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Full Hearings

Hearing: 8th May 2008, day 16

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held at:
The Interpoint Centre
20-24 York Street
Belfast BT15 1AQ

on Thursday, 8th May 2008
commencing at 10.15 am

Day 16









1 Thursday, 8th May 2008

2 (10.15 am)

3 THE CHAIRMAN: Yes, Mr Phillips.


5 Questions by MR PHILLIPS

6 MR PHILLIPS: Mr Campbell, can you first give the Inquiry

7 your full names, please.

8 A. Yes, Joseph Anthony Campbell.

9 Q. Do you have a copy of your witness statement to the

10 Inquiry with you?

11 A. I do.

12 Q. Can that come up on the screen, please? It is

13 RNI-803-074 (displayed). If we look, please, at

14 RNI-803-082 (displayed), do we see your signature?

15 A. Yes.

16 Q. And the date there of 29th November?

17 A. Yes.

18 Q. Last year, thank you. As you explain in your

19 statement -- and I am now back to paragraph 2 on

20 RNI-803-074 -- your father was a serving police officer

21 who was murdered in 1977.

22 A. That's right.

23 Q. Leaving eight children.

24 A. Yes.

25 Q. And so far as the Inquiry is concerned, what your





1 statement sets out for us is how you came to come into

2 contact with Rosemary Nelson.

3 A. That's right.

4 Q. As part of your continuing attempts to find out more

5 about and generally to campaign about this murder.

6 A. That is right.

7 Q. And it is that aspect of it -- in other words, your

8 contact with Rosemary Nelson -- that concerns us,

9 obviously.

10 A. Yes.

11 Q. First of all, could you look, please, at paragraph 5,

12 which is on the next page, RNI-803-075 (displayed)? I

13 am going to be asking you, I am afraid, to help us as

14 much as you can with dates. Do you see at the end of

15 this paragraph you say that you met her -- that is

16 Rosemary Nelson -- four times from late 1997 through

17 1998?

18 A. Yes.

19 Q. And there were four such meetings in all, I think,

20 weren't there?

21 A. That is correct.

22 Q. Thank you. Earlier in the paragraph you say that you

23 were advised to get in touch with Rosemary Nelson and

24 that the person you originally spoke to was Jane Winter.

25 Is that right?





1 A. That's correct.

2 Q. She recommended, I think, a firm in London?

3 A. Yes.

4 Q. But it was decided that you needed a local firm and that

5 is how you came to Rosemary Nelson?

6 A. Yes, because my father's murder was in this

7 jurisdiction, so I decided to get a solicitor in

8 Northern Ireland.

9 Q. Thank you. When you first met Rosemary Nelson, you say

10 to us -- in paragraph 15, and this is moving through the

11 statement to page RNI-803-078 (displayed) -- that what

12 you had heard about her and seen of her on the

13 television gave you confidence. Can you help us with

14 that? What do you mean "confidence for your case"?

15 What does that mean?

16 A. First of all, I needed somebody that I could trust, so

17 the first thing was she came as a recommendation from

18 a solicitor in London that I did trust. So not having

19 an awful lot of knowledge of other solicitors in

20 Northern Ireland, I took that as a good recommendation,

21 and I was impressed with what I saw. The lady was

22 obviously very brave, not afraid to take on what might

23 be considered controversial cases. So I felt that,

24 initially from a distance, that it was a good choice and

25 that was confirmed.





1 Q. Thank you. When you say not afraid to take on

2 controversial cases, which were the cases you have in

3 mind?

4 A. I knew that -- I had seen Rosemary on the TV with regard

5 to the Colin Duffy case and what was happening around

6 Garvaghy Road.

7 Q. And you say at the end of this paragraph 15 that:

8 "There weren't many solicitors on the list in

9 Northern Ireland who I would have trusted to go to ask

10 for assistance."

11 A. That is correct. I didn't actually see a list; I don't

12 think there is a list. I don't think that is meant

13 literally, but I had been away from Northern Ireland for

14 quite some time and I had to be very confident about the

15 solicitor that I was going to work with. So, Rosemary

16 came with good recommendation so I chose Rosemary.

17 Q. Thank you. Now, just to put it in a slightly broader

18 context, as I understand it from paragraph 4 of your

19 statement, where you say:

20 "About 16 years ago I started to investigate my

21 father's murder."

22 That suggests that the investigation, your

23 investigation, began in the early 1990s. Is that about

24 right?

25 A. That's correct.





1 Q. Because there had been, as you explain in paragraph 3,

2 a trial and the defendant was acquitted of the offence?

3 A. Yes.

4 Q. Is that right?

5 A. Yes, there was a police officer, Charles McCormick, who

6 was tried but not convicted of the murder.

7 Q. Now, looking at the thing quite generally, you have

8 explained that there were four such meetings with

9 Rosemary Nelson?

10 A. Yes.

11 Q. And you have done what you can to help us with the

12 timeframe, with the dates. Can I ask you, during that

13 period, the period of your contact with her, how did you

14 communicate with her? Did you communicate between the

15 meetings and, if so, how did that take place?

16 A. Yes, phone calls and I think there was probably a couple

17 of letters.

18 Q. Before the first meeting, did you have a telephone

19 conversation or conversations with her?

20 A. No, I don't recall that I did.

21 Q. Thank you. Now, the first meeting you explain took

22 place at Heathrow airport. This is paragraph 6 of your

23 statement at RNI-803-075 (displayed), and you were with

24 her, you say, for less than an hour?

25 A. That's right.





1 Q. What was her response when you, having told her about

2 the case, asked for her advice?

3 A. Well, she was quite inquisitive. She asked a lot of

4 questions and I did not have an awful lot of paperwork

5 with me, so I would imagine it was kind of off-the-cuff

6 meetings. So she took everything in and we agreed to

7 meet at a later date.

8 Q. But she certainly didn't agree to take the case on

9 immediately, did she?

10 A. No, she certainly didn't because she didn't understand

11 all the details and I did not have everything with me.

12 Q. What is it that you were asking her to do?

13 A. I wasn't really sure, to be honest. At that point I

14 was -- when I say an investigation, it was me and some

15 members of my family who were investigating this. So we

16 didn't really know what to do with what we had.

17 I certainly couldn't go to the RUC with it. I had made

18 some enquiries to very senior people in the RUC and we

19 had got a closed door. So like an awful lot of people

20 in Northern Ireland, I have got some information here,

21 what do I do with it.

22 So it wasn't really clear. I was just looking for

23 best advice on what we could do.

24 Q. So essentially you were looking for her help on what you

25 could do, what steps you could take?





1 A. Yes, that's correct.

2 Q. You say in your statement at the top of

3 page RNI-803-076, the same paragraph 7 (displayed), that

4 you think she had misgivings about getting involved

5 initially. What makes you say that?

6 A. Yes, well, she didn't have the full details and, you

7 know, I was giving her kind of a potted account of what

8 I had done so far and what I believed, you know,

9 evidence that I had come up with. But, you know, she

10 didn't know me from Adam. She hadn't got, you know, any

11 of the written details that I had and some of the

12 evidence. So I guess she was just unsure about taking

13 it on.

14 Q. So the problem was perhaps a lack of sufficient

15 information rather than anything in particular?

16 A. Yes.

17 Q. About the case?

18 A. Yes.

19 Q. Thank you. But you then say in the same paragraph, if

20 you read on:

21 "As time went by, I began to understand her initial

22 caution given some of the things she later told me in

23 relation to her dealings with the RUC."

24 Can you help us: What do you mean by that?

25 A. Well, later, when I guess she could trust me, she told





1 me about some of the dealings that she had had with the

2 RUC and I guess she was trying to reconcile in her mind

3 perhaps taking on a case involving, you know, a murdered

4 RUC's family as clients and given perhaps some of the

5 dealings she had had with the RUC. So I guess she was

6 kind to reconcile that.

7 Q. Now, in the same paragraph, you say that:

8 "In this very first meeting I believe Rosemary may

9 have told me that she had been threatened."

10 Are you sure about that or might it have been in the

11 later meetings?

12 A. I am not absolutely sure so I can't say that. It could

13 have been, but I am not absolutely sure.

14 Q. We will return to that in due course.

15 After the first meeting, it looks as though you went

16 away saying that you would get her more information. Is

17 that right?

18 A. That is correct.

19 Q. And you say in paragraph 8 that you exchanged

20 correspondence?

21 A. Yes.

22 Q. And then you had your second meeting which took place at

23 her office in Lurgan. Is that right?

24 A. That is correct.

25 Q. Again, I am sorry to keep doing this but can you help us





1 any more than you have a date for that meeting?

2 A. No, I am sorry, I can't.

3 Q. So, late 1997/early 1998, you say?

4 A. Yes.

5 Q. Thank you. As you came to the second meeting, it is

6 right, isn't it, that she had not at that stage agreed

7 to take on the case?

8 A. That's correct.

9 Q. Thank you. And what you do in your paragraph 9 is to

10 give us a description of the office.

11 A. Yes.

12 Q. And there is a particular phrase I would like to ask you

13 about. You say:

14 "It was an extremely unusual set-up, a bit like

15 a canteen."

16 Can you explain what you mean by that?

17 A. When I walked in the door, it was easy access, first of

18 all. There didn't appear to be any security in the

19 place, which surprised me somewhat, and when I walked

20 in, there was like a hatch and there was obviously case

21 files in the back of it and a little kind of counter,

22 but there was nobody around. So the image of the hatch

23 sort of portrays canteen, if you like. And there was

24 nobody around. I was quite surprised.

25 It seemed very informal but I was quite taken aback





1 by that actually. So I just wandered up the stairs

2 myself to seek out Rosemary.

3 Q. So you were able to walk in off the street, walk past

4 what was in fact reception, the hatch?

5 A. Reception, yes.

6 Q. To you it looked like a food servery?

7 A. Yes.

8 Q. But you walked past that and up the stairs, presumably

9 where you found Rosemary Nelson's office?

10 A. Yes.

11 Q. Thank you. Now, so far as the second meeting is

12 concerned, once you had made your way to her office, you

13 say in that meeting you handed over a copy of what you

14 call the RUC's file that had been put together and you

15 said you believed it to be extremely useful to the case.

16 So this was presumably yet further information you were

17 giving her?

18 A. Yes, it was very detailed information regarding the file

19 that was put together against McCormick at the time.

20 Q. But again, you had your meeting, you handed over the

21 file, but is this right: she did not agree to take on

22 the case in the course of that meeting either?

23 A. That's correct, because I was still investigating and I

24 was still meeting people and taking notes of interviews

25 with people, and I was getting help from journalists as





1 well. So I was still, if you like, investigating.

2 Q. And does that explain why, at this stage at any rate,

3 there was no discussion about fees, about payment?

4 A. That is correct. It is quite a bulky file so

5 I appreciated that Rosemary needed to read through that

6 to understand the real detail of the case and the issues

7 that we had.

8 Q. But it follows, doesn't it, that as far as you were

9 aware, the time she had spent on the case, the first

10 meeting, looking at the further information you gave,

11 the second meeting, looking at the file you then handed

12 over, all of that, as far as you were aware, she was not

13 charging, she was not generating fees for you?

14 A. Absolutely not.

15 Q. And you didn't have to pay her at any stage, I think,

16 for that work?

17 A. No, I didn't.

18 Q. Thank you. So as I understand it, the result of this

19 meeting is that you left her with the file and she would

20 read it, and when she had read it there would be perhaps

21 a third meeting?

22 A. That is correct.

23 Q. Is that right? Yes.

24 Now, the third meeting which you deal with in

25 paragraph 12 took place in the same office in Lurgan.





1 And again, you say in the second sentence -- this is

2 RNI-803-077 (displayed) -- you can't remember the date.

3 Presumably by this stage you had got used to the layout

4 of the office.

5 Can you remember this time whether you were able to

6 walk in without seeing anybody at reception?

7 A. There was somebody at reception this time.

8 Q. And you were presumably shown into the waiting room?

9 A. That's right.

10 Q. And eventually shown up to the office in perhaps the

11 more conventional way?

12 A. That is correct.

13 Q. Thank you. Now, you say, so far as I am concerned, that

14 the relevant parts begin in paragraph 14 of your

15 statement about this meeting. You say that she was very

16 surprised, to put it mildly, when she heard what you had

17 been up to. This is what you have described for us

18 earlier in your statement. And one gets the impression

19 from the statement that this was something of

20 a watershed?

21 A. Yes.

22 Q. Because it was after that, wasn't it, that, as you

23 describe it, she opened up?

24 A. Yes.

25 Q. And it was in this meeting, as you explain, that she





1 started to tell you about her own work and her own

2 experiences?

3 A. That is correct.

4 Q. Thank you. At the bottom of the page, if you see in

5 paragraph 16, you tell us that it was in the course of

6 that meeting that she told you about threats she had

7 received.

8 So far as that is concerned, you give us

9 a particular example over the page in the rest of

10 paragraph 16. Before I ask you about that, was that the

11 only example of threats that she mentioned?

12 A. I believe it was at that meeting and possibly one of the

13 others but certainly at that one.

14 Q. Okay. In your own words, can you tell us what she

15 explained to you had happened to her at the courthouse?

16 A. Yes. She said that -- obviously, the courthouse was

17 somewhere that she did an awful lot of work and she told

18 me that she had been threatened by a named senior RUC

19 officer. She told me his name, and I can't remember the

20 name because it was of no significance to me at the time

21 or since, but she told me that she had been threatened

22 on two occasions by a senior RUC officer while she was

23 in or around the courthouse.

24 Q. And so I am clear about this, you set out some words

25 that she told you were spoken to her by the officer.





1 Was it your understanding that the same words were used

2 on both occasions?

3 A. Yes.

4 Q. And you then say:

5 "I took this to mean a threat on her life."

6 From your conversation with her, was it clear that

7 she also understood the words in that way?

8 A. Yes, it was.

9 Q. Yes, and that this had happened to her before; in other

10 words she had been threatened by the police --

11 A. Yes.

12 Q. -- but as far as I can see from your earlier answers,

13 she did not in this meeting give you any further

14 details?

15 A. No, she didn't. I think she was empathising with me

16 after where I had just been, and I think that is why she

17 opened up a little bit to me.

18 Q. But you then make this interesting comment:

19 "... but that she had to get on with life."

20 Now, is that based on something she said to you?

21 A. Yes, she said, you know, you can't -- something along

22 the lines of, "You can't worry every day of your life,

23 you have you have to get on with life" and I understood

24 what she meant by that.

25 Q. Do you think she included, "You have got to get on with





1 your work"?

2 A. Yes, life -- that term means get on with your work and

3 your everyday life, family -- so both.

4 Q. So were you able to assess from what she said to you

5 whether, despite her determination to get on with her

6 work, she was troubled by or frightened by these

7 threats?

8 A. She would have to be, because, you know, when --

9 I'll just position this a bit.

10 After I had come back from seeing Robin Jackson and

11 I saw the look on her face when I told her where I had

12 been and she opened up to me, I did realise that some of

13 the things that I was doing were probably quite

14 dangerous. So when she shared with me the threats that

15 had been made to her, I identified with what she was

16 talking about. But I definitely took it that it was

17 a serious -- it was serious to her but that, you know,

18 she couldn't lock herself up in her house and not go to

19 work and not do normal things that anyone would do with

20 her family. So she had to get on with her life and her

21 work.

22 Q. You say in this same paragraph:

23 "I had no doubt she was genuine but she did not seem

24 too concerned."

25 Is that based on the way she presented it to you?





1 A. The way she presented it to me, but I understood what

2 she meant.

3 Q. Can I just ask you a couple of more questions about the

4 incidents as she described them. You said that you

5 can't remember the name of the officer. Can you

6 remember whether she gave you his rank?

7 A. I think she did but I honestly can't remember.

8 Q. Thank you. Again, a question, I am afraid, about

9 timing. In the conversation, did she tell you when

10 these events had taken place?

11 A. I don't think she told me the exact dates but it seemed

12 to me that it was fairly recent.

13 Q. Fairly recent?

14 A. Yes.

15 Q. Ie shortly before the meeting?

16 A. It seemed in the weeks or months beforehand.

17 Q. Yes, thank you. But it seems clear from your statement

18 that there was nothing in the conversation you had that

19 made you believe that she would be put off from or

20 diverted from taking on your case?

21 A. That's correct.

22 Q. And you say that you probably didn't understand at the

23 time, I think you mean, the environment in which she was

24 doing her work?

25 A. I didn't.





1 Q. Do you mean by that that you weren't sufficiently aware

2 because you weren't living in Northern Ireland?

3 A. Well, no, I hadn't really thought about it very much to

4 be honest, but you know, when you stand back and think

5 about it, you know, some of the cases that she was

6 involved in, she was in media focus, she was involved in

7 some very controversial cases. So I can imagine, you

8 know, when you think about it, just what it must have

9 been like for her.

10 Q. Did that at least begin to come home to you during the

11 course of this third meeting?

12 A. It did, but I think ultimately for me when Rosemary was

13 murdered, then you reflect on just what it must have

14 been like.

15 Q. Now, at the end of this third meeting, did she agree to

16 take on your case?

17 A. Yes, I believe she did.

18 Q. She did. Is it possible for you to help us at this

19 point in time as to what it was that enabled her to make

20 that decision following the third meeting?

21 A. Well, she had had the opportunity to read the file. She

22 understood what issues we had and I, of course, was

23 still investigating, still meeting people, still making

24 notes. So I believe it was probably because she had

25 read the statement and understood what the issues were





1 when we talked about that.

2 Q. In paragraph 20 at RNI-803-080 (displayed), you put

3 forward a suggestion about this slightly different to

4 the one you have just given us. You say:

5 "I think by the end of our third meeting, Rosemary

6 realised it was not ..."

7 That's the case:

8 "... not about giving the RUC a kicking, but that

9 the family just wanted to know the truth about my

10 father's murder."

11 A. Yes.

12 Q. And that's how you see it today, is it?

13 A. That is how I see it today retrospectively, because

14 obviously my statement is some years later.

15 Q. Yes. So she agreed to take it on and we know that there

16 was one further meeting between you?

17 A. Yes.

18 Q. Presumably there was, again, communication between the

19 two of you?

20 A. Yes, I sent some notes and we had some telephone calls.

21 Q. But was there any particular plan as to what was going

22 to happen, what she was going to do with the case now

23 that she had agreed to take it on?

24 A. No, not a plan at that stage, because she obviously had

25 to assess everything that I had. But we had talked





1 about a couple of options; perhaps a civil case against

2 the RUC or taking the case to European Court.

3 Q. Now, you describe the fourth meeting in paragraph 22,

4 which is RNI-803-081 (displayed). Again, you are not

5 able to put a precise date on it but you think it is

6 some time in 1998?

7 A. Yes.

8 Q. And it was a meeting to catch up on further progress.

9 From the way you talk about this meeting, it sounds as

10 though it was, as it were, business-like?

11 A. Yes.

12 Q. And so I infer from it that you didn't have the sort of

13 personal conversation that you had had on the third

14 meeting?

15 A. No, that is correct.

16 Q. So is this right: there was no further reference by her

17 to threats, for example?

18 A. No, I can't recall that.

19 Q. Thank you. Can I just ask you this question about how

20 the case was to be handled -- because this was the last

21 meeting, as we know -- picking up what I asked you

22 before. By this stage she had agreed to take on the

23 case. Did you then have a discussion about fees?

24 A. No discussion about fees.

25 Q. Was there ever a discussion about fees in relation to





1 the case?

2 A. No.

3 Q. Did you ever pay her for her work?

4 A. No.

5 Q. Thank you. Now, you say that after the meeting you

6 would have kept in touch with her up to the time of her

7 murder, but again, just could you confirm this,

8 please -- this is paragraph 24, RNI-803-081

9 (displayed) -- that you didn't return to the personal

10 circumstances and the question of threats at any stage?

11 A. That is correct.

12 Q. Thank you very much.

13 Mr Campbell, there is one final question I have for

14 you, which is this: if there is any matter we haven't

15 covered in the course of our discussion but which you

16 would like to raise with the Inquiry panel to assist

17 them in their work, please feel free to raise it now.

18 A. Yes, I would just like to say that the day I went to see

19 Robin Jackson in his home, Martin O'Hagan had

20 accompanied me and I was also aware of the threats

21 to Martin O'Hagan. So I understood retrospectively when

22 I looked back, Martin passed it off probably the same

23 way that Rosemary did.

24 It is bizarre really that two people that I had

25 become quite close to professionally and personally that





1 they were both murdered, but I identified with the

2 threats that they were -- and the environment that they

3 were working in.

4 Q. Thank you.

5 THE CHAIRMAN: Mr Campbell, thank you very much for coming

6 to the Inquiry to help us.

7 A. Thank you.

8 THE CHAIRMAN: We will adjourn now for a quarter of an hour

9 this morning.

10 (10.45 am)

11 (Short break)

12 (11.00 am)

13 THE CHAIRMAN: Yes, Mr Phillips.


15 Questions by MR PHILLIPS

16 MR PHILLIPS: Mrs Bradshaw, can you give us your full names,

17 please.

18 A. Bernadette Marie Bradshaw.

19 Q. Thank you. Can I ask you, please, to look first at the

20 statement you have made to the Inquiry, which I hope you

21 have got there with you. It will come up on the screen,

22 RNI-802-017 (displayed), thank you very much. If we go

23 over, please, to RNI-802-024 (displayed), do we see your

24 signature there and the date of 4th January last year?

25 A. Yes.





1 Q. Thank you. I would like you to look at three short

2 statements that you made to the police after the time of

3 Rosemary Nelson's murder: The first, please, at

4 RNI-830-011 (displayed), dated 24th March; the second at

5 RNI-830-013 (displayed), dated 11th May that year; and

6 then the next one at RNI-830-014 (displayed),

7 24th May 1999.

8 You were then Bernadette Rogers, you are now

9 Bernadette Bradshaw?

10 A. Yes.

11 Q. Thank you. Now, could we stick with one of the police

12 statements first, please, and look at RNI-830-011

13 (displayed). You say in that statement that you had

14 been working at Rosemary Nelson's office

15 since June 1996?

16 A. Yes.

17 Q. Can I ask you, what led you to apply to work for the

18 firm?

19 A. I had been working in another solicitor's office in the

20 town and I applied to work for a local newspaper.

21 I worked there for about a year. It wasn't what

22 I thought it was going to be and I wanted to go back to

23 what I knew and I applied for the job with Rosemary's

24 office.

25 Q. What did you know about the practice before you





1 joined it?

2 A. Not much, to be quite honest, only that -- I didn't know

3 a whole lot about it, to be quite honest, no.

4 Q. But you joined to work as a secretary. Is that right?

5 A. Yes.

6 Q. As you say in paragraph 2 of your statement to the

7 Inquiry -- that is RNI-802-017 (displayed) -- you were

8 hired as Rosemary's personal secretary; is the way you

9 put it?

10 A. Yes.

11 Q. But in fact everyone who worked there was her secretary?

12 A. Yes.

13 Q. And that is the impression we have had from other

14 witnesses: that in a sense all the other employees

15 worked for her?

16 A. Yes.

17 Q. And, whether as secretaries or not, took an active part

18 in the cases that came into the practice. Is that fair?

19 A. Yes.

20 Q. And how long did you work at the practice?

21 A. I think for about three or four years. I can't remember

22 now.

23 Q. You were still working at the time of her murder,

24 weren't you?

25 A. Yes, and for about a year or so after that.





1 Q. Did you carry on until the practice was disbanded

2 eventually?

3 A. Yes, there was probably a few months before it finally

4 closed.

5 Q. Thank you. During the time you were working at the

6 practice, did you see Rosemary Nelson socially as well

7 as during business hours?

8 A. Only on, like, Christmas or special occasions, if there

9 was a wedding or something.

10 Q. And how would you describe your relationship with her?

11 A. It was a good working relationship. I wouldn't have

12 said that I knew her greatly on a personal level, but

13 she was a very approachable person. So if something was

14 bothering you, you could have went to her.

15 Q. When you joined the firm in June 1996, what was the

16 atmosphere like in the practice?

17 A. It was really nice atmosphere. Everybody seemed -- we

18 were basically all in the one room. Everybody worked

19 together and it was a nice place to work. I was glad

20 I started there.

21 Q. It was a friendly atmosphere?

22 A. Yes.

23 Q. At the time when you joined, when you say you were all

24 working in one room, was this at the time when you were

25 just on one floor of the building or were you already on





1 both floors?

2 A. No, when I started we were on one floor.

3 Q. And downstairs was the hairdressers?

4 A. Yes.

5 Q. Thank you.

6 Now, you say in paragraph 3 of your statement -- it

7 is on the same page, RNI-802-017 (displayed) -- that you

8 were originally hired to do the conveyancing work

9 because that is work you had done before?

10 A. Yes.

11 Q. Is that at a previous solicitor's office?

12 A. Yes.

13 Q. But you also did some other work -- matrimonial and

14 criminal -- but that when a big case, a high profile

15 case, as you put it, came in, you all got involved?

16 A. Yes.

17 Q. So that the employees would simply get their energies

18 directed into whatever was required for the big cases?

19 A. Yes.

20 Q. Thank you. And you say this:

21 "We were generally left to get on with the work

22 ourselves."

23 In other words, there was a lot of delegation to

24 you?

25 A. Yes.





1 Q. And the day-to-day running of files was done by you and

2 your colleagues rather than by Rosemary Nelson?

3 A. Yes.

4 Q. Thank you. But that was obviously something from your

5 statement anyway that you were happy with?

6 A. Yes.

7 Q. And you described her as being a good boss?

8 A. Hm-mm.

9 Q. Now, what you tell us in your statement in paragraph 6

10 is that it was often busy, people were working very,

11 very hard and staying late?

12 A. Yes, and we often worked overtime.

13 Q. So that in addition to looking after your own files, you

14 would have to spend time helping out with the big cases?

15 A. Yes.

16 Q. You then tell us about the lawyers, the solicitors who

17 were working there, and you say that by the time of

18 Rosemary Nelson's death there was only one solicitor in

19 the practice?

20 A. Yes, Pat Vernon.

21 Q. Mr Vernon, exactly. Before that, there had been two, I

22 think, hadn't there?

23 A. Yes, Brian Leeson and Sharon Keeley.

24 Q. Thank you. Now, so far as the way in which

25 Rosemary Nelson carried on her work is concerned, the





1 impression one gets from your statement, paragraph 7, is

2 that she was very much the front person for the

3 practice?

4 A. Yes.

5 Q. She would get the work in?

6 A. Hm-mm.

7 Q. She would make and have the initial contact with the

8 clients?

9 A. Yes.

10 Q. But that in the vast majority of cases, the subsequent

11 work was done by other people in the firm?

12 A. Yes.

13 Q. Not just the solicitors but also the secretaries and

14 others?

15 A. Yes.

16 Q. Thank you. And you say that she was seen as a fighter?

17 A. Definitely, yes.

18 Q. Is that by people in the office?

19 A. I think generally, just with the clients who would have

20 come to her with cases that maybe nobody else would have

21 been interested in, you know.

22 A prime example would be for the local travellers'

23 community. There was kind of like a stigma attached to

24 the travellers and she had took on their case as well.

25 You know, it wasn't just criminal or political things,





1 it was broad ranging.

2 Q. Can you remember when she took that case on?

3 A. No, I don't.

4 Q. Was it shortly after you joined, just before --

5 A. No, it would have been a while after I joined, maybe

6 a year or so after I joined.

7 Q. What was the work she did for the travellers?

8 A. I don't think there was a lot of actual going to court

9 or anything at that point. There was a lot of

10 consultation with the travellers' committee. I am not

11 sure what actually happened. I didn't work a whole lot

12 on it, to be quite honest.

13 Q. That is what I was going to ask you. Were you involved

14 in that work?

15 A. No, I might have done a couple of letters or phone calls

16 or something, I don't really remember.

17 Q. That is the sort of example, is it, of the sort of

18 unpopular case that she would take on?

19 A. Yes.

20 Q. You also say that she was known for taking on difficult

21 cases even if there wasn't a snowball's chance in hell

22 of a case succeeding?

23 A. Yes.

24 Q. Can you think of a case like that?

25 A. The travellers one again has just come to mind. The





1 local community, there was a lot of contentious issues

2 with the local community and the travellers. Her

3 actually taking that on and even consulting with the

4 travellers' committee, I think.

5 Q. And so far as that reputation, the way she was seen,

6 goes, do you think that was a reputation she had in the

7 town as well as in the office and amongst other clients?

8 A. Yes.

9 Q. Were there cases that she did spend time on after the

10 initial contact with the client?

11 A. Yes.

12 Q. Which were they?

13 A. Well, she worked hard on the Garvaghy Road residents

14 cases, Colin Duffy's case. There was lots. They are

15 big cases so they are sticking in my head.

16 Q. She was passionate about her work, wasn't she?

17 A. Yes, very much so.

18 Q. You say in your statement at paragraph 41 -- this is at

19 RNI-802-024 (displayed) -- that the passion she had,

20 strong passion, was for the downtrodden generally?

21 A. Yes.

22 Q. Rather than anyone or anybody in particular?

23 A. Hm-mm.

24 Q. And again, would the travellers' case be a good example

25 of that?





1 A. Yes.

2 Q. In paragraph 8, you talk about the question of payment

3 or fees for the work. You weren't of course handling

4 the money side directly, were you?

5 A. No.

6 Q. But would you be processing the relevant forms as part

7 of your work?

8 A. Well, as I say, I dealt mainly with conveyancing. I

9 would have issued bills in that regard. On other

10 occasions, if -- obviously, if Rosemary or one of the

11 other solicitors had seen clients and got them to sign

12 the forms, we would have maybe just filled out the rest

13 of them.

14 Q. To your knowledge did she take on work which was unpaid?

15 A. I would say so. I would say she did.

16 Q. Can you think of examples for us?

17 A. The Garvaghy Road residents. I would say there was

18 a lot of input there.

19 Q. Which you think was unpaid?

20 A. I would say so, yes.

21 Q. Yes. Just returning to the questions I was asking you

22 about the fact that she was the front woman for the

23 practice, getting in the work, when you were working

24 there, did you see her trying to generate publicity for

25 her cases?





1 A. No.

2 Q. No?

3 A. No.

4 Q. Do you remember her conducting interviews with the

5 media, for example?

6 A. I was never around when she done that. I did see her on

7 TV. I was never around.

8 Q. But as far as your view of matters is concerned, you

9 didn't experience her seeking publicity in that way?

10 A. No, definitely not.

11 Q. Thank you. Now, I would like now to ask you some

12 questions about the sort of clients the firm had and,

13 first of all, the sort of clients the firm had at the

14 beginning, ie when you first joined in June 1996. If

15 you look, please, at paragraph 11 on RNI-802-019

16 (displayed), you say:

17 "When I first started, the clients used to come from

18 all over the community. Rosemary was very well liked.

19 As a result of the Garvaghy Road and Colin Duffy cases,

20 there was a lot of media attention and gradually people

21 from the other side of town did not want to come in.

22 The practice obtained work from mainly Catholic clients

23 towards the end mainly because of the high profile of

24 the practice."

25 A. That is a personal opinion.





1 Q. That is your personal opinion?

2 A. Yes.

3 Q. And based on your, perhaps, just under three years working

4 there, is it before the time of her murder?

5 A. Yes.

6 Q. What was it that you noticed, that you observed, that

7 made you have that view?

8 A. Well, Lurgan was and probably still is very much

9 divided. There is Catholics at one end and Protestants

10 at the other end. We would have got a lot of

11 instructions from estate agents at the other end of

12 town, which then obviously brought -- the clients were

13 coming from the other end of town. That phased out. I

14 would say probably due to the high profile of the

15 Colin Duffy case.

16 Q. That case, does that help you to put a date, a rough

17 date, on that change?

18 A. No, I couldn't -- I couldn't say for certain. It is too

19 long ago.

20 Q. Might the change have happened after 1997? Does that

21 sound right?

22 A. Yes, probably.

23 Q. You obviously observed this change. Was it something

24 that concerned you?

25 A. Not immediately, no.





1 Q. Did it come to concern you?

2 A. It did, yes.

3 Q. Why?

4 A. Well, if somebody asked me where I worked, sometimes I

5 didn't like to say, to be quite honest. During the

6 marching season, in July in particular, I was actually

7 quite frightened working there and I know some of the

8 other girls were. We often pulled the shutters down.

9 Q. You set that out for us in your statement?

10 A. Yes.

11 Q. So the atmosphere was tense --

12 A. Yes.

13 Q. -- at those times of year?

14 A. Yes.

15 Q. Was it tense at other times of year?

16 A. No. I think -- when you are in a situation for so long,

17 sometimes it becomes the norm, if you like.

18 Q. But you were concerned about it?

19 A. Yes.

20 Q. You were concerned for your own safety?

21 A. Yes.

22 Q. Do you think that was a concern shared by other members

23 of staff?

24 A. Yes.

25 Q. And I think it is right, isn't it, that you continue





1 not, as you put it, really to mention it when you are

2 applying for jobs?

3 A. Yes.

4 Q. That is paragraph 42 of your statement. Certainly at

5 the time it was something that you were worried about

6 and that led you not to mention your place of work?

7 A. Yes.

8 Q. You have mentioned about the putting the shutters down.

9 Were there other things that people tried to do to deal

10 with these concerns?

11 A. The doors would have been locked if we were doing

12 overtime. Usually they were always open.

13 Q. That is what we have heard from a number of witnesses,

14 that normally the office was very open, people could

15 just walk off the street, but at these times you changed

16 that, did you?

17 A. I wouldn't say they could just walk -- they could go

18 into the reception area, yes.

19 It was interesting when I heard Mr Campbell's -- he

20 said that he just walked on up the stairs. It would

21 have been interesting to know what particular time he

22 went in. Sometimes after hours, when everybody went

23 home, obviously there wouldn't have been a secretary or

24 receptionist there and that is why he probably just

25 walked on up the stairs. But usually the reception





1 wasn't left unattended.

2 Q. But getting back to what you were telling us, so one of

3 the things you would do at those times of year would be

4 to make sure the door was closed?

5 A. Only after business hours, yes.

6 Q. Thank you. So far as the work that you did at the

7 practice is concerned, you tell us in your statement

8 that you took part with other members of the firm in the

9 statement-taking of the residents, the Garvaghy Road

10 residents, and I think this was following the July 1997

11 march, wasn't it?

12 A. Yes.

13 Q. And this is paragraph 13 on page RNI-802-019

14 (displayed). We have heard from other witnesses that

15 the office decamped to a hall down by the Garvaghy Road

16 where all the witness statements were taken. Do you

17 remember taking part in that?

18 A. No, I didn't.

19 Q. Do you remember being asked to do so?

20 A. No.

21 Q. No. Now, so far as the high profile cases are

22 concerned, you tell us in paragraph 12 that Colin Duffy

23 was already a client of the firm at the time you

24 arrived?

25 A. Yes. I didn't know who Colin Duffy was.





1 Q. Before you arrived?

2 A. Yes.

3 Q. No. And you think that at the time you started with the

4 practice, the appeal was ongoing?

5 A. Yes.

6 Q. And in terms of the high profile cases, is it right then

7 that it is those two cases, Mr Duffy's case and the work

8 for the Garvaghy Road, that stick out in your mind?

9 A. Yes.

10 Q. Am I right, therefore, to assume that you connect the

11 change in the profile of the practice with those cases?

12 A. Definitely.

13 Q. Would you be able to say whether it was, as it were, the

14 one or the other in particular that changed the profile?

15 A. Probably a combination of the two.

16 Q. A combination of the two.

17 A. As I say, when I was -- Colin Duffy was already

18 a client. There was already media attention on that

19 particular case and I was still looking after

20 conveyancing work from both ends of the town. I think

21 it was probably the Garvaghy Road incident just topped

22 it off.

23 Q. In relation to the Garvaghy Road case, you talk in

24 paragraphs 13 and 14 about your understanding of the

25 nature of that work. As you have already said, I think,





1 as far as you know, there was no payment for that work.

2 That is paragraph 14. Did you understand this work to

3 be political?

4 A. I could see how it could be perceived to be political.

5 I don't think that was Rosemary's view on it, though.

6 Q. What do you think her view was?

7 A. It was more for the residents, you know. It wasn't

8 anything to do with orange and green; it was more that

9 there was -- people on the Garvaghy Road had, I don't

10 know, been put out because people from the other end of

11 town who didn't live there wanted to walk down their

12 road.

13 Q. But you were aware then, were you, that that sort of

14 work was perceived to be political?

15 A. Yes.

16 Q. Is that something you discussed with Rosemary Nelson?

17 A. No.

18 Q. You didn't discuss the way her work was perceived?

19 A. No.

20 Q. Now, in paragraph 16 on the next page, RNI-802-020

21 (displayed), you say this:

22 "I can see how it would look in terms of her

23 representing certain high profile clients."

24 Can you help me: What do you mean by that?

25 A. Well, obviously that she was a Catholic-based solicitor





1 and that she wanted -- I could see how maybe people from

2 the other side of the community would pigeonhole her as

3 being someone who only wanted to act for Catholics.

4 Q. Do you think that it would look to them as though she

5 was connected with or linked to the other side?

6 A. Other side?

7 Q. The other side of the community.

8 A. Yes.

9 Q. And you say in the same paragraph:

10 "There was a suggestion that she was linked to that

11 kind of organisation but I have nothing to say about

12 that. I don't think she was into the Provisionals."

13 A. I think that was a question posed to me and I didn't

14 want to comment.

15 Q. Yes, but were you aware at the time that people might

16 view her as being linked to a paramilitary organisation

17 because of her work?

18 A. I think it was just general chitter. It was all

19 nonsensical or non-founded, you know.

20 Q. But as far as you are concerned, she didn't have any

21 sectarian motivation?

22 A. No, definitely not.

23 Q. And she was concerned, wasn't she, by the way in which

24 the direction of her practice was perceived?

25 A. I think she was.





1 Q. That is why you say, as you do in the second sentence:

2 "I know that she didn't want the office to think

3 that that was the direction she was going."

4 So was that based on something she said to you?

5 A. I don't remember. I am reading that and I don't

6 remember having a conversation in which she said that

7 she was concerned.

8 Q. But were you -- sorry.

9 A. There might have been. I have said that for a reason.

10 Q. Do you think you were aware then of a concern on her

11 part about this perception?

12 A. I am not sure.

13 Q. Do you think the direction the practice went, the

14 changes you have described to us, do you think those

15 were changes that worried her?

16 A. I am sure they did. I mean, she was a mother, you know,

17 first and foremost and I am sure she was afraid of the

18 impact that any work that she did would have on her

19 family.

20 Q. So what you mean by that presumably is fear for her own

21 safety?

22 A. Yes.

23 Q. And for the safety of her family?

24 A. Yes.

25 Q. If she didn't talk to you about these things, were you





1 aware that she had talked to other members of staff

2 about them?

3 A. Yes.

4 Q. And you learned of them from them?

5 A. Yes.

6 Q. And did you see at the time a connection between this,

7 her reputation, the way the practice was seen as going

8 and the threats that you mention in paragraph 17?

9 A. Yes.

10 Q. You see a direct connection?

11 A. Yes.

12 Q. Now, was the fact that she was receiving threats

13 a matter discussed in the office?

14 A. Direct threats to her sometimes came second-hand. I

15 would never have actually talked directly to her about

16 it. It wasn't until I opened some threatening letters.

17 Q. We know from your police statements, for example, that

18 after the murder you opened, I think, two letters?

19 A. Yes.

20 Q. Can we talk first about before the murder?

21 A. Okay, sorry.

22 Q. Not at all. Your awareness of threats then came

23 second-hand?

24 A. Yes.

25 Q. And again, can I ask you, did it come as a result of





1 talking to other members of staff?

2 A. Yes.

3 Q. Thank you. You didn't take any of the telephone calls,

4 for example?

5 A. I wasn't aware that I did. That is not to say that

6 I actually --

7 Q. If you did take them, you have forgotten them?

8 A. No, what I am saying is that I know there is talk and

9 you'll see in my statement that I put a call through to

10 Rosemary which turned out to be a threatening telephone

11 call. When I took the call, I obviously -- whoever it

12 was claimed to be somebody she knew, otherwise she

13 wouldn't have taken the call.

14 Q. You say that you did have a conversation with her --

15 this is paragraph 18 -- about security. Can you help us

16 with a rough date for that?

17 A. I can't. I don't know.

18 Q. And you give brief details of it:

19 "She did mention her security to me at one point and

20 possibly having people round to her house to enhance it,

21 but I am not sure whether she ever did anything

22 about it."

23 Can you help us with any more detail about this?

24 Was this a matter that she raised with you?

25 A. I have obviously been in her office talking about work





1 and it has led on to talking about that. I don't recall

2 the conversation directly though.

3 Q. Were you at the time concerned for her?

4 A. Yes.

5 Q. So do you think you might have raised this question of

6 her security with her?

7 A. No, I don't think so. I don't think I would have.

8 Q. You think she will have raised it with you?

9 A. Yes. Maybe -- because I know that there was -- at one

10 point there was a letter or something that she had

11 received and she had torn up, and I think it has

12 probably come from that.

13 Q. So you think it was prompted by a threat letter?

14 A. Yes.

15 Q. And what did she say to you about having people round to

16 her house to enhance it?

17 A. Well, Rosemary would have just brushed things off as if

18 they didn't concern her. I think it would have been

19 just like a flippant comment, just like that. She would

20 have just said it exactly like that.

21 Q. She kept up a brave face?

22 A. Yes, definitely.

23 Q. You say in the next paragraph:

24 "Rosemary would not have let us know that she was

25 frightened."





1 A. No, she wouldn't have appeared frightened.

2 Q. But I am sure that she was, you say?

3 A. Yes.

4 Q. And that was a view you held at the time?

5 A. Yes.

6 Q. What was it based on?

7 A. Well, the talk within the office of the threats that she

8 had been receiving. I know that when she was -- some of

9 her clients were being questioned, she was indirectly

10 threatened then. So there was a lot of threats out

11 there.

12 Q. Getting back to the conversation about security, how

13 clear is your recollection that she told you that people

14 had come round to her house to enhance it; "it" being

15 the security issue?

16 A. I have obviously asked her did she have security at her

17 house and she has flippantly said, "I will have to get

18 somebody round". You know -- I know that it was

19 definitely talked about, I just can't remember when and

20 how we arrived at talking about that.

21 Q. But was she referring to something that she had had done

22 or something she should do in the future?

23 A. No, something that she should do.

24 Q. I see. And did she give any more detail to you than

25 that?





1 A. No.

2 Q. Now, you have said to us that you can't help with the

3 timing of that conversation. Can I ask you about the

4 timing of the threats that we were talking about

5 a little earlier and to look, please, at RNI-830-011

6 (displayed). This is the statement you made to the

7 police on 24th March, so obviously much nearer the time

8 than we are now.

9 Do you remember I showed it to you before to show

10 you your start date with the practice, June 1996?

11 A. Yes.

12 Q. If you read down the page, you will see that you told

13 the police about threatening letters.

14 A. Hm-mm.

15 Q. And you mention one in particular:

16 "A blue envelope written on blue paper. It was

17 handwritten."

18 Do you see that?

19 A. Yes.

20 Q. And you can't say exactly when it was received:

21 "It was a considerable time ago, a number of months.

22 "Question: More than six months ago?

23 "Answer: I can't be any more accurate than that."

24 Then you talk about another threat on a scrap of

25 paper, and at the bottom of the page, do you see, you





1 say:

2 "While I am not aware of when the threats started, I

3 was not aware of them during the course of the first six

4 months or more of my employment."

5 Just pausing there, that suggests, doesn't it, that

6 you first became aware of them probably in 1997?

7 A. Yes.

8 Q. And then you go on to talk about the last threat by

9 letter of which you are aware, a blue letter and

10 envelope, and you say that you think the British Irish

11 Rights Watch or CAJ could perhaps elaborate and you

12 believe a copy of the threats was passed to them.

13 I would like you to look, please, at a threat note

14 and to see whether it is one of the ones you talked

15 about in this statement. Can we have, please,

16 RNI-115-351 (displayed). Obviously it is a photocopy

17 and not a very good one, it certainly doesn't give you

18 the colour, but do you see the words of the note at the

19 bottom of the page?

20 A. Hm-mm.

21 Q. "We have you in our sights, you Republican bastard. We

22 will teach you a lesson. RIP."

23 Is that something you have seen before?

24 A. Yes, I think so. I couldn't say for certain. I am

25 almost sure. I can remember that when I received





1 letters, the writing really stood out and I would have

2 pulled it out of the bundle to open before the rest.

3 Q. And do you think that this may be the blue letter, as

4 you put it?

5 A. Yes, I think so.

6 Q. Thank you. Presumably the receipt of the letters you

7 describe in that statement, including this one, must

8 have increased the sense of concern that you had about

9 working in the practice?

10 A. Yes.

11 Q. And again, presumably this is something that didn't just

12 affect you but affected other members of staff?

13 A. Yes.

14 Q. And that you no doubt discussed together?

15 A. Hm-mm.

16 Q. Did you ever consider moving from the practice and

17 working elsewhere?

18 A. Yes.

19 Q. And was that because of these concerns?

20 A. No, I wouldn't say just because of the concerns, no.

21 Q. There were other reasons?

22 A. Probably just for more money.

23 Q. More money. Perhaps less work and more money?

24 A. More money anyway.

25 Q. Certainly. But would the concerns that you have





1 explained have played a part at least in your

2 consideration?

3 A. Maybe not at the time I made this statement, but

4 certainly in around July time, yes.

5 Q. At that time of year, when things got particularly bad?

6 A. Yes.

7 Q. Yes. Can I ask you this: you decided to stay clearly,

8 and was that partly because she was good boss?

9 A. Yes.

10 Q. And because you enjoyed the company of the people you

11 were working with?

12 A. Yes, it was a nice place to work.

13 Q. And that tipped the balance for you over the money?

14 A. Probably. She was paying good rates of pay. No one

15 else in Lurgan was paying it, so I would have had to go

16 to Belfast.

17 Q. Right, thank you.

18 Now, can I just take you back to the question, not

19 of letters, but of telephone calls. We talked about

20 this a little earlier. This is paragraph 23 of your

21 statement at RNI-802-021 (displayed), and it picks up

22 the last two sentences of the previous paragraph, where

23 you say:

24 "I know that Rosemary received a call relating to

25 her and her staff being called 'IRA bastards'. I don't





1 recall taking the call or the phrase being mentioned to

2 me ..."

3 Now, at this stage or at any stage before

4 Rosemary Nelson's murder, were you responsible for

5 incoming calls?

6 A. When the receptionist was busy, had to go to the loo, at

7 the time somebody would have covered reception. So,

8 yes, I would have taken calls.

9 Q. And generally then the calls would come through the main

10 switchboard, would they?

11 A. Yes.

12 Q. But is it right that there was also a direct line?

13 A. Yes.

14 Q. A direct line for Rosemary Nelson, I mean?

15 A. Yes.

16 Q. So clearly anybody with that number could go straight

17 through to her?

18 A. Yes.

19 Q. But you don't, as you said to us earlier, remember this

20 particular call?

21 A. No.

22 Q. And does it follow, therefore, that you can't help us

23 with the date when it might have been?

24 A. No.

25 Q. Any estimate you are prepared to make about how long





1 before the time of the murder?

2 A. No.

3 Q. No. Thank you.

4 When the calls came through to the practice, whether

5 through you or not, you have explained their effect on

6 you and other members of staff. Was there a discussion

7 about them with Rosemary Nelson or with Mr Vernon?

8 A. Maybe if someone was in -- it wouldn't have had any

9 group discussions, but if somebody had been in the room

10 and the topic just come up, they would have talked about

11 it and then we would have talked about it again

12 downstairs.

13 Q. And did you ever get given any advice, for example, as

14 to how to handle threatening calls like that?

15 A. No.

16 Q. No. Is it right to say that the atmosphere you have

17 described and the sense of concern or anxiety, did that

18 increase in the months before Rosemary Nelson's murder?

19 A. Yes, it seemed to be more constant rather than, you

20 know, "She was in the news today", you know. It just

21 seemed to be constant then.

22 Q. So that during that period it no longer was a seasonal

23 thing --

24 A. Hm-mm.

25 Q. -- in the summer, it was something that, as it were,





1 hung in the air --

2 A. Yes.

3 Q. -- month in, month out?

4 A. Yes.

5 Q. And although she wasn't revealing anything, do you think

6 that had its effect on Rosemary Nelson?

7 A. I don't know. I am sure it had but I don't know.

8 Q. Again, she said nothing to you?

9 A. Not to me directly, no.

10 Q. When we were talking about security earlier and the

11 conversation you had with her, did she say who might

12 come to advise her about her security?

13 A. No.

14 Q. She didn't mention taking advice from the police, for

15 example?

16 A. No.

17 Q. In the course of your work at the practice, were you

18 regularly in contact with the police?

19 A. I would have been at the police station a lot.

20 Q. You would go down to --

21 A. Accompany clients.

22 Q. And if this was at the local police station at Lurgan,

23 would you be then present in interviews?

24 A. Yes.

25 Q. And the impression I get is that a number of members of





1 staff would go down with clients?

2 A. Yes, hm-mm.

3 Q. So those attending the police stations would not just be

4 the solicitors?

5 A. No.

6 Q. How regularly would that happen for you?

7 A. Every other week.

8 Q. Every other week. And when you went with the clients,

9 were you, so far as the practice was concerned, always

10 on your own?

11 A. Yes.

12 Q. So you never went to accompany one of the solicitors,

13 for example?

14 A. No.

15 Q. I would like to ask you some questions about

16 Rosemary Nelson's relationship with the police. If you

17 look at paragraph 10 of your statement at RNI-802-019

18 (displayed), you say:

19 "I know there has been some suggestion that the

20 police reacted in a particularly bad way to Rosemary; I

21 don't think any ill-treatment that I may have

22 experienced was anything to do with me in particular, I

23 think it was mainly to do with the type of work I was

24 there to do ..."

25 Now, the suggestion you refer to about "the police





1 reacted in a particularly bad way to Rosemary", is that

2 based on your own experience working at the practice?

3 A. No, it was probably more to do when I attended the

4 police station with a particular client. You were

5 almost treated with contempt, I felt. Maybe I was just

6 being paranoid but that is how I felt.

7 Q. The contempt was manifested by the police officers with

8 whom you dealt?

9 A. Yes.

10 Q. Is that at Lurgan police station?

11 A. Yes.

12 Q. Did you ever attend the holding centres with clients?

13 A. No.

14 Q. How was it manifested?

15 A. They were just very, I feel, abrupt and almost rude, but

16 maybe it is just -- they were just tired of doing the

17 same thing.

18 Q. What you say in your statement is that you didn't take

19 it personally?

20 A. No.

21 Q. You thought it was because of the work you were there

22 to do?

23 A. Yes.

24 Q. Do you think it was because of the firm for whom you

25 were working?





1 A. No, probably more to do with the type of the client.

2 Q. What did you learn about Rosemary Nelson's own

3 relationship with the police?

4 A. I don't know what her relationship was to do with the

5 police.

6 Q. Was that not something that was talked about in the

7 office?

8 A. It was but I personally don't know. Rosemary never

9 discussed it with me personally.

10 Q. What was the view in the office about that?

11 A. That she was treated with contempt.

12 Q. By the police?

13 A. Yes.

14 Q. Did you learn anything from conversations in the office

15 about her own view of the police?

16 A. No.

17 Q. Now, you thought at the time, didn't you, that she

18 received a lot of hassle. It is paragraph 16 on page

19 RNI-802-020 (displayed). Do you see the last sentence:

20 "I am sure Rosemary received a lot of hassle, but we

21 would not necessarily have known much about it"?

22 A. Yes.

23 Q. So what was it that you learned which led you to say --

24 A. I know that -- again, I don't recall, it was a long time

25 ago. I know that when she went to holding centres she





1 received hassle. I think she received -- some of the

2 officers jeering at her and stuff and being suggestive

3 and, again, what the police would have said to her

4 clients, and was being reported back to her then.

5 Q. But again, this isn't something that you yourself

6 experienced?

7 A. No.

8 Q. It is something based on second-hand reports to you?

9 A. Yes.

10 Q. Can you remember when those sorts of reports began?

11 A. There was -- I can't remember details exactly but I know

12 that there was a time in Lurgan where the police were

13 raiding lots of people's houses and a lot of people were

14 being taken into Gough Barracks, and I think a lot of it

15 was done around that time.

16 Q. Might that have been in 1997?

17 A. Yes, probably, 1997/1998.

18 Q. Thank you. But you certainly didn't learn any of this

19 from Rosemary Nelson herself?

20 A. No.

21 Q. I would like to talk briefly to you now, please, and ask

22 some questions about the day of the murder itself,

23 15th March 1999.

24 You were at work that day, weren't you?

25 A. Yes.





1 Q. And you tell us in paragraph 27 and 28 that when you had

2 heard the news you went to the scene?

3 A. Yes.

4 Q. I would like to ask you some questions, please, about

5 paragraph 29 on page RNI-802-022 (displayed). You tell

6 us that you saw some police standing around Land Rovers

7 laughing?

8 A. Yes.

9 Q. Now, can you help us, please, with where you were when

10 you saw this?

11 A. Probably a couple of hundred yards away from the

12 cordoned off area.

13 Q. I am going to ask you to look at a map.

14 A. Okay.

15 Q. Can we have the Lurgan map, please (displayed).

16 Now, this is a map we have been using for various

17 purposes, hence the brightly coloured boxes. Please

18 don't be put off by them.

19 If you look at the black box, that shows

20 Rosemary Nelson's house, and the red one is where the

21 explosion took place, where the car came to rest; do you

22 see at the junction of Ashford Grange and

23 Castor Bay Road?

24 A. Yes.

25 Q. Now, can you help me: Where were you standing, can you





1 remember, when you observed the policeman laughing?

2 A. Yes, we were standing on the left-hand -- the path on

3 the left-hand side before you came to Ashford Grange.

4 This is coming from Lake Street.

5 Q. So a little further north from Fox's Glen but on the

6 other side?

7 A. Yes.

8 Q. And where were the police officers?

9 A. At both sides of the cordoned area.

10 Q. And what was it about this behaviour you describe that

11 struck you?

12 A. They just seemed very jolly, you know, something so

13 tragic, just after happening, and they were chatting to

14 each other in wee groups and huddles and laughing, and

15 it was very clear to see.

16 Q. And you weren't the only person who noticed it,

17 were you?

18 A. No, I am sure I wasn't.

19 Q. And you describe a feeling of hatred. Now, on whose

20 part was the hatred?

21 A. Of all the bystanders, everybody who knew Rosemary,

22 everybody who lived in the area.

23 Q. So the behaviour that you were seeing provoked that

24 feeling, did it?

25 A. I would say so, yes.





1 Q. And at this point Rosemary Nelson was still in the car?

2 A. Yes.

3 Q. And you saw it as an affront to decency, didn't you?

4 A. Definitely.

5 Q. Are you certain in your mind now, in 2008, that you saw

6 and heard police officers laughing at this point?

7 A. Yes.

8 Q. Did people object to the behaviour, to the police, or

9 protest?

10 A. I didn't see anything. When Rosemary was removed from

11 the scene, we made our way back to the office. We

12 didn't stay around, so I don't know what happened

13 afterwards.

14 Q. Sorry, yes.

15 I would like to ask you, please, about events after

16 the murder and about the particular letters that you

17 handled at the practice. And I would like you to look,

18 please, at your second police statement, RNI-830-013

19 (displayed) -- it is dated 11th May -- because I am

20 taking it that your recollection would have been much

21 better then than it is now.

22 A. Yes.

23 Q. You describe in the statement how, on 7th April:

24 "I was examining the mail."

25 So you were obviously handling the mail when it came





1 into the practice, and you say you:

2 "... noticed a strangely addressed letter."

3 Can you help me: what was strange about the

4 address?

5 A. I don't recall right now but I know that it must have

6 stood out. I went on to say that it reminded me of

7 a similar letter. You will notice that other letter

8 that was received was almost child-like in the writing.

9 Q. So it reminded you then, did it, of the one we saw

10 earlier on the screen?

11 A. Yes.

12 Q. The same sort of handwriting?

13 A. Yes.

14 Q. I see. Who was it addressed to?

15 A. I don't remember.

16 Q. But it was --

17 A. I know there was a letter addressed to Paul Nelson. I

18 don't know whether that was the one I am talking about

19 here.

20 Q. I think that may have been a later one, actually. We

21 will come to that in a minute.

22 A. Sorry.

23 Q. That is absolutely fine. You describe its contents as

24 being threatening and you obviously opened it and found

25 it was actually sent to Rosemary Nelson and was signed





1 "RHD"?

2 A. Yes.

3 Q. And you found its contents very weird and intimidating?

4 A. Yes.

5 Q. I am turning to the next statement you made on 24th May,

6 RNI-830-014 (displayed). This is the letter you

7 mentioned which was addressed to Mr Nelson. Again, you

8 opened the mail; is that right?

9 A. Yes.

10 Q. And it was another threatening letter.

11 A. Yes.

12 Q. And this one was written on office-type envelope and on

13 office-type memo paper?

14 A. Hm-mm.

15 Q. So it was of a different kind to the one we saw on the

16 screen, obviously?

17 A. Yes.

18 Q. Was it typed?

19 A. I don't remember -- no, I don't think so.

20 Q. But you handed it to a police officer?

21 A. Well, I handed it to Pat Vernon and he called the police.

22 Q. Thank you. Now, so far as other events after the murder

23 are concerned, were there any further telephone calls

24 that you received?

25 A. No.





1 Q. That you took?

2 A. No.

3 Q. But were you aware of other calls being made to the

4 practice?

5 A. There was a call to the practice on the day of

6 Rosemary's death.

7 Ita, one of the other girls in the office, had taken

8 the call and we were all sat in the reception area,

9 which was just off where she was taking the calls, and

10 I remember it was very clear that she was upset by what

11 she was hearing down the phone and I remember her

12 shouting something down the phone and slamming it down.

13 Q. She shouted down the phone?

14 A. She shouted back at the person on the other end.

15 Q. Did she tell you what had been said to her?

16 A. She would have, yes, but I don't remember exactly.

17 Q. If you look at paragraph 33 at RNI-802-023 (displayed),

18 you have described that call which took place on the

19 very day of the murder, but were there others perhaps

20 later that you are aware of?

21 A. I don't remember.

22 Q. It looks, doesn't it, from the statement as though there

23 was more than one, some bad calls, you say?

24 A. I don't remember. There could more than one. I am

25 only -- I was there when that call was taken so





1 I remember it.

2 Q. I will just ask you this question, Mrs Bradshaw: is

3 there any other matter you would like to mention to the

4 Inquiry panel that we haven't already covered?

5 A. No.

6 Q. Thank you very much.

7 A. Thank you.

8 THE CHAIRMAN: Mrs Bradshaw, thank you very much indeed for

9 coming to the Inquiry to give evidence before us.

10 A. Thanks.

11 MR PHILLIPS: Sir, that is all the evidence we have for

12 today. Tomorrow morning we have Ita McCrory.

13 THE CHAIRMAN: We will adjourn until quarter past ten

14 tomorrow morning.

15 (12.00 pm)

16 (The Inquiry adjourned until 10.15 am the following day)













1 I N D E X

MR JOSEPH CAMPBELL (sworn) ....................... 1
Questions by MR PHILLIPS ..................... 1
MRS BERNADETTE BRADSHAW (sworn) .................. 21
Questions by MR PHILLIPS ..................... 21