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Full Hearings
Hearing: 8th May 2008, day 16
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ROSEMARY NELSON
PUBLIC INQUIRY
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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.
4 MR JOSEPH CAMPBELL (sworn)
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
2
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?
3
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.
4
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.
5
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.
6
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?
7
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
8
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
9
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
10
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
11
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.
12
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
13
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.
14
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
15
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?
16
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.
17
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
18
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
19
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
20
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
21
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.
14 MRS BERNADETTE BRADSHAW (sworn)
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.
22
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
23
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.
24
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
25
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.
26
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
27
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,
28
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
29
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?
30
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?
31
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.
32
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.
33
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
34
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
35
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.
36
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,
37
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
38
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.
39
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
40
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
41
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
42
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."
43
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?
44
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
45
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
46
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
47
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
48
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
49
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,
50
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
51
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
52
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?
53
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
54
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.
55
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
56
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.
57
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
58
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
59
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.
60
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
61
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)
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