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Letter of Response
Letter of Response
05.03.2015 Claim issued
05.10.2015 Defence
05.11.2015 Reply to Defence
05.11.2015 Defendant’s Response to Claimant’s Part 18 Request for Further Information
01.02.2016 Order transferring case to Royal Courts of Justice
Claimant’s Response to Defendant’s Part 18 Request for Further Information.
Claimant’s Response to Defendant’s Second Part 18 Request for Further Information.
- Heading
- Evidence 14 - 16
- Defendant’s witnesses 124 - 169
- Law 201 - 203
- Analysis 215 - 216
- Introduction
- Facts; an overview
- The Parties’ Cases
- PARTICULARS OF MALICIOUS PROSECUTION
- PARTICULARS OF MISFEASANCE IN PUBLIC OFFICE
- Evidence
- Defendant’s witnesses
- Mr Deveney’s disclosure and associated evidence
- Lisa Vescio and Paul Vincent
- Case Summary and MG6
- To summarise At this juncture in the inquiry it is evident that
- MG6
- The drugs investigation
- Claimants witnesses
- Mr Breeze
- Mr Wilson
- However he also explained that
- The following points are noteworthy
- Mr Ward
- Mr Chancellor
- He continued
- Anthony Bull
- Mr Drewery
- Charles Bott KC
- Margaretha Gaisford
- Mr Cooper
- There was then a diversion into small talk and it was later stated by DS Brownsell that
- City Club Evidence
- Victor Miller
- Mr Pointer
- The restraint proceedings and the evidence of Mrs Breeze and DC Wilcox
- Other witnesses
- David Prior
- David Graham
- Mr Graham continued
- Susan Smith
- Raymond Adcock
- Sandra Grunwald
- James Braithwaite
- Richard Innes
- Sir Norman Lamb
- Corinne Scicluna
- Dr John Olive
- Defendant’s witnesses
- Closed mind
- Conduct of officers
- Pressure to achieve a result
- Health Care Commission
- Mr Cooper
- Ms Gaisford
- Deveney’s computer
- 14 th November 2006
- Linda Todd
- Mr Prior
- Dr Barker
- Missing Rough Book
- Dr Badcock
- Charges levied
- Kelling Park
- PwC
- Questionnaire
- Mr Bull
- Mr Drewery
- Exclusion from court
- Mr Breeze’s interviews
- Weight attached to other evidence
- DLA Piper letter
- Mr Ward
- DS Brownsell’s mindset
- Pleaded case
- DC Baker
- SIOs
- Mr Cooper
- 14 th November, Ms Gaisford and arrests
- City Club
- Mr Bull
- Mr Chancellor
- Mr Ward
- DC Deacon
- DC Wilcox
- DC Flynn
- Willan and Woodhead
- Mr Bull
- Mr Ward
- Judith Cass
- Draft, unsigned statement of Mr Tarrant
- Other Statements/Interviews
- Dr Barker
- And
- Linda Todd
- And in respect of the meeting to agree terms
- Documentary Evidence
- The Hird Report
- The trial and the failure of the prosecution
- After Mr Brook gave evidence Counsel took stock. As they stated
- Post Prosecution
- IPCC
- Reasonable and probable cause
- Honest belief
- Objective analysis
- Malice
- Misfeasance in public office
- Conduct in the exercise of public power
- Acting dishonestly/in bad faith
- Limitation for misfeasance in Public office
- Analysis
- The investigation and prosecution; a critique
- Interviews
- Witness tampering
- The honest belief of officers
- Other pleaded issues
- PwC
- Healthcare Commission
- Was the case summary deliberately “slanted”
- Was there reasonable and probable cause?
- Malice
- The prosecutor?
- Conclusion
- and
- Sept – Oct ’03 Cawston Park site purchased
- 25 May ’05 Management buy-out of Chancellor Care Ltd
- 15 Aug ’05 Mr Cooper commenced employment at Cawston Park as Operations Manager
- Dec 2005 (per Particulars of Claim)
- 27 Jan ’06 Allegation made by Mr Deveney to NHS CFS
- 4 July ’06 Report prepared by DS Kirkham re Operation Genus addressed to Det Supt Julian Blazeby
- 1 Aug ’06 Meeting between NHS CFS and the Major Investigation team
- 19 Sept ’06 Unannounced inspection of Cawston Park by HCC
- 29 March ’07 Statement signed by Mr Brook
- 23 Aug ’10 Outcome of Operation Meridian Review communicated to Claimants
- Letter of Response
- Amended Reply to Defence
- Conclusions