that: we

          10       have a picture of you, you are sitting in this car, are

          11       you, in the front passenger seat?

          12   A.  Yes.

          13   THE ASSISTANT CORONER:  You stay in the car all the time?

          14   A.  Yes.  That's correct.

          15   THE ASSISTANT CORONER:  Do you have much of a view up to

          16       your right or left to see much of Vicarage Road or not?

          17   A.  I can see the roundabout.

          18   THE ASSISTANT CORONER:  You can see the roundabout straight

          19       ahead of you.

          20   A.  There's a little mini roundabout straight ahead.

          21       Because you are there to get the direction of movement

          22       of the vehicle so we were sitting to watch, if a vehicle

          23       did come down, which way it went at that roundabout.

          24   THE ASSISTANT CORONER:  You didn't know, the vehicle could

          25       have come towards you down Park Road or left or right?


                                           155
 

 

 


           1   A.  Absolutely.

           2   THE ASSISTANT CORONER:  Did you have much of a view left and

           3       right up and down Vicarage Road or not?

           4   A.  No.

           5   THE ASSISTANT CORONER:  You were too far back into Farmer

           6       Road?

           7   A.  Yes, that's correct.

           8   THE ASSISTANT CORONER:  Thank you very much.  Yes, Mr Stern.

           9   MR STERN:  No, thank you.

          10   THE ASSISTANT CORONER:  Mr Butt?

          11   MR BUTT:  No, thank you.

          12   THE ASSISTANT CORONER:  No, Ms Leek?

          13           Yes, Mr Keith?

          14                      Questions by MR KEITH

          15   MR KEITH:  In relation to the research you did, please,

          16       ZZ46, you were given quite a tall order, were you not,

          17       which was to try to identify a link between "Kevin" and

          18       the name "Juvanne Miller".

          19   A.  Yes, that's correct.

          20   Q.  I presume that your research is only as good as the

          21       databases to which you have access and the entries which

          22       are put those databases?

          23   A.  Yes.  That's correct.

          24   Q.  You did pretty well, if I may say so, because you made

          25       a link to somebody called Kevin Hutchinson and


                                           156
 

 

 


           1       conceivably to Kevin Hutchinson-Foster.  Did you, in the

           2       course of your research, however, find other "Kevins"

           3       and other "Kevin Hutchinsons", was there more than one

           4       "Kevin" in the course of your research or more than one

           5       "Hutchinson", as far as you could see?

           6   A.  There was more than one "Kevin", certainly.

           7   Q.  In the course of your researches are you reliant upon

           8       the entries relating to individuals having accurate

           9       dates of birth and being spelt in the same way?

          10   A.  Yes, that's correct.

          11   Q.  So did you find that there were occasions when you would

          12       come across a name which seemingly looked similar to

          13       another name but in fact had a different date of birth

          14       and perhaps a different spelling?

          15   A.  Yes, that's right.

          16   Q.  But the result of your research carried out on 2 August

          17       over, I think, many hours, was that you found no current

          18       address or location for Kevin Hutchinson-Foster?

          19   A.  No, I didn't.

          20   Q.  No mobile?

          21   A.  No.

          22   Q.  No landline?

          23   A.  No.

          24   Q.  No car registered to him currently?

          25   A.  No.


                                           157
 

 

 


           1   Q.  There was no reference, was there, in any of your

           2       researches, to Burchell Road?

           3   A.  No.

           4   Q.  No reference to Desire Cox?

           5   A.  No.

           6   Q.  You had, therefore, no clues as to where you might go

           7       thereafter, other than the possibility of the probation?

           8   A.  That's correct, yes.

           9   Q.  If you had gone down that route, would you necessarily

          10       have found Burchell Road?

          11   A.  Not necessarily.  I don't know what probation held.

          12   Q.  Because we know, of course, that Burchell Road is not

          13       his address, but you've no doubt carried out hundreds of

          14       enquiries and research tasks over the many years.

          15   A.  Yes, I have.

          16   Q.  Did you feel that you had done all the reasonable

          17       research that your boss had asked of you?

          18   A.  Yes, I did.

          19   Q.  In fact, you carried out further research on 4 August

          20       but nothing to do with "Kev" or "Kevin".

          21   A.  No, nothing.

          22   Q.  That was to do, was it not, with the other

          23       investigations being carried out by the Dibri team --

          24   A.  That's correct, yes.

          25   Q.  -- against other people --


                                           158
 

 

 


           1   A.  Yes.

           2   Q.  -- of which we've heard something from ZZ17.

           3           Then moving forward, please, to 4 August in the

           4       evening, when ZZ37 came over the net to report what he

           5       saw in Vicarage Road, did you have any doubt at all that

           6       the minicab that he had just spotted was turning left

           7       into Burchell Road?

           8   A.  No, I didn't.

           9   Q.  Because that's what he told you --

          10   A.  That's what he told me.

          11   Q.  -- as it was happening?

          12   A.  Yes.

          13   Q.  You then waited to see what would happen thereafter?

          14   A.  That's correct.

          15   Q.  The position was this, wasn't it, that you were parked

          16       up in Farmer Road, that we've seen, ZZ37 was parked up

          17       in Vicarage Road, one of your colleagues, two of your

          18       colleagues, ZZ50 and ZZ63, were parked elsewhere.  You

          19       had to wait to see which one of you, if any of you,

          20       would spot a minicab if it came down Vicarage Road.

          21   A.  Yes, that's correct.

          22   Q.  Luckily ZZ37 did --

          23   A.  Indeed.

          24   Q.  -- and he told you.

          25   A.  He did, yes.


                                           159
 

 

 


           1   MR KEITH:  Thank you very much.

           2   THE ASSISTANT CORONER:  It was ZZ37.  I think at one point

           3       Mr Keith said ZZ17 but it was ZZ37 all the time, as

           4       given.

           5   A.  Sorry, yes.

           6   THE ASSISTANT CORONER:  You don't have anything really

           7       clever -- you don't have a marvellous sat nav within

           8       your car which shows where your colleague's cars are or

           9       anything clever like that?

          10   A.  No, we don't.

          11   THE ASSISTANT CORONER:  But you would no doubt have a map of

          12       the area while you are sitting there?

          13   A.  Yes, we would have had a map book.

          14   THE ASSISTANT CORONER:  So Burchell Road would have meant

          15       something to you when you heard that, that it was

          16       a road?

          17   A.  Yes, I would have been looking at the map and would have

          18       worked out where it was in conjunction with where we

          19       were, yes.

          20   THE ASSISTANT CORONER:  Good, thank you very much.

          21           Back to you, Mr Underwood.

          22   MR UNDERWOOD:  Nothing arising, thank you.

          23   THE ASSISTANT CORONER:  Thank you very much.  That concludes

          24       your evidence.  You are free now to go.  Thank you very

          25       much for assisting the jury.  As I say to everybody,


                                           160
 

 

 


           1       don't discuss the case, please.

           2   A.  Thank you.

           3                      (The witness withdrew)

           4   THE ASSISTANT CORONER:  We remain with the public in the

           5       other court.

           6   MR UNDERWOOD:  The next witness is A10.

           7   THE ASSISTANT CORONER:  We will let this witness leave.  Can

           8       we have A10 now?

           9                           A10 (sworn)

          10                   (The witness was anonymised)

          11   THE ASSISTANT CORONER:  Thank you very much.  If you would

          12       like to have a seat firstly.  Once you are seated, we'll

          13       turn the cameras on for upstairs, please.  We now have

          14       a witness before us.  Please can you just have a look at

          15       the list.  We are going to refer to you as "A10".  Do

          16       you see a list with your true name against that cipher

          17       or is it not on that list?

          18   A.  No, sir, it's not on that list.

          19   THE ASSISTANT CORONER:  We'll get you a piece of paper with

          20       hopefully your true name on it because I think it's

          21       important for court purposes that you confirm what your

          22       true name is, obviously not out loud.

          23           Anyway we'll carry on for the moment calling you A10

          24       if we may.  Yes, Mr Underwood.

          25                    Questions by MR UNDERWOOD


                                           161
 

 

 


           1   MR UNDERWOOD:  Good afternoon, my name's Underwood and I'm

           2       counsel for the Inquest and I have some questions for

           3       you to start with.

           4   A.  Okay.

           5   Q.  I think you are actually a Metropolitan Police officer;

           6       is that right?

           7   A.  That is correct, yes.

           8   Q.  But in August 2011 were you working at SOCA?

           9   A.  Yes, I was.

          10   Q.  Was your job there to do with intelligence?

          11   A.  That's correct, yes.

          12   Q.  Were you concerned at all with Operation Dibri and

          13       intelligence to do with Operation Dibri?

          14   A.  Yes, I was a case officer.

          15   Q.  You were the case officer for Dibri in SOCA; would that

          16       be fair?

          17   A.  Yes.  I'm a -- based in SOCA but the operation is

          18       a Trident operation but I was a case officer at SOCA for

          19       that operation.

          20   Q.  How long had you been a case officer for Dibri in

          21       August 2011?

          22   A.  I think it was about 2009 -- it will be 2009, I think.

          23   Q.  Okay.  We've very helpfully been given a couple of

          24       witness statements from you, and also helpfully the

          25       legal team for the family has produced a document which


                                           162
 

 

 


           1       cuts and pastes from those, so we've got in sequential

           2       order what it is you have said about intelligence.

           3       I would like to run you through that, if I may, to see

           4       whether you are content with the way it's been done.

           5           There are two bundles there: one, I think the

           6       thicker of the two bundles, the paler red, is documents

           7       for the jury.  There should be a tab C9 there.

           8   A.  Yes, sir, I have that.

           9   Q.  We are all becoming quite familiar with this but have

          10       you had a chance to see this?

          11   A.  No, sir.

          12   Q.  Let me just take you through it then.  You've got 1s and

          13       2s and 1s and 2s down the side and they are references

          14       to your first statement or to your second statement.

          15           I know we have to be careful about how we get

          16       evidence out of you about intelligence, so that is why

          17       we are all going so cautiously here.

          18           The first one is from the first statement and what

          19       it recites is that:

          20           "On 31 July 2011 I received credible intelligence

          21       that Mark Duggan wished to collect a firearm from a male

          22       associate.  This intelligence indicated that the male

          23       might be called 'Kevin' but there was insufficient

          24       intelligence to establish the male's identity, where the

          25       firearm was being stored or when it was going to be


                                           163
 

 

 


           1       collected."

           2           So that's the only entry from this to do with

           3       31 July and it's the only reference in your witness

           4       statements to 31 July.  Is that a fair, and as full as

           5       you can give us, representation of the intelligence you

           6       had on 31 July to do with Mr Duggan and

           7       Mr Hutchinson-Foster, as it turned out to be?

           8   A.  That is correct, yes.

           9   Q.  Thank you.  Then the next entry here is from your second

          10       statement and it deals with 1 August.  It says:

          11           "On 1 August 2011 I received further intelligence

          12       that the male associate holding this firearm stored it

          13       at the premises of an unidentified female and, due to

          14       the female's absence at work each day, he would not be

          15       able to gain entry to the premises to retrieve the

          16       firearm until she returned from work some time

          17       mid-to-late evening."

          18           So we've moved on to 1 August and at least a firearm

          19       is stored at the premises of an unidentified female who

          20       went to work each day and the person, "Kevin", wouldn't

          21       be able to get into the premises until she got back from

          22       work, yes?

          23   A.  That is correct.

          24   Q.  Did you also know there was more than one gun there?

          25   A.  I don't believe I can answer that question, sir.


                                           164
 

 

 


           1   Q.  I think you can, because I thought this came out this

           2       morning.

           3   THE ASSISTANT CORONER:  It's already been said.

           4   MR UNDERWOOD:  Perhaps Ms Leek can confirm that.

           5   MS LEEK:  Sir, perhaps the difficulty is the evidence was

           6       a bit more general than that, I think, this morning, in

           7       relation to passing intelligence that Mark Duggan was

           8       seeking to collect one of a number of firearms from

           9       Kevin Hutchinson-Foster.  There was no evidence given as

          10       to where those might be stored.

          11   THE ASSISTANT CORONER:  It was "one of a number" --

          12   MS LEEK:  Yes.

          13   THE ASSISTANT CORONER:  -- that was the phrase that was put

          14       forward.

          15   MS LEEK:  Yes, if that's the question then I believe the

          16       officer can answer that but I don't believe there was

          17       intelligence as to where they may be stored.

          18   THE ASSISTANT CORONER:  Let Mr Underwood use that phrase.

          19   MR UNDERWOOD:  Let me soften the question a bit: did you

          20       have intelligence to the effect that

          21       Mr Hutchinson-Foster may have had control of at least

          22       one, in fact more than one, firearm?

          23   A.  That's correct, yes.

          24   THE ASSISTANT CORONER:  One of a number?

          25   A.  Yes.


                                           165
 

 

 


           1   THE ASSISTANT CORONER:  All right, thank you, A10.

           2           Is there any problems if one gets the witness using

           3       a pen, which no doubt you have in your pocket, have you,

           4       A10?

           5   A.  I haven't.

           6   THE ASSISTANT CORONER:  .Whilst we carry on with this

           7       document, could we just carry on and then number the

           8       next paragraph 3 and then the one 4 and then 5 in a very

           9       logical way down to 8 so when the questions are asked it

          10       can be quite easy to follow.  I understand why we've got

          11       1 and 2, because we have it written at the top but even

          12       that little paragraph can be number 6, and it can then

          13       go 3, 4, 5, 6, 7, 8.  If the jury did that, I've done it

          14       a long time ago, it actually makes it a bit easier.

          15       There are eight paragraphs on this page.  There we are.

          16           Then we come on to paragraph 3; is that what you are

          17       now going to be asking about.

          18   MR UNDERWOOD:  It is indeed.  It comes from the first

          19       statement and it says this:

          20           "I received further credible intelligence on

          21       2 August 2011 that indicated that the male 'Kevin' was

          22       likely to be Kevin Hutchinson-Foster.  There was still

          23       insufficient evidence to identify where the firearm was

          24       being stored or when it would be collected."

          25           Then if we just carry on to the next paragraph 4:


                                           166
 

 

 


           1           "On 2 August I received intelligence that Kevin

           2       Hutchinson-Foster would not be in London in the evening

           3       so Mark Duggan wouldn't be able to meet with him to

           4       collect the firearm."

           5           Now, those are picked up from two different

           6       statements of yours.  Are they two pieces of

           7       intelligence or are they one piece of intelligence that

           8       happens to have been split up?

           9   A.  That's one piece of intelligence.

          10   Q.  Right.  So at some point then on 2 August, you got to

          11       know that "Kevin" was likely to be

          12       Kevin Hutchinson-Foster, Hutchinson-Foster wouldn't be

          13       in London that evening so Duggan wouldn't be able to

          14       meet him; is that fair?

          15   A.  I believe that is, sir.

          16   Q.  Now, we're trying to sort out who knew what when.  One

          17       of the things we have just learned is that ZZ46 was

          18       doing some work for the Met to try, by research, to

          19       identify -- she's a Trident officer, you may not know

          20       her -- she was doing some research to try to identify

          21       who a person called "Kevin" was who may be associated

          22       with guns and Mr Duggan.

          23   A.  Yes.

          24   Q.  Can you help with whether it was the Met that discovered

          25       that "Kevin" was Kevin Hutchinson-Foster or was it SOCA?


                                           167
 

 

 


           1   A.  I believe it was the Met.

           2   Q.  Right.

           3   A.  I believe it was the Met, yes.

           4   Q.  Then if we go down to what's now paragraph 5 on here:

           5           "On 3 August 2011 I received further intelligence

           6       that Mark Duggan still wished to collect a firearm from

           7       the male, whom I now believe to be

           8       Kevin Hutchinson-Foster.  There was still insufficient

           9       intelligence to identify where the firearm was being

          10       stored beyond the premises of the female associate

          11       probably in the Leyton area.  The intelligence indicated

          12       that Kevin Hutchinson-Foster intended to travel out of

          13       London later that evening.  I subsequently received

          14       intelligence that indicated that Mark Duggan wouldn't be

          15       in a position to collect the firearm as he was attending

          16       a family barbeque.  I disseminated this intelligence to

          17       ZZ17 by telephone."

          18           I don't want to pin you down to times at all here

          19       but can you give us some sort of idea about what part of

          20       the day we are talking about those two pieces of

          21       intelligence?  (Pause)

          22   A.  Okay, in relation to the first part of the intelligence,

          23       right up until the "Kevin Hutchinson-Foster intended to

          24       travel out of London later that evening", time wise --

          25       probably late morning/mid-afternoon.


                                           168
 

 

 


           1   THE ASSISTANT CORONER:  The middle of the day?

           2   A.  Yes.

           3   THE ASSISTANT CORONER:  Then you say "I subsequently

           4       received", so that's two lots.  So the first one is the

           5       middle of the day.

           6   A.  Yes.

           7   MR UNDERWOOD:  Then you say that you subsequently received

           8       intelligence that -- this is about the barbecue.

           9   A.  Yes.

          10   Q.  Very roughly, in terms of we know there was a briefing

          11       about 6 o'clock and we know there was mention that this

          12       might happen at 9 o'clock -- I'll come back to that --

          13       but very broadly in terms of 6 o'clock and 9 o'clock;

          14       before or after those?

          15   A.  That would have been after 6 o'clock, sir.

          16   Q.  Before 9 o'clock, can you help?

          17   A.  I think it was -- if not 9 o'clock, beyond 9 o'clock,

          18       I think it was around -- I'm not sure what the exact

          19       time was but I think it was later in the evening,

          20       I think it was a continuous intelligence picture.

          21   Q.  On that point, I've spoken about 9 o'clock, your

          22       intelligence was specific enough, was it, earlier in the

          23       day to make you believe that the pick up was likely to

          24       happen about 9 o'clock; is that right?

          25   A.  That was my understanding, yes.


                                           169
 

 

 


           1   Q.  Then you go on, the paragraph now numbered 6:

           2           "The intelligence throughout this period indicated

           3       that Mark Duggan upon collection of the firearm would

           4       store it at unidentified premises."

           5           Had you any narrowing down of that at all, the

           6       "unidentified premises"?

           7   A.  I didn't know where the firearm was going to be going

           8       to.

           9   Q.  It could have been London, it could have been out of

          10       London, it could have been anywhere; is that right?

          11   A.  I assumed it was going to be London but I didn't know

          12       where.  I assumed it was London.

          13   Q.  Right.  Then what's now paragraph 7, it's from your

          14       first statement:

          15           "Some time between 1710 and 1715 on 4 August 2011

          16       I received intelligence that indicated that Mr Duggan

          17       would be imminently travelling by minicab to Vicarage

          18       Road in Leyton to collect the firearm.  This was the

          19       first occasion on which I received intelligence which

          20       indicated an area where the firearm might be.

          21       I assessed the intelligence as being credible and

          22       immediately disseminated it to ZZ17 by way of a verbal

          23       briefing by telephone."

          24           Is that a fair summary?

          25   A.  That is correct, yes.


                                           170
 

 

 


           1   Q.  Then:

           2           "Later on 4 August 2011 I received credible

           3       intelligence that Mr Duggan was in possession of the

           4       firearm and intended taking it to the Broadwater Farm

           5       Estate in Tottenham.  I immediately disseminated this

           6       intelligence to ZZ17 by way of a verbal briefing by

           7       telephone."

           8           Again, is that a fair summary?

           9   A.  That is correct, yes.

          10   Q.  Thank you.  I don't want to delve into what sources of

          11       intelligence you were operating on, but can I ask

          12       whether you had research facilities as well as

          13       intelligence gathering facilities?

          14   A.  I do have a small research team, yes, sir.

          15   Q.  So in August 2011, did you have access through that team

          16       to the police national computer and the sort of

          17       databases that the Met Police would use to research?

          18   A.  The research team would have had those facilities.

          19   Q.  Did you task that team in late July and early August to

          20       try to track down anything more about Hutchinson-Foster

          21       or Mr Duggan?

          22   A.  I believe the majority of the research was in relation

          23       to the Trident officers, was going to do that search in

          24       relation to Kevin Hutchinson-Foster.

          25   Q.  Was this a decided division of labour, is that what


                                           171
 

 

 


           1       you're saying?

           2   A.  No, I don't -- my research team were aware of Kevin

           3       Hutchinson-Foster but I believe it was the Operation

           4       Trident team that identified Kevin Hutchinson-Foster.

           5   Q.  I'm interested at the moment in who was trying rather

           6       than who succeeded.  Was your team given the job of

           7       trying to research into Mr Hutchinson-Foster or "Kevin"

           8       or whatever he was thought to be at the time?

           9   A.  I believe the research was carried out by the

          10       Metropolitan Police Operation Trident.

          11   Q.  Let's get this clear: your research team was not given

          12       the task of attempting to identify Kevin

          13       Hutchinson-Foster; is that right?

          14   A.  I believe it was down to the Trident team that carried

          15       out that enquiries.

          16   Q.  We've just heard from ZZ46 that she did research based

          17       on a Juvanne Miller.  Was that from -- she says she

          18       believed that came through from SOCA; can you confirm

          19       that?

          20   A.  That is correct, yes.

          21   Q.  So does it follow that, in relation to that name, no

          22       research was done by SOCA?

          23   A.  In relation to that name, that was a name that was given

          24       to Operation Trident to ZZ17, as we believed that there

          25       was a link between that individual and "Kevin".


                                           172
 

 

 


           1   Q.  Did you know where Kevin Hutchinson-Foster was at any

           2       time?

           3   A.  No.

           4   Q.  Did you have an address at any time for where the guns

           5       were or gun was?

           6   A.  No.

           7   Q.  I have carefully covered whether your research team was

           8       asked to do any work in relation to

           9       Mr Hutchinson-Foster.  Let me be more specific: was your

          10       research team asked to do any work in relation to the

          11       female associates of Mr Hutchinson-Foster?

          12   A.  I'm not sure, sir.

          13   Q.  Sorry?

          14   A.  I'm not sure, sir.

          15   Q.  If they were, who would have asked them to do it?

          16   A.  It would probably have been me that would ask them to do

          17       it.

          18   Q.  When you say you are not sure do you mean that you don't

          19       remember or that this is one of those questions that you

          20       are not allowed to answer or what?

          21   A.  I believe that it was the Operation Trident team that

          22       I passed the information onto, for them to do the

          23       enquiries in relation to "Kevin".

          24   Q.  Did you, at any stage, make a record to the effect that

          25       on 3 August you had an address where the gun was or guns


                                           173
 

 

 


           1       were?

           2   A.  An address where -- I never knew where the guns were.

           3   Q.  Did you at any stage make a record which suggested that

           4       on 3 August you had an address for this female

           5       associate?

           6   A.  I've never had an address for the female associate.

           7   Q.  It's not what I asked.  Did you at any time make

           8       a record which suggested that on 3 August you did have

           9       an address?

          10   A.  No, I've never made that (inaudible).

          11   Q.  You told us that at 5.15 or so on 4 August you passed

          12       intelligence on to ZZ17 about the imminent move by

          13       Mr Duggan to go and pick up the gun.  You carefully say

          14       you had that intelligence about then.  Do you know when

          15       that intelligence first became available to SOCA?  I am

          16       not asking you what it was for the moment, I'm just

          17       asking whether you know when it was first available to

          18       SOCA.

          19   A.  It would have been shortly before I dealt with that

          20       intelligence, sir.

          21   Q.  We've heard from ZZ17 that if he had had that

          22       intelligence three or four hours before, it might have

          23       made a difference to him.  He's told us that, if he had

          24       had that intelligence about an hour before, it wouldn't

          25       have made any difference, he still would have had to


                                           174
 

 

 


           1       carry on with the plan he'd got.  Can you help us with

           2       whether you did, in fact, know, or SOCA in fact knew

           3       that intelligence anywhere between an hour and three or

           4       four hours before?

           5   A.  No, that wasn't -- three or four hours before?

           6   Q.  Between an hour and three or four hours before did you

           7       have it?

           8   A.  No, it was shortly before 5.15.

           9   Q.  Thank you.  The only other thing I want to ask you about

          10       is the final piece of intelligence you passed on to

          11       ZZ17, according to the summary we've got at C9, that

          12       Mr Duggan was in possession of the firearm and intend

          13       intended to take it to the Broadwater Farm Estate in

          14       Tottenham.  Did you have any specific part of Broadwater

          15       Farm Estate in which you thought the gun was going?

          16   A.  No, sir.

          17   MR UNDERWOOD:  Thank you very much.  Would you wait there

          18       please?  There will be more questions.

          19   THE ASSISTANT CORONER:  Yes.  Mr Mansfield?

          20                    Questions by MR MANSFIELD

          21   MR MANSFIELD:  Good afternoon, officer.  I represent the

          22       Duggan family.  My name is Michael Mansfield.

          23           You have divider 9, C9 sheet in front of you.  Did

          24       you bring any form of records to court today of your

          25       own?


                                           175
 

 

 


           1   A.  No, sir.

           2   Q.  No.  I'm going to ask you some questions, I don't wish

           3       to compromise any sources, but of course you can gist

           4       quite a lot of material, can't you?

           5   A.  If I'm able to, sir, yes.

           6   Q.  Have you got a memory of everything that was coming in

           7       to SOCA about this case, without documents?

           8   A.  I was the case officer in this case, sir, so I had

           9       a better knowledge than anybody else in relation to the

          10       intelligence around this operation.

          11   Q.  Do you have a memory, without documents, of pieces of

          12       information as they came in, the time they came in, the

          13       time they went out and the detail of it, without

          14       documents?

          15   A.  There are documents in relation to this case, yes, sir.

          16   Q.  Yes, please answer the question, I'm sorry, otherwise

          17       I may have to go a little bit repetitious about the

          18       questions.

          19           Now, the question was: do you have a memory of

          20       pieces of information that came in and then went out and

          21       the detail of it, without documents?

          22   A.  Sir, I do have a memory, yes.

          23   Q.  You do?

          24   A.  Yes.

          25   Q.  So when you came to make a statement about these


                                           176
 

 

 


           1       matters, you would have had a memory, would you?

           2   A.  Yes, sir.

           3   Q.  Yes.  Now, look at the sheet, please, with your acronym

           4       at the top, A10, that's the divider 9 sheet.  Do you

           5       have your statements in front of you?

           6   A.  My statement?  No.

           7   Q.  Yes, your statement?

           8   A.  No, no.

           9   Q.  Did you bring them to court today?

          10   A.  No.

          11   Q.  I wonder if he could have copies of his two statements,

          12       just before him.  I don't mind if --

          13   THE ASSISTANT CORONER:  No, they can be provided by the --

          14       (handed)

          15   MR MANSFIELD:  What we have done is we have taken passages,

          16       the relevant passages out of these statements and put

          17       them on this one sheet of paper; do you follow?

          18   A.  Yes, sir.

          19   Q.  There is a typographical error, for which I apologise,

          20       at the beginning of the A10 statement -- so sorry,

          21       compilation -- you see in parenthesis in brackets it

          22       says "Numbering: 1 equals 6.9.12"; do you see that?

          23   A.  Yes, sir.

          24   Q.  It should read -- and please could everyone correct

          25       it -- it should read "13", I'm sorry about that.  Then


                                           177
 

 

 


           1       there's another statement made a few days later, the

           2       same month, this year, the month that is a just gone,

           3       12 September.

           4           Why did you have to make two statements so closely

           5       together?

           6   MS LEEK:  Sir, I'm not sure that's a matter for the witness.

           7       As my learned friend knows, there was ongoing discussion

           8       between SOCA's legal team and yourself and SOCA

           9       responded to requests that you had made in relation to

          10       what information was required.

          11   MR MANSFIELD:  Of course, I don't have that.  But what

          12       I want to obviously go -- and I will certainly

          13       persevere, I'm afraid, with these statements.  If we

          14       look at the first two paragraphs, 1 and 2, the first

          15       paragraph came out of a statement that you made on

          16       6 September, do you follow --

          17   A.  Yes.

          18   Q.  -- which means that when you made the statement on

          19       6 September, you said nothing about the intelligence on

          20       1 August --

          21   A.  (Nods)

          22   Q.  -- did you?

          23   A.  These statements I've provided, sir, I was asked

          24       specifically to cover those points that are mentioned in

          25       these statements.


                                           178
 

 

 


           1   MS LEEK:  Sir, I wonder if you might be able to assist at

           2       this point because all this officer was asked to provide

           3       was a statement dealing with 3 and 4 August initially.

           4   THE ASSISTANT CORONER:  He was doing very well on his own

           5       actually, A10, because he was just saying then he was

           6       answering what he was asked to say and that's what

           7       happens.  Witnesses get asked to give evidence about

           8       particular dates and items and that's what you, A10,

           9       were doing.  So I'm quite happy about that.  There's

          10       nothing suspicious about it, he's just been asked to

          11       give one statement and then asked to give another.

          12       I don't think there's any mystery more than that.

          13   MR MANSFIELD:  There may be, sir.  We don't know what he's

          14       been asked to do.  What we know is what we're given.  So

          15       may I say straightaway, if he was asked to make

          16       a statement on or about 6 September about the 3rd, 4th

          17       and 5th, it's very interesting that the first item he

          18       mentions in his statement of the 6th is 31 July.

          19           That's why I'm asking you the questions, and I'm

          20       sorry, I'm going to persevere because I want to get as

          21       full a picture of what was known at the root of this

          22       case, what was known by you, A10, the case officer; do

          23       you follow?

          24   A.  Yes.

          25   Q.  I don't want to compromise anybody but we would like to


                                           179
 

 

 


           1       get near the truth of what was known.

           2   THE ASSISTANT CORONER:  The "anybody" is you.  I think, A10,

           3       you know the rules and the legal difficulties so if

           4       there are any problems about answering the specific

           5       question put to you, please say and then I shall have to

           6       judge.  We are all subject to the law and so if you feel

           7       that the law impinges on you and you cannot answer the

           8       question, much as though you might like to but you

           9       cannot, then please say.  Then that answer will be

          10       final, subject to anything that I have to say.

          11   A.  Thank you, sir.

          12   THE ASSISTANT CORONER:  Yes?

          13   MR MANSFIELD:  Let's take the first statement, 6 September

          14       last month.  What were you asked to provide?

          15   A.  The details in that statement, sir.

          16   Q.  You were asked to provide just details relating to the

          17       31st, the 2nd, the 4th, and that's it?

          18   A.  That is correct, yes, sir.

          19   Q.  Just those dates --

          20   A.  That's correct.

          21   Q.  -- or was it just the 3rd and the 4th, as has just been

          22       said?

          23   A.  The dates that are in that statement, sir.

          24   Q.  Sorry, I'm going to ask if we may be provided with what

          25       it was he was asked to do because there's materials


                                           180
 

 

 


           1       here --

           2   THE ASSISTANT CORONER:  He has now answered it.  He's said

           3       he was asked to provide the statement and the contents

           4       of it.  There are cases, we all know -- and the jury are

           5       here listening -- whereby you say to a witness "Tell us

           6       everything we want to know about the incident" and then

           7       they tell you everything that you want to know within

           8       that statement and then you get a statement saying "I've

           9       forgotten something", and then you can make, as

          10       an advocate, some point about that, about a memory

          11       coming out.

          12           Here, this gentleman has been asked to deal with

          13       certain specific items, he deals with them in his first

          14       statement, he's told you that, and then no doubt you'll

          15       ask him about what he was asked to deal with in his

          16       second statement and he'll give his answer about that,

          17       and that's it.

          18   MR MANSFIELD:  No, sir, sorry, the problem here is we need

          19       to know what the intelligence was in relation to this

          20       exercise, the dates that relate to it and what it was.

          21       If he was asked to provide a statement indicating the

          22       intelligence held by SOCA in relation to this case,

          23       that's one thing, in which case one has to ask why the

          24       first statement didn't have all the intelligence and

          25       there had to be a second statement, which has more


                                           181
 

 

 


           1       intelligence.  As I shall come to, there is yet more

           2       intelligence that isn't in either statement.

           3   THE ASSISTANT CORONER:  I am aware of that.

           4   MR MANSFIELD:  We weren't aware until a certain witness

           5       came, ZZ17, that there were other materials that were

           6       not there.  The question is: what else is not there?

           7       That's the point.  I'm going to ask you --

           8   THE ASSISTANT CORONER:  Ask the question and see how we get

           9       on.

          10   MR MANSFIELD:  What else is not in your --

          11   THE ASSISTANT CORONER:  Not that question.  You are asking

          12       the witness what is it that he cannot tell us.  That's

          13       really -- come on, Mr Mansfield, you know what we're all

          14       doing here.  We are trying desperately to be as open as

          15       possible within the law.  It applies to us all, I am not

          16       above the law.  We are all having to work around

          17       particular pieces of legislation --

          18   MR MANSFIELD:  I appreciate that.

          19   THE ASSISTANT CORONER:  -- and we are trying to be as open

          20       as possible and we are all in difficulties in different

          21       ways.  So please --

          22   MR MANSFIELD:  I hope the truth isn't in difficulties

          23       because of this.

          24   THE ASSISTANT CORONER:  Well, I hope so.

          25   MR MANSFIELD:  You do follow what I'm trying to ascertain?


                                           182
 

 

 


           1   A.  Yes, I do follow you, sir, but I'm obviously -- there

           2       are many restrictions on me.

           3   Q.  Yes, I appreciate that.  We can see, as we run down this

           4       page, that there are items that you put in the first

           5       statement and then items that you had obviously left out

           6       of that statement.  Did you leave items out on purpose?

           7   A.  No, I did not.

           8   Q.  You didn't.  Well, were you told to leave items out?

           9   A.  I wasn't told to leave items out.  I was asked to do

          10       specific statements to cover certain points.

          11   Q.  Yes.  Well, that's what I'm trying to find out, as to

          12       what the points were that you were asked to cover.

          13   A.  Well, in relation to my first statement, it covers the

          14       incident on the 31st, on the 2nd --

          15   Q.  Nothing on the 3rd, is there?

          16   A.  Well, that wasn't requested at the time, sir.

          17   Q.  Wasn't it?  I thought just a minute ago you were asked

          18       to do the 3rd, the 4th and the 5th?

          19   A.  You can see what's --

          20   Q.  Have you got there the questions that you were asked?

          21   A.  Yes.  This was the 31st, the 2nd and the 4th, on the

          22       first statement.

          23   Q.  Why nothing about the 3rd?

          24   A.  Because I wasn't requested at the time to write anything

          25       about the 3rd.


                                           183
 

 

 


           1   Q.  I'm sorry, we have just had a statement indicating you

           2       were asked for the 3rd, the 4th --

           3   THE ASSISTANT CORONER:  That's his evidence and I think that

           4       that is the position.  Ms Leek doesn't give evidence.

           5   MR MANSFIELD:  Let's just deal with the 4th, if we might.

           6       Again, the 4th is right at the bottom, it's in

           7       paragraphs 7 and 8; do you see that?

           8   A.  Yes, sir.

           9   Q.  Yes.  As there stated on that page, do they include all

          10       the intelligence that you were passing on on that day

          11       about this particular exchange that was thought to have

          12       been intended?

          13   A.  I can't answer that question, sir.

          14   Q.  Well, I'm going to put something to you --

          15   THE ASSISTANT CORONER:  As a matter of law?

          16   A.  As a matter of law, sir.

          17   MR MANSFIELD:  Sir, it's already in the public domain.

          18   THE ASSISTANT CORONER:  That's why we have talking about

          19       gisting, isn't it, so if we have a gist it cannot have

          20       every word?

          21   MR MANSFIELD:  No, no, I'm not asking for that.  There's

          22       a significant piece of intelligence that we know about

          23       that is not included here.

          24   THE ASSISTANT CORONER:  Right.  Put that.

          25   MR MANSFIELD:  Sir, it comes from the last witness.  Shortly


                                           184
 

 

 


           1       before 6 o'clock on the 4th, you told ZZ17, didn't you,

           2       that the minicab thought to be carrying Duggan was in

           3       Vicarage Road?

           4   A.  I can't answer that question, sir.

           5   Q.  Sir, may I address you in the absence of the jury?

           6   THE ASSISTANT CORONER:  Of course, you may.

           7   MR MANSFIELD:  This is becoming?

           8   THE ASSISTANT CORONER:  Members of the jury, just have

           9       a break.  We'll see if we can deal with this evidence in

          10       the next half an hour, so please don't go too far away.

          11       Just for the moment, if you just stay outside court.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

                                           185
 

 

 

 


          22                  (In the presence of the jury)

          23                (The witness returned into court)

          24                         A10 (continued)

          25   THE ASSISTANT CORONER:  Thank you very much, A10.  Have


                                          

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


                                      195
 

 

 


           1       a seat back there.  We can put the cameras back on.  Can

           2       you just confirm, please, on the oath, that you have

           3       handed to me via the usher a document with your true

           4       name on it?

           5   A.  That's correct sir.

           6   THE ASSISTANT CORONER:  To be retained by myself for court

           7       purposes.  But thank you very much for that.

           8   A.  Thank you.

           9   THE ASSISTANT CORONER:  Now Mr Mansfield was asking you some

          10       questions, and I'll ask him to carefully repeat the

          11       question that he asked you.

          12              Questions by MR MANSFIELD (continued)

          13   MR MANSFIELD:  If you have the sheet, C9, in front of you,

          14       please.  If I concentrate just for the moment on the

          15       4th -- never mind earlier days -- that's the day it all

          16       happened.

          17           My first question in relation to material on the

          18       4th: did you communicate with ZZ17 shortly before

          19       6 o'clock that Mark Duggan was in the vicinity of

          20       Vicarage Road?

          21   A.  I did have a conversation with ZZ17 and I was giving him

          22       an update in relation to the intelligence.  Yes.

          23   Q.  It does not quite answer the question.  I'll put it

          24       again -- well, perhaps I don't need to put the detail --

          25   THE ASSISTANT CORONER:  You have heard the question.


                                           196
 

 

 


           1   A.  Yes.

           2   THE ASSISTANT CORONER:  Ms Leek is Queen's Counsel advising

           3       the Serious Organised Crime Agency.

           4   A.  Yes.

           5   THE ASSISTANT CORONER:  She's not leaping to her feet, so

           6       you can take it that, as a matter of law, you will not

           7       breach any particular statutory provision if you are

           8       able to answer a little bit more specifically about the

           9       quality and the nature of the intelligence that you

          10       passed on.

          11   A.  Okay.  Sir, that is correct, that is the update that

          12       I gave ZZ17.

          13   MR MANSFIELD:  What I have just read out is the update that

          14       you gave?

          15   A.  Yes, sir.

          16   Q.  Of course, that's not on the A10 sheet -- I mean the C9

          17       one.

          18           Another piece relating to the same day, the 4th, on

          19       the A10 sheet it just says "later".  Was "later" just

          20       after 6 o'clock?  I'll read you what ZZ17 says about it:

          21           "At about this time, I then received further

          22       intelligence [from you] that indicated that Mark Duggan

          23       had taken possession of a firearm and was heading

          24       towards the Broadwater Farm Estate in Tottenham."

          25           That's just after 6 o'clock.  Is that what happened?


                                           197
 

 

 


           1   A.  That was the update that I gave ZZ17, yes.

           2   Q.  That was the update you gave.  Now, I want to ask you

           3       more.

           4           If you go back to the earlier occasions, and for

           5       these purposes I want to, if it's possible, to have

           6       ZZ17's statement where it's carefully set out.  It's

           7       page 780.  It will come up on the screen.

           8   THE ASSISTANT CORONER:  It will come up on the screen in

           9       front of you there, A10, thank you.

          10   MR MANSFIELD:  This is in the period leading up to the 4th.

          11       So you have the context, on 3 August there was

          12       a briefing by this officer of officers concerned with

          13       this pro-active, protracted operation.  This is what he

          14       says in the statement:

          15           "In the days leading up to 4 August 2011,

          16       intelligence from SOCA identified that somebody was

          17       looking after more than one firearm on behalf of Mark

          18       Duggan and that Duggan intended to take possession of

          19       one of these firearms."

          20           I pause.  Did you communicate that intelligence to

          21       ZZ17?

          22   A.  I did give that information to ZZ17.

          23   Q.  Now, I will just carry on:

          24           "As a result of careful research [and so on].  The

          25       person believed responsible for storing the firearms was


                                           198
 

 

 


           1       identified as Kevin Hutchinson-Foster."

           2           I'll come back to that because you have already said

           3       something about it:

           4           "It became apparent that Hutchinson-Foster was

           5       probably storing these firearms with an unidentified

           6       female associate."

           7           I pause there.  Did you communicate that

           8       intelligence?

           9   A.  That is correct, yes.

          10   Q.  Again, in those terms, it's not part of the A10

          11       statements you made, is it?

          12   A.  No it's not, sir.

          13   Q.  No.  Just go on the rest of that sentence:

          14           "Intelligence indicated that she resided somewhere

          15       in the Leyton area."

          16           Did you communicate that?

          17   A.  (Pause)  I did communicate that, yes.

          18   Q.  Now, if the intelligence that ZZ17 and SOCA had by

          19       3 August was that a man, thought to be called

          20       Kevin Hutchinson-Foster, was storing more than one gun,

          21       and namely firearms, that's very significant

          22       intelligence, isn't it?

          23   A.  That is significant intelligence, yes.  It was one of

          24       a strand of intelligence that was coming in around that

          25       time.


                                           199
 

 

 


           1   Q.  I'm so sorry?

           2   A.  It was one of a strand of intelligence that was coming

           3       round in that time.

           4   Q.  I appreciate that.  I've used the term "quartermaster",

           5       I think you have heard that term before, presumably you

           6       know what a quartermaster, the role, is?

           7   A.  Yes, I do.

           8   Q.  Somebody who's storing things for other people.

           9   A.  Yes.

          10   Q.  Would you accept, on the Serious Organised Crime Agency,

          11       that it is imperative to see if you can identify not

          12       only who the person is, but possibly where this store,

          13       however small, may be?

          14   A.  Yes, of course it would.  If we identified where those

          15       firearms was being stored, then that was what the aim

          16       was.

          17   Q.  Yes, of course.  Part of the process for identifying

          18       where the store is, again however small, whether it's

          19       one, two, three firearms, is obviously research you do

          20       yourself on paper.

          21   A.  (Nods)

          22   Q.  Yes?

          23   A.  Yes.

          24   Q.  I'm sorry, can you speak up?

          25   A.  Yes.


                                           200
 

 

 


           1   Q.  Yes.  I'm just dealing with that part first, research on

           2       paper.  Who within SOCA did any research on paper into

           3       who Kevin Hutchinson-Foster was and any addresses that

           4       might be associated with him on paper?

           5   A.  I believe that the majority of the intelligence in

           6       relation to Kevin Hutchinson-Foster was conducted by the

           7       operational team, Operation Trident.

           8   Q.  Yes.  I'm sorry, I'll have to ask the question again.

           9       Is it a difficult question that you can't answer?

          10   A.  I think it is a difficult question that I can't answer.

          11   Q.  Well, sir, I do want to persevere with this question.

          12   THE ASSISTANT CORONER:  Yes, quite.  You've told us that

          13       a lot of the information was given and it was those

          14       officers conducting Operation Trident, or within the

          15       Trident team, sorry, that were doing the work into

          16       discovering more --

          17   A.  Yes.

          18   THE ASSISTANT CORONER:  -- about Mr Hutchinson-Foster.

          19   A.  Yes.

          20   THE ASSISTANT CORONER:  But you also felt able, so far, to

          21       tell us about what the research was that you didn't do

          22       because you were passing it on.  Did you do any research

          23       within your team, pass anything to your team?

          24   A.  My role is basically to pass the information out to the

          25       operational team and the operational team conduct all of


                                           201
 

 

 


           1       the enquiries around the subjects that they are

           2       investigating.  So I receive information and I pass that

           3       information out to the operational team and they take

           4       the lead in relation to those enquiries.

           5   THE ASSISTANT CORONER:  As you said to Mr Underwood already,

           6       you didn't task anybody within any organisation, SOCA or

           7       your team or anyone else, to do any paper research, as

           8       has been put?

           9   A.  I believe I passed details that I had to ZZ17.

          10   THE ASSISTANT CORONER:  Yes.

          11   MR MANSFIELD:  Well, I'm sorry, it still doesn't answer the

          12       question either the learned Coroner is asking or I'm

          13       asking.  Did you task anyone at SOCA -- because you are

          14       in a separate place, aren't you?

          15   A.  Yes.

          16   Q.  You are not placed with Trident?

          17   A.  That's correct.

          18   Q.  They are north and you are south.  I'm going to put it

          19       generally, all right, in London?

          20   A.  Yes.

          21   Q.  So in your separate place further south, did you

          22       ask/task anyone in your organisation "Find out as much

          23       as you can about Kevin Hutchinson-Foster"?

          24   A.  There was some research conducted at SOCA in relation to

          25       Kevin Hutchinson-Foster but I can't talk about those


                                           202
 

 

 


           1       matters, sir.

           2   Q.  Were those matters, whatever they were, passed on to

           3       Trident?

           4   A.  I can't answer that question, in so far that any

           5       information I could give to Trident, I did give to

           6       Trident.

           7   THE ASSISTANT CORONER:  All the information you could pass

           8       on, you did?

           9   A.  I did, that's exactly right, yes, sir.

          10   MR MANSFIELD:  There's a core point here: did any of the

          11       information that you passed on to Trident involve

          12       revealing that you knew an address where Kevin

          13       Hutchinson-Foster resided right then in August?

          14   A.  I don't recall the address.  I thought that came from

          15       SOCA -- sorry, from Trident informing us of where the

          16       address -- but all the enquiries in relation to Kevin

          17       Hutchinson-Foster came from the team.

          18   Q.  Sorry, did they give you an address then?

          19   A.  Sir, I am not interested in any addresses.  I give out

          20       information, I don't record information.

          21   Q.  I am just trying to do it that way round.  Did you

          22       provide Trident, amongst the information that you appear

          23       unable to tell us, but was amongst all of it --

          24   A.  Yes.

          25   Q.  -- a current address in August for Kevin


                                           203
 

 

 


           1       Hutchinson-Foster?

           2   A.  I don't recall giving them an address for Kevin

           3       Hutchinson-Foster, no.

           4   THE ASSISTANT CORONER:  So the answer is no, is it?

           5   A.  No.

           6   MR MANSFIELD:  You don't recall.  But is it something you

           7       can check?

           8   A.  I can try and check but I don't recall personally giving

           9       out an address for Kevin Hutchinson-Foster.

          10   Q.  The second question linked to it is this: did you

          11       indicate to Trident how they might trace this man who's

          12       storing weapons for someone else?

          13   A.  There was a person's name given out and an address to

          14       assist the operational team.

          15   Q.  Yes.  It's the name I think we've had today.  Is that

          16       all; is that the only name you gave?

          17   A.  That is correct, yes.

          18   Q.  Because what you were saying, on intelligence you have

          19       got on that sheet of A10, is that the address that would

          20       be most relevant, if you had it, was of a female

          21       associate; yes, do you agree?

          22   A.  That is correct, yes.

          23   Q.  Now, did you give Trident any information/intelligence

          24       about potential female associates in Leyton?

          25   A.  No.  The only information I gave them was that there


                                           204
 

 

 


           1       was -- I think it was talk on the 2nd -- I think it was

           2       the 2nd when I spoke to Operation Trident -- that the

           3       mention of a female where the firearms was being

           4       stored -- that was the intelligence on the 2nd,

           5       I believe.

           6   Q.  Yes, but given you have your own facilities for

           7       research --

           8   A.  Yes.

           9   Q.  -- you are not just a conduit, do you understand me, of

          10       getting intelligence and passing it on?  You do a bit

          11       more than that, don't you?

          12   A.  Yes, we do but most of the work is carried out by the

          13       operational team.

          14   Q.  Yes, I follow that.  But Serious Organised Crime analyse

          15       intelligence as well, don't they?

          16   A.  Yes.  But the majority of it is passed out to the

          17       operational team for those to conduct their enquiries.

          18   Q.  I realise you pass it on but you have an analysis

          19       function, don't you?

          20   A.  Yes.

          21   Q.  Yes.  You are not just a post box, are you?

          22   A.  A lot of our work is in relation to assisting the

          23       operational teams.

          24   Q.  Yes, I appreciate that.  You've already accepted that

          25       identifying premises where weapons may be stored is


                                           205
 

 

 


           1       really at the top of priorities, isn't it?

           2   A.  Of course.  If we know where the premises are, yes.

           3   Q.  Yes, I appreciate that.  But of course to find that out

           4       you have to do more than I have asked you about: paper

           5       research.  You would recognise, with your Metropolitan

           6       Police hat on or even with your SOCA hat on, that

           7       sometimes you just have to go out and find it, don't

           8       you --

           9   A.  Yes.

          10   Q.  -- on the street --

          11   A.  Yes.

          12   Q.  -- that might involve surveillance.

          13   A.  Yes.

          14   Q.  I'm only asking you a question which I don't think is

          15       going to breach any rules: on the 3rd, the records that

          16       are kept by SOCA would that indicate times that

          17       intelligence was handed on?

          18   A.  No.

          19   Q.  So you have to work from memory?

          20   A.  I will know -- yes, roughly -- if it's something that is

          21       happening now, it's imminent or in the near future, it's

          22       passed on straightaway.

          23   Q.  You have already been asked, but it was in relation to

          24       intelligence about Mark Duggan on the 3rd --

          25   A.  Yes.


                                           206
 

 

 


           1   Q.  -- because we know an operation was mounted on the 3rd

           2       at about 8.30 or 9 o'clock.  So the question is really:

           3       when did you pass on information on that day that he was

           4       going -- that is Mark Duggan -- was going to be at

           5       a barbecue?

           6   A.  That would have been the evening, sir.

           7   Q.  I appreciate that, but you cannot be more specific?

           8   A.  I cannot be more specific.  It was in the evening, sir.

           9   Q.  This is the final question in relation to all of this.

          10       When you passed on information to ZZ17 on the 4th about

          11       Vicarage Road, did you say "in the vicinity of Vicarage

          12       Road" or did you say "in Vicarage Road"; do you follow,

          13       there's a difference?

          14   A.  I think it was "in the vicinity".

          15   Q.  "In the vicinity"?

          16   A.  In the area.

          17   MR MANSFIELD:  Yes, thank you.

          18   THE ASSISTANT CORONER:  Thank you.  Let's just see if there

          19       are other questions that we can deal with in short.

          20           Mr Thomas, anything you want to ask?  No.

          21           Anything at all from --

          22   MR STERN:  No, thank you, sir.

          23   THE ASSISTANT CORONER:  -- Mr Stern?

          24           Mr Butt?

          25   MR BUTT:  No thank you, sir.


                                           207
 

 

 


           1   THE ASSISTANT CORONER:  Then I think, actually, Mr Keith you

           2       come in here on my list of questions, so -- questioning

           3       rather -- anything you would like to ask.

           4   MR KEITH:  Happily, I have no further questions.

           5   THE ASSISTANT CORONER:  Let's then continue on: Ms Dobbin?

           6   MS DOBBIN:  No thank you, sir.

           7   THE ASSISTANT CORONER:  Mr Glasson?

           8   MR GLASSON:  No thank you, sir.

           9   THE ASSISTANT CORONER:  I think then finally, Ms Leek?

          10   MS LEEK:  No thank you, sir.

          11   THE ASSISTANT CORONER:  Anything else from you,

          12       Mr Underwood?

          13   MR UNDERWOOD:  No.  Thank you very much.

          14   THE ASSISTANT CORONER:  That brings everything neatly to

          15       a conclusion almost on the dot of 4.30.

          16           So thank you, members of the jury, for your

          17       concentration then today.  We'll break now and we will

          18       be back together at 10.30 tomorrow morning, please.

          19       Make sure that the cameras are not on upstairs, please.

          20       Thank you.  Members of the jury may now leave.

 

 

 

 

 

 

                                           208
 

 

 


          

           9   (4.32 pm)

          10       (The Inquest adjourned until 10.30 am on Wednesday,

          11                         2 October 2013)

          12
               ZZ17 (continued) .....................................1
          13
                   Questions by MR MANSFIELD (continued) ............2
          14
                   Questions by MR THOMAS ..........................58
          15
                   Questions by MR STERN ...........................86
          16
                   Questions by MR BUTT ...........................106
          17
                   Questions by MS LEEK ...........................111
          18
               DETECTIVE SUPERINTENDENT MALLON ....................115
          19             (recalled)

          20       Questions by MR UNDERWOOD ......................115

          21       Questions by MR MANSFIELD ......................117

          22       Questions by MR BUTT ...........................119

          23   ZZ46 (affirmed) ....................................121

          24       Questions by MR UNDERWOOD ......................121

          25       Questions by MR MANSFIELD ......................142


                                        

 

 

 

 

 

 

 

 

                                   209
 

 

 


           1       Questions by MR THOMAS .........................153

           2       Questions by MR KEITH ..........................156

           3   A10 (sworn) ........................................161

           4       Questions by MR UNDERWOOD ......................161

           5       Questions by MR MANSFIELD ......................175

           6   Discussion re evidence .............................185

           7   A10 (continued) ....................................195

           8       Questions by MR MANSFIELD (continued) ..........196

           9

          10

          11

          12

          13

          14

          15

          16

          17

          18

          19

          20

          21

          22

          23

          24

          25


                                           210