IICSA - Rochdale etc Preliminary Hearing 10 May 2017

1 Wednesday, 10 May 2017 1 directions arising from this hearing will be published 2 (10.30 am) 2 on the inquiry's website in short order after the 3 Opening remarks by THE CHAIR 3 hearing, as will the hearing transcript. 4 THE CHAIR: Good morning, and welcome to everybody here. My 4 I will now invite leading counsel to the inquiry, 5 name is Alexis Jay. I am the chair of the Independent 5 Brian Altman QC to provide us with an update on the 6 Inquiry into Child Sexual Abuse. 6 Cambridge House, Knowl View and Rochdale investigation. 7 Sitting with me are the other panel members of 7 After Mr Altman, I will invite other counsel present to 8 the inquiry: Professor Sir Malcolm Evans; Ivor Frank; 8 speak, if they wish, in the following order: counsel for 9 and Drusilla Sharpling. 9 the victims and survivors represented by 10 On behalf of the inquiry, I welcome you all to this, 10 Slater & Gordon, Laura Hoyano; counsel for Lancashire 11 the third preliminary hearing in the Cambridge House, 11 Police, Mr Alan Payne; counsel for Greater Manchester 12 Knowl View and Rochdale investigation. 12 Police, Ms Ann Studd QC; counsel for the Crown 13 This investigation, along with those into 13 Prosecution Service, Mr Edward Brown QC; and counsel for 14 Lambeth Council and Nottinghamshire Councils, focuses on 14 Rochdale Borough Council, Mr Steven Ford QC; and 15 the experiences of children in institutions operated or 15 finally, counsel for the Secretary of State for 16 overseen by local authorities. 16 Education, Ms Catherine McGahey. Good morning to you 17 As you know, this inquiry is broad and 17 all. Please go ahead, Mr Altman. 18 unprecedented. Our task is to examine the extent to 18 Opening remarks by MR ALTMAN 19 which public and private institutions in England and 19 MR ALTMAN: Thank you, Chair. I appear, together with 20 Wales have failed to protect children from sexual abuse 20 Ms Dobbin and Mr Henderson, as counsel to the inquiry. 21 in the past and for us to make meaningful 21 Before I proceed, can I state for the record that 22 recommendations to keep children safer today and in the 22 Professor Sir Malcolm Evans has indicated both to the 23 future. 23 solicitor to the inquiry and counsel to the inquiry 24 In December 2016, the inquiry set out a work 24 overnight that he and counsel on behalf of 25 programme for 2017, which is available publicly on the 25 the complainants core participants, Ms Hoyano, were

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1 inquiry website. There is a full timeline of hearings 1 academic colleagues at Bristol for some years, and they 2 and seminars which are due to take place this year and 2 remained in friendly contact for some years after her 3 early next year. 3 move to Oxford, but apparently have not been in contact 4 The first public hearings took place from 4 directly for some five or six or more years. 5 27 February until 1 March and concerned part 1 of 5 These facts have been brought to the attention of 6 the child migration programmes case study. Further 6 all other core participants, solicitors and counsel, and 7 hearings in part 2 of that case study will take place 7 no-one raises any objection. 8 in July. 8 Chair, as the panel well knows, there have been two 9 After that, the next public hearings will be in this 9 previous preliminary hearings in this investigation: on 10 investigation, Cambridge House, Knowl View and Rochdale, 10 16 March 2016 and on 27 July 2016. This is the third 11 and will take place in October. 11 preliminary hearing in this investigation, and will be 12 The inquiry has obtained a great deal of information 12 the final substantive one for the hearings which begin 13 about allegations of sexual abuse in institutional 13 on 9 October of this year. 14 settings in Rochdale which have received significant 14 There are a number of important matters to be 15 publicity on account of the alleged involvement of 15 considered this morning about the approach which counsel 16 the late Sir Cyril Smith MP. 16 to the inquiry submits ought to be taken to the hearing 17 Much work has already been done in organising and 17 and to the evidence which the panel will, in due course, 18 analysing that material, and today's preliminary hearing 18 be invited to base its findings and, indeed, its 19 is an opportunity to make sure that we are all broadly 19 recommendations upon. 20 in agreement with regard to the conduct of the hearing 20 All of these matters were foreshadowed in 21 in October. 21 submissions by counsel to the inquiry which were 22 Before we hear from counsel, a couple of points on 22 provided to all core participants on 13 April. Counsel 23 timing. We will take a 15-minute break at around 23 also provided core participants with a witness list 24 11.45 am, and then a break for lunch, if this hearing 24 which they were asked to treat as provisional, and it 25 hasn't been included before then, at 1.00 pm. Any 25 was emphasised that, although those witnesses were

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1 regarded as being able to provide relevant evidence and 1 police investigations into Cyril Smith and why they 2 had been identified as being the best witnesses to give 2 didn't result in him being prosecuted. 3 evidence on given matters, it was unlikely that each one 3 The position regarding why children who resided at 4 could be called in the course of the hearing. 4 Knowl View were exposed to exploitation is less obvious. 5 It was also indicated in the submission the broad 5 It was, after all, a residential school specifically set 6 approach which had been taken to the selection of 6 up to educate and care for children with emotional and 7 witnesses, and I will return to the witness list later 7 behavioural needs. It might have been thought that such 8 in the course of these submissions. 8 an institution would have been vigilant about the risks 9 Core participants were invited to respond to the 9 that its young residents would have been exposed to. 10 suggested course proposed in these submissions in fact 10 The investigation will consider why some children who 11 by 4 May. They were provided on behalf of all core 11 resided there were nonetheless exploited, the extent to 12 participants, apart from the Secretary of State for 12 which this was known and why it appears it was allowed 13 Education. We are grateful to core participants for 13 to continue. 14 providing them, as this will make, and indeed does make, 14 Although I have described this case study as 15 this morning's hearing a great deal shorter than it 15 a snapshot in time, it is intended to add to the bank of 16 might otherwise have been. 16 the inquiry's knowledge about what was taking place 17 There are, however, a number of matters which need 17 within institutions at points in time in different 18 to be set out publicly in this forum in advance of 18 geographical locations across the country. This sort of 19 the hearing. 19 background will allow the inquiry to consider whether 20 There are five main issues which fall for 20 the sorts of problems in child protection that we see 21 consideration this morning and are reflected in your 21 today are part of a continuum; whether the same sorts of 22 agenda which you will find at divider 1 of your bundle. 22 problems of culture and perception endure; and whether 23 The first is scope. The second is the 23 the modern framework for child protection has rendered 24 investigation's approach to sensitive materials. The 24 of historical interest only this investigation or 25 third is the investigation's approach to findings of 25 whether there are valuable lessons still to be learned.

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1 fact in respect of allegations of sexual abuse. Fourth, 1 The approach taken by this investigation has been 2 the investigation's approach to peer-on-peer allegations 2 informed by the other investigations taking place and 3 made in the context of Operation Jaguar, and, finally, 3 which are considering many of the same matters which the 4 the investigation's approach to the hearings and to 4 panel will be invited to consider in the course of this 5 the selection of witnesses. 5 investigation. This has a direct bearing upon the 6 Chair, before I address you on each of those issues 6 conduct of the hearings in this investigation. 7 in turn, it may well assist if I provide the panel with 7 As you are all aware, Neil Garnham QC, now 8 an update as to the course the investigation has taken. 8 Mr Justice Garnham, was asked in 2014 to conduct an 9 This is, as is well known, a backward-looking 9 independent review on behalf of Rochdale Borough 10 investigation which, in essence, captures a snapshot in 10 Council. This included a review of all information 11 time. It will look at two institutions and consider why 11 available to the council which suggested that during the 12 children who resided in those institutions were 12 period 1961 to 1995 sexual or physical abuse of children 13 vulnerable to sexual abuse. Neither of those 13 took place at premises owned, managed or operated by the 14 institutions was in fact a home. Cambridge House was 14 council and/or which involved pupils or residents under 15 a hostel for working young men. That such an 15 the age of 18 attending establishments which were funded 16 environment was not suitable to house vulnerable young 16 by the council. 17 children might seem evident. What the inquiry is 17 During the Garnham Review, a considerable body of 18 interested in, in its regard, is the extent to which 18 contemporaneous materials was assembled, a number of key 19 a public figure like Cyril Smith may have been able to 19 witnesses identified and then interviewed. The 20 target young men who lived there, the reasons why he may 20 preliminary report which set out a non-contentious 21 have gone unchecked, and how he was able to remain at 21 treatment of the primary facts was also prepared, but it 22 the centre of public life in Rochdale, despite 22 stopped short of making any judgmental findings about 23 awareness, on the part of some, of the allegations 23 the matters the review was considering. 24 against him. 24 The work of that review was suspended pending the 25 The inquiry will consider, as part of that, the 25 outcome of Operation Clifton. That was an investigation

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1 carried out by the Greater Manchester Police and 1 consideration that it be conducted proportionately. For 2 included consideration of the actions of the Greater 2 that reason, the investigation has not, for the most 3 Manchester Police and Rochdale Metropolitan Borough 3 part, asked witnesses to provide statements when they 4 Council in response to information of child abuse at 4 have already done so or where they have already been 5 Knowl View School, with particular emphasis on the 5 interviewed. Instead, it will ask witnesses if they are 6 information included in reports generated from within 6 content if the investigation proceeds on the basis of 7 Rochdale Borough Council around 1991 to 1992. 7 their existing account. The investigation will seek 8 As part of its remit, Operation Clifton investigated 8 clarification or any further details it requires from 9 a number of claims or allegations which were made in the 9 key witnesses if and when they give evidence orally, 10 book "Smile for the Camera" by Simon Danczuk MP, which 10 unless it is considered necessary that they do so in 11 related to Cyril Smith MP, to Cambridge House and to 11 advance. 12 Knowl View School. The focus of this investigation is 12 There is a small number of witnesses who have not 13 not upon Mr Danczuk's book, but, rather, upon the 13 previously provided statements or whose existing 14 experiences of children who resided at Cambridge House 14 accounts lacked certain detail. Statements will be 15 and Knowl View School and an examination of 15 obtained from those individuals over the course of 16 the institutional responses to those children where it 16 the coming months. 17 was thought they may have been sexually abused or were 17 It is intended that the hearings will be opened by 18 at risk of sexual abuse. 18 counsel to the inquiry in some detail so as to set the 19 That said, evidence gathered in the course of 19 scene, to introduce the important documentary evidence 20 Operation Clifton is material to this investigation. 20 that witnesses will be asked about, and to set out the 21 Operation Jaguar was another Greater Manchester 21 main issues that witnesses will be asked to address. 22 Police inquiry, also set up in 2014, this time looking 22 The intention is that all evidence will focus upon the 23 into allegations of sexual and physical abuse linked to 23 most contentious aspects of the evidence, which is 24 Knowl View School. Whilst Operation Clifton focused 24 a necessary and proportionate approach in order to 25 upon the response of Greater Manchester Police and 25 enable the hearing to be conducted within the allocated

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1 Rochdale Metropolitan Borough Council to Knowl View 1 time. 2 School, Operation Jaguar was an investigation into the 2 Despite that, the reality is that not all of 3 actual allegations of abuse, and I will return to 3 the witness statements and documentary material relevant 4 aspects of that operation later in the course of these 4 to this investigation will be adduced in the course of 5 submissions. 5 the oral hearing. The panel will, however, be invited 6 Lancashire Police has also gathered materials which 6 to make their findings on the basis of all of 7 it had submitted to the Director of Public Prosecutions 7 the evidence which is regarded as relevant and which has 8 in 1969. The investigation intends to rely upon those 8 been disclosed to core participants. 9 materials in order to consider the 1969 investigation, 9 As for disclosure, the inquiry intends to disclose 10 the DPP's decision -- of course, these were in pre Crown 10 material to core participants on a rolling basis prior 11 Prosecution Service days -- not to prosecute Cyril Smith 11 to the hearings and core participants will know what 12 and generally the response to Cyril Smith by Rochdale 12 documentary evidence is regarded as relevant as part of 13 Borough Council, the police and, indeed, in the years 13 the overall investigation. It is anticipated that 14 after, by the CPS. 14 disclosure to core participants through the inquiry's 15 Taken together, the Garnham Review, 15 electronic document system will commence within the next 16 Operation Clifton, Operation Jaguar and the work carried 16 couple of weeks and, by note of 13 April, all 17 out by Lancashire Police resulted in a considerable body 17 participants were told that that rolling disclosure will 18 of evidence, witness statements and interviews which 18 take place up to around the end of July, by when it is 19 were gathered. The key documents have been put to 19 hoped the majority, vast majority, of the material will 20 a number of witnesses and their responses have been 20 have been disclosed, although of course some disclosure 21 recorded. 21 will naturally follow thereafter. 22 As has been explained at previous preliminary 22 All core participants and their legal 23 hearings, we consider that no purpose would be served by 23 representatives who require access to material disclosed 24 this investigation duplicating precisely the same work. 24 by the inquiry have been asked, of course, to sign 25 It would be unnecessary and contrary to the overarching 25 undertakings that ensure that material provided to them

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1 is kept securely and confidentially unless and until it 1 abuse, et cetera. 2 is called as evidence during the inquiry proceedings. 2 In other words, as currently drafted, the scope 3 Can I deal, please, with the issue of redaction? 3 envisages that findings as to failings will only be made 4 Despite the police investigations and the Garnham 4 where the inquiry finds allegations of child sexual 5 Review, there is a number of core contemporaneous 5 abuse well founded. It has become clear to counsel to 6 documents common to each investigation which are in turn 6 the inquiry that the wording is far too restrictive. It 7 relevant to this investigation. The process of 7 is clear that the panel doesn't need to find proved, as 8 disclosing that evidence is under way. It is, however, 8 it were, that children were abused in order to find that 9 much complicated by the need to redact in accordance 9 there were failings in the protection of children from 10 with the inquiry's redaction policy. 10 sexual abuse. In fact, in many ways, that would seem to 11 Consonant with the redaction policy, the 11 go against the grain of this inquiry, which is to look 12 investigation will, in general, not name individuals who 12 at failures to investigate or to protect in light of 13 have been accused of sexual or physical abuse, who are 13 information that children may have been sexually abused 14 living and who have not been convicted or against whom 14 or at risk of sexual abuse. Taking two clear examples 15 no findings have been made in respect of that conduct. 15 in this investigation, in September 1990, Rodney Hilton, 16 I now come to the issues set out in the agenda. 16 a convicted abuser of children, was able to access 17 I will deal with each in turn, and once I have done so, 17 Knowl View School at night and did so. The panel 18 including summarising any responses that we have 18 doesn't need to make prior findings as to what Hilton 19 received from core participants in writing, I shall 19 did whilst he was on the premises in order to examine 20 invite individual submissions to be made to you. 20 any failings that his ability to access the school in 21 Discussion re scope 21 the first instance involved. 22 Submissions by MR ALTMAN 22 Secondly, and similarly, the fact that it was 23 MR ALTMAN: Chair, may I start with the first substantive 23 suspected that children at Knowl View were being 24 issue which arises for consideration, the definition of 24 exploited at Smith Street toilets in Rochdale does not 25 scope of this investigation, which I will simply refer 25 require the panel to make findings about the specifics

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1 to as "scope". 1 of what was happening to those children in order to make 2 The scope, as drafted at the outset, was intended to 2 findings about any failings. 3 be a flexible guide to the matters that the 3 What is of the essence is the response to that 4 investigation would look into and was based upon 4 information. Was it, for example, adequately 5 information available at the time. It was not intended 5 investigated? Were children spoken to about it? What 6 to be a fixed blueprint that would dictate the terms of 6 steps were taken to ensure that it didn't happen or 7 this investigation. I am not going to recite all of 7 wasn't happening? 8 the matters within scope of this investigation. One of 8 The definition of "scope" is therefore intended to 9 the terms, and I globalise them, sets out that the 9 be a flexible tool for the inquiry insofar as it 10 investigation would consider whether boys who attended 10 provides guidance as to the areas to be investigated. 11 Knowl View School or Cambridge House had been subject to 11 It shouldn't constrain the panel from making findings 12 sexual abuse, including sexual exploitation, and the 12 that are available on the evidence that it hears or 13 question whether this extended to other institutions. 13 receives. It can be adapted as the evidence in the 14 Paragraph 2 of scope, which I indicated earlier you 14 individual investigations develop, and in the Rochdale 15 will find in the fourth divider of your bundle, as 15 investigation I respectfully suggest that the panel 16 currently drafted, states at paragraph 2: 16 ought to adopt a more flexible approach by amending 17 "To the extent that the inquiry finds some or all of 17 paragraph 2 so as to provide -- and this document you 18 the allegations to be well founded, it will make 18 will find behind your divider 5, but on the second 19 findings on ..." 19 page -- so it should provide instead "where a sufficient 20 It then proceeds to state what that might cover, 20 evidential basis exists, the inquiry will make findings 21 including, at paragraph 2.2, the nature and extent of 21 on", and thereafter a number of paragraphs are set out. 22 the failings of Rochdale Council, law enforcement 22 In response to this issue, no core participant has 23 agencies, prosecuting authorities, the security and/or 23 indicated any disagreement with the proposed amendment. 24 intelligence agencies and/or other public authorities or 24 Mr Ford, however, on behalf of the Rochdale Borough 25 statutory agencies to protect children from sexual 25 Council, has submitted that, as interpreted, this is

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1 a change in the standard of proof. 1 we are strongly in support of the rewording of the scope 2 To be clear, that's not what is, or was, intended by 2 as proposed in paragraph 14. Thank you. 3 the proposed amendment, but the position is that it 3 THE CHAIR: Thank you, Ms Hoyano. Mr Payne? 4 became apparent to counsel to the inquiry that there was 4 MR PAYNE: Madam, Lancashire Police have no submissions to 5 no necessary relationship between findings that abuse 5 make on this issue. 6 occurred and findings that there were failings, and 6 THE CHAIR: Thank you. Ms Studd? 7 counsel regards it as clear that a failing in child 7 MS STUDD: Greater Manchester Police have no submissions. 8 protection is a failure to protect from the risk of 8 THE CHAIR: Mr Brown? 9 child abuse which does not require proof of the abuse 9 MR BROWN: Nothing to add, thank you, ma'am. 10 having actually occurred. 10 THE CHAIR: Mr Ford? 11 Also, we take the point which Mr Ford also makes 11 Submissions by MR FORD 12 that it may be logically unnecessary for paragraph 2.1 12 MR FORD: Our observations about scope were principally 13 to remain in the revised definition of "scope" if 13 directed at the logic of what is 2.1 in the first 14 findings made within paragraphs 1.1 to 1.3 provide 14 version and 2.5 in the second version remaining there. 15 a sufficient evidential basis to make findings about 15 We say that not in the abstract. We say it because, as 16 institutional failures. 16 we have said in our short note for today, this is one of 17 We are in the process of considering whether the 17 those cases in which there are civil claims in the 18 scope needs to be further refined. 18 background. I know the inquiry is facing that in 19 Chair, before leaving scope, I should mention that 19 a number of its investigations and it can cause 20 counsel to the inquiry considered the extent to which 20 problems. We don't think it is going to cause enormous 21 the hearings in this investigation could provide for an 21 problems in this case, because there aren't very many of 22 examination of the contemporary state of child 22 them, and my learned friend, I am pleased to say, is 23 protection in Rochdale as regards children within the 23 alive, as a result of our discussions this morning, to 24 care of Rochdale Borough Council. It was considered 24 the problems that can cause. So we raised it for that 25 that this would likely give rise to complex issues 25 reason.

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1 common to many local authorities which would not be 1 He has said to me that he is aware of 2 suited to treatment in public hearings intended to 2 the difficulties that can be caused and that we will 3 resolve factual issues about historical matters; all the 3 liaise about how to avoid them on the fact-finding 4 more so in a very targeted, relatively short series of 4 issue. 5 public hearings. 5 THE CHAIR: Thank you, Mr Ford. Ms McGahey? 6 That doesn't mean that Rochdale Borough Council is 6 MS McGAHEY: The Secretary of State has no submissions. 7 precluding from setting out in its corporate statement 7 Thank you, ma'am. 8 current policies or practices which it considers address 8 THE CHAIR: Mr Altman? 9 the issues which the investigation will consider. 9 MR ALTMAN: Thank you very much. Let me then move on. 10 However, enquiring into these will not form part of 10 Issue number 2, sensitive materials. 11 the fact-finding work that is carried out as part of 11 Discussion re sensitive materials 12 the hearings. Again, core participants were given 12 Submissions by MR ALTMAN 13 notice of this point and no-one has disagreed with that 13 MR ALTMAN: Chair, this second issue that arises for 14 proposed course. That is all I have to say on the first 14 consideration this morning is that of 15 issue, scope, and I invite any submissions from any of 15 the investigation's approach to sensitive materials. By 16 the core participants. 16 "sensitive", I mean those contemporaneous records which 17 Submissions by MS HOYANO 17 relate to individual children who are not core 18 MS HOYANO: Madam Chair, I would just say that we are 18 participants in this investigation and which records 19 content with counsel to the inquiry's submissions, which 19 contain very private information about them. The most 20 we believe set out a very careful balancing of 20 obvious example of this are Social Service records. 21 the issues to be explored in the inquiry and will 21 The investigation doesn't have many of these 22 certainly reach -- enable the inquiry, we hope, to reach 22 records, but there is some information within some 23 some positive conclusions. 23 records which the panel may nonetheless consider to be 24 We would, in particular, like to see the 24 relevant. It may, for example, provide some background 25 paragraph 2.5 remain in the scope description and also 25 as to the vulnerabilities of certain children or

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1 demonstrate the role that the Rochdale Social Services 1 participants hold that is relevant to this inquiry and 2 Department played in their lives. The identity of 2 relevant to the complainants, as is the case with public 3 the individuals to whom these records relate is not, of 3 interest immunity applications, for example. We have 4 itself, relevant to the investigation. What matters is 4 had a very conditional response from the MGP. I have 5 the information about them available at the material 5 spoken with counsel from the MGP this morning and have 6 time or what it tells the investigation about children 6 been assured that an open approach will be taken and 7 who resided at either Cambridge House or Knowl View 7 a flexible approach to ensure that the objectives of 8 School. 8 the inquiry are met. 9 We are conscious that just redacting files in 9 But I just want to say at this stage that, in 10 accordance with the inquiry's policy may be 10 response to what is stated in paragraph 5, that under 11 insufficient, especially given that these individuals 11 potentially restricted evidence this would be 12 belong to a small group of individuals who attended 12 restricted, for example, to documents which were created 13 Knowl View School at certain points in time or who lived 13 by -- that unredacted documents would be restricted to 14 in Cambridge House during its short lifetime. 14 documents that were created by or received by a witness, 15 These individuals may well still live in the 15 well, by definition, our clients did not create any 16 Rochdale area or have family there. Given the 16 documents. They are the victims in this. They did not 17 particular sensitivity of this category of material, the 17 receive any documents. There are significant gaps in 18 investigation is reviewing the material in order to 18 their history. Many of them have no idea why they were 19 separate out the information in these files. A decision 19 sent to Knowl View. It is vitally important that they 20 will then be made as to whether core participants can be 20 understand what decisions were made about their welfare 21 provided with a gist of these files or provided with 21 and about the complaints they made about being sexually 22 files redacted in their entirety, save for the limited 22 abused, both contemporaneous and later. 23 amounts of information that are relevant to the matters 23 It is vitally important that they understand why 24 under investigation here. 24 those responsible for their plight and leaving them 25 The investigation needs to find the best way of 25 vulnerable to sexual abuse, that they be made

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1 balancing the ability of the inquiry to carry out its 1 accountable to this inquiry. 2 work with a need to protect the privacy of those 2 So we are not content to have only disclosure of 3 individuals whose records the inquiry holds. The 3 documents where our clients are the author or the 4 approach will be that the panel will make findings on 4 recipients of the documents. We would like unredacted 5 the basis of the material as it is disclosed to the core 5 copies of any document that refers to any of our core 6 participants. A closed process is not envisaged, as 6 participants. 7 matters stand. 7 Also, we would ask that a schedule be prepared of 8 In terms of their responses, we welcome the core 8 documents that are not being disclosed or which are 9 participants' agreement on this approach to sensitive 9 being heavily redacted with the reasons that are being 10 materials. I should point out for the record that 10 advanced for the non-disclosure. Much has happened in 11 counsel for both the Greater Manchester Police and 11 public interest immunity applications so that we have 12 Lancashire Police have made certain observations about 12 some idea of the nature of what is being withheld from 13 the redaction of material owned by them. The inquiry's 13 us and can, if necessary, make further applications to 14 policy has been explained by telephone to solicitors to 14 the panel. 15 both forces to their satisfaction, and there is, 15 I would say also that we are not aware of any 16 therefore, no need for any debate about it today. 16 criminal investigations ongoing in relation to the core 17 I think everybody understands the position about the 17 participants and, consequently, we don't have that issue 18 issue of redaction, so I don't need to go into that any 18 which we do acknowledge could be a serious issue in 19 further. But I will, nonetheless, invite any 19 other modules. 20 submissions if anybody has any on those issues. 20 I would also just indicate that, in relation to the 21 THE CHAIR: Ms Hoyano? 21 Crown Prosecution Service, they are maintaining legal 22 Submissions by MS HOYANO 22 professional privilege. Of course, in many senses, 23 MS HOYANO: Yes, Madam Chair, as always, we are at 23 legal professional privilege applies to everything which 24 a disadvantage in this kind of proceeding because we do 24 the Crown Prosecution Service does. They have also 25 not know what the material is that the other core 25 given a welcome undertaking to be as generous as they

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1 can in relation to the inquiry, but I would suggest that 1 you will be well aware of the sorts of issues and will 2 their disclosure be treated much like judicial review in 2 be able to make that balance between the scope of your 3 the Administrative Division of decisions to prosecute or 3 inquiry and the work you do, together with the balance 4 not to prosecute where the internal documentation and 4 to the individuals themselves. Of course you do. But 5 reviews of those decisions internally to the CPS are 5 we will seek to make those representations, but 6 actually produced to the court. Thank you. 6 consistent with our duty to the inquiry as well, we 7 THE CHAIR: Thank you, Ms Hoyano. 7 hope. 8 MR PAYNE: No submissions. 8 So far as legal professional privilege and 9 THE CHAIR: Any others? 9 consistent with the Administrative Court judgments of 10 Submissions by MS STUDD 10 the recent past, we will seek to provide all the 11 MS STUDD: Chair, I think I made the position quite clear in 11 information that is necessary for you to make your 12 my submission. Obviously there has been -- Greater 12 judgment on some of the issues that will go back in time 13 Manchester Police have been working under an arrangement 13 and the like. Whether the actual document will be 14 with Operation Hydrant in relation to disclosure of 14 provided to you, madam, we hope to provide at least the 15 material. So we would just want an opportunity to 15 information necessary that's contained in the document, 16 consider whether any redaction should be made to the 16 and that is consistent with the Administrative Court 17 relevant material which is going to be provided to the 17 rulings, as I understand it. 18 core participants. 18 So we will not stand in the way of the inquiry in 19 I made it clear, and I have made it clear to counsel 19 any way standing on the principle of LPP. We will seek 20 for the victims and survivors, that no decision has been 20 to provide everything that you need and everybody can be 21 made yet in relation to any redaction, and we are just 21 assured that that will take place. 22 unable to say whether there will be any, a little or 22 THE CHAIR: Thank you, Mr Brown. Mr Ford? Ms McGahey? 23 more. But each redaction will be considered on its own 23 MS McGAHEY: No, thank you, ma'am. 24 merits and an explanation will be provided to your team 24 THE CHAIR: Mr Altman? 25 and, if appropriate, to the victims and survivors' team 25 MR ALTMAN: Two points. In relation to Ms Hoyano, the point

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1 and other core participants as to why that redaction has 1 that I raised, at least the first point, specifically 2 been made. 2 relates to individuals who are not core participants, as 3 We are very aware of the need for openness and 3 to how we deal with sensitivity as far as they are 4 transparency in relation to disclosure and we will 4 concerned. 5 endeavour to ensure that as much openness and 5 Secondly, as regards her request that core 6 transparency is given in relation to the documents as we 6 participant, complainant core participant, records be 7 can. 7 unredacted, of course we will consider that. But we 8 THE CHAIR: Thank you, Ms Studd. Mr Brown? 8 recognise -- and it will have to be recognised -- that 9 Submissions by MR BROWN 9 they may refer to, for example, other children or 10 MR BROWN: Thank you, madam. Plainly, we will make 10 families of other children, and we are going to have to 11 submissions in respect of redactions. The Crown 11 be very sensitive to that. But we have in mind her 12 Prosecution Service, in a sense, holds some material, of 12 point. 13 course, that comes from the investigative police 13 MS HOYANO: Madam Chair, what Mr Altman proposes in terms of 14 material. But the CPS, of course, still has 14 redacting the names of other children and families who 15 a responsibility to protect those individuals, for 15 might be referred to in those documents is entirely 16 example, and we will seek to continue to do so, but, in 16 acceptable to us. 17 the end, madam, it will be a matter for you, having 17 THE CHAIR: Thank you. 18 heard our representations. 18 Discussion re treatment of allegations of abuse 19 I know all parties will be sensitive to this, that 19 Submissions by MR ALTMAN 20 sometimes just the names being redacted doesn't ensure 20 MR ALTMAN: Thank you. The third issue, Chair, is the 21 the privacy of some of those participants because of 21 treatment of allegations of abuse. We have set out in 22 the nature of triangular identification and the like, 22 writing to the core participants the approach it is 23 often called jigsaw identification. But we will make 23 suggested should be taken to allegations of sexual 24 those representations. 24 abuse; for example, those allegations which were made 25 We know perfectly well that your counsel, madam, and 25 over the course of a number of years in respect of

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1 Cyril Smith. 1 Rochdale and outside Rochdale. Again, applying the 2 I am not going to repeat the content of those 2 redaction protocol, adults implicated in this 3 allegations or the decisions which were made by the 3 exploitation may be referred to by name where they have 4 Crown Prosecution Service or the DPP in respect of them, 4 been convicted in respect of the sexual abuse of 5 suffice it to say that, in order to consider the 5 children. 6 institutional response, the allegations against 6 I should mention, before leaving this topic, that 7 Cyril Smith will necessarily form part of the oral 7 the geographical remit of this investigation is clearly 8 hearing, but we repeat what will be of the essence is 8 Rochdale. Its focus is on children who resided in 9 how the institutions concerned responded to those 9 Rochdale. The investigation will not examine 10 allegations. 10 allegations made against Cyril Smith regarding events 11 What that does not require is that the panel makes 11 alleged to have taken place in London or elsewhere 12 specific findings against Cyril Smith. Counsel for the 12 related to his having been a member of parliament. Such 13 inquiry submits that the same approach which has been 13 matters are within the scope of the Westminster 14 taken in the investigation into the late Lord Janner is 14 investigation and may or may not be the subject of 15 apt to the instant investigation and that findings of 15 detailed examination by that investigation. 16 fact as to whether an individual may have sexually 16 This investigation will consider how the local 17 abused children may be appropriate, but only where such 17 political parties responded to Cyril Smith and why he 18 findings first are relevant to the discharge of 18 was able to remain so prominent in public life in 19 the inquiry's overall terms of reference; second, are 19 Rochdale and involved in Rochdale Borough Council 20 open and available on the evidence; and, third, can 20 matters related to children, despite knowledge of 21 fairly be made in all the circumstances, such 21 the investigation into his conduct in the period 1969 to 22 circumstances including, of course, the inability of 22 1970; the publication of the Rochdale alternative press 23 Cyril Smith to respond to those allegations. 23 articles in 1979; and general suspicions about his 24 It is respectfully submitted that this does not 24 having a sexual interest in young boys. 25 require a determination now as to whether such findings 25 By contrast, questions as to how the national

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1 can be arrived at. Not least, this would be to pre-empt 1 political parties responded to him are within the scope 2 matters which will be adduced in evidence and which 2 of the Westminster investigation. 3 might well bear upon the appropriateness of making such 3 Similarly, the Rochdale investigation will adduce 4 findings, including, for example, evidence as to why an 4 evidence as to how Lancashire Constabulary and the 5 allegation wasn't made at an earlier point in time. 5 Greater Manchester Police responded to Cyril Smith, but 6 The investigation will also consider investigations 6 issues as to whether Cyril Smith was investigated by 7 into some men associated with Cyril Smith, including 7 other forces or organisations in his capacity as an MP 8 Councillor Harry Wild. He died in 2001. No core 8 fall within the scope of the Westminster investigation. 9 participant in this investigation has made any direct 9 In terms of core participant responses, again, 10 allegations against him, but the investigation is 10 Chair, no core participant has taken issue with the 11 nonetheless considering what was known about him by the 11 suggested approach to allegations of sexual abuse as 12 authorities at the time of his involvement in education 12 made against known individuals. 13 in Rochdale. 13 As you have already heard from Mr Ford, he has 14 The investigation will also consider how a local 14 indicated now in writing and orally that the council is 15 man, somebody to whom I have already referred, 15 facing a number of claims in the civil jurisdiction. It 16 Rodney Hilton, with convictions related to the sexual 16 may be, in that regard, that submissions will have to be 17 abuse of children and seemingly well known to have 17 made about whether the inquiry should make findings 18 a sexual interest in children, targeted the school over 18 about any claimants in any outstanding claims in this 19 a prolonged period of time, notoriously staying there 19 investigation. 20 through the night. In accordance with the inquiry's 20 We consider that this is a matter which should be 21 redaction protocol, it is considered appropriate to 21 raised closer in time to the hearings, when the position 22 publicly name this individual, given that he has been 22 becomes clearer, although, of course, the inquiry has to 23 convicted of the sexual abuse of children. An important 23 have in mind section 2 of the 2005 Act which provides 24 aspect of the investigation will be the exploitation of 24 that an inquiry panel is not permitted to rule on and 25 pupils from Knowl View School in public toilets in 25 has no power to determine any person's civil or criminal

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1 liability, but that section 2(2) provides that an 1 Discussion re statements gathered during Operation Jaguar 2 inquiry panel is not to be inhibited in the discharge of 2 Submissions by MR ALTMAN 3 its function by any likelihood of liability being 3 MR ALTMAN: Thank you very much. We now move to the fourth 4 inferred from facts that it determines or 4 issue, the statements gathered during Operation Jaguar. 5 recommendations that it makes. But I repeat and 5 The operation codename Jaguar also included an 6 emphasise, we have in mind what Mr Ford has said, and 6 investigation into allegations by former residents of 7 I am sure we can work through the issues much closer to 7 Knowl View School that they had been sexually assaulted 8 the time. 8 by other residents at the school, sometimes referred to 9 Submissions? 9 as "peer-on-peer abuse". 10 Submissions by MS HOYANO 10 No former pupils were charged in respect of those 11 MS HOYANO: Madam Chair, appreciating that this issue has 11 allegations. The investigation is, therefore, in 12 been postponed for a final determination and ruling by 12 possession of evidence that relates to unproven and 13 the panel, we would just like to lay down a marker now 13 unsubstantiated conduct, which did not clearly pass the 14 that we will be submitting that the panel will be 14 test provided for in the code for Crown prosecutors. 15 inhibited in making its report and fulfilling its terms 15 Counsel to the inquiry considers that these 16 of reference should it consider itself prevented from 16 allegations are complex and ill-suited to adjudication 17 making findings that the core participants were sexually 17 in the context of this investigation. They raise issues 18 abused by Cyril Smith or by other individuals whose 18 of considerable sensitivity related to adults who are 19 activities were connected with Cambridge House or 19 not core participants in the investigation. Given the 20 Knowl View. 20 focus of this investigation is upon the failures to 21 My instructing solicitor acts for the core 21 respond to the possible sexual abuse of children at the 22 participants who currently have civil proceedings on 22 time, it is submitted that, in keeping with that 23 foot. None of those will conclude before the hearing. 23 purpose, its focus should be on the information that was 24 We submit that it is really irrelevant, and indeed 24 available to the authorities at the time and the efforts 25 utterly inappropriate, that the core participants who 25 made then to distinguish between sexual conduct that was

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1 have had the temerity to sue the borough council should 1 abusive and conduct which, although potentially harmful 2 be singled out as being survivors respecting whom no 2 or inappropriate, given the ages of the children 3 findings can be made as to whether they were sexually 3 involved, might be categorised as experimentation, or 4 abused in these institutions or persons associated with 4 what steps were taken to protect children as regards 5 them, whereas other core participants who have not sued 5 this sort of activity, regardless of whether it was 6 or whose civil proceedings have been concluded, those 6 considered abusive or not. 7 findings can be made. I submit that a consistent 7 Irrespective, in any event, of those 8 approach should be taken and that the fact that civil 8 categorisations, the investigation will consider the 9 proceedings have been brought is made irrelevant by 9 steps taken to address the issues raised by sexual 10 section 2(2) of the Inquiries Act 2005. 10 activity between children at Knowl View School. This 11 MR PAYNE: No submissions. 11 will include consideration of what was known about the 12 THE CHAIR: Ms Studd? 12 background of some children by staff who dealt with them 13 MS STUDD: No, thank you. 13 on a day-to-day basis; the physical and mental health 14 THE CHAIR: Mr Brown? 14 implications of what was taking place between children; 15 MR BROWN: Nothing to add. 15 and the steps taken to address it. 16 THE CHAIR: Mr Ford? 16 Having regard to the existence of 17 MR FORD: We will have something to say about what was just 17 the contemporaneous evidence, and given that the focus 18 said by counsel for the victims and survivors, but 18 of the investigation is upon institutional failings, 19 I think this probably isn't the time. We are content 19 based upon what was known at the time, the investigation 20 with the way the matter has been left by Mr Altman and 20 doesn't consider that the disclosure to core 21 we will respond as and when the decision needs to be 21 participants of the Operation Jaguar statements 22 made. 22 concerning peer-on-peer abuse would be either 23 THE CHAIR: Thank you, Mr Ford. Ms McGahey? 23 proportionate or necessary in order to resolve the 24 MS McGAHEY: No, thank you, madam. 24 issues I have just identified. 25 25 Critically, these statements necessarily identify

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1 children said to have been abused, and those children 1 Plainly, they can't all be called to give oral evidence 2 said to have been abusers and who are not core 2 in the course of a three-week public hearing in October. 3 participants in this investigation. Disclosure of those 3 It is anticipated that the evidence of a number of 4 statements would, therefore, give rise to very complex 4 witnesses will be capable of being read, and we will 5 issues going to the privacy of those individuals. 5 inform core participants of the views about this and 6 The investigation intends to ask the Greater 6 invite submissions once the disclosure process is in 7 Manchester Police to provide a statement on 7 a more advanced state. 8 Operation Jaguar which explains what was investigated in 8 Because choices as to the best witnesses have to be 9 that operation, the number of individuals involved and 9 made, counsel have drawn up the provisional witness 10 the obstacles to mounting a prosecution as regards those 10 list, having regard to the following broad 11 allegations made. 11 considerations, which have not been treated as 12 The police will also be asked to address in that 12 prescriptive, but, rather, as a guide to the selection 13 statement some discrete issues which are relevant to 13 of witnesses. First, the centrality of the individuals' 14 some of the other issues which fall within the terms of 14 evidence, either as a victim of abuse or as an 15 reference regarding this investigation. The 15 individual involved in responding to it; second, whether 16 Operation Jaguar materials also encompass allegations 16 fairness requires that the individual is afforded the 17 made against some members of staff. The investigation 17 opportunity to give evidence, having regard to the type 18 intends to review those further to determine whether 18 of findings that the panel might consider making in due 19 they are disclosable, again, subject to the inquiry's 19 course; third, whether an important part of their 20 redaction protocol. 20 evidence is the subject of dispute; and, fourth, the 21 Insofar as core participant responses go, all were 21 witnesses' ability to provide conclusive evidence as 22 given notice that we intended to ask the inquiry to take 22 regards an issue. 23 this approach to the statements gathered within 23 There is likely to be evidence from other witnesses 24 Operation Jaguar, and no core participant has indicated 24 which will be considered by the investigation as it 25 any disagreement with that course. But I, again, invite 25 develops over the next few months. This should not add,

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1 any submissions. 1 we feel, significantly to the number of witnesses who it 2 MS HOYANO: We are content with the submissions of counsel 2 is presently intended will be called to give live 3 for the inquiry. 3 evidence. It is intended that the hearings will 4 THE CHAIR: Thank you, Mr Payne? 4 consider the following issues. As regards 5 MR PAYNE: No, thank you. 5 Cambridge House, first, the establishment of 6 THE CHAIR: Ms Studd? 6 Cambridge House and Cyril Smith's role in managing it; 7 MS STUDD: No thank you. 7 second, Rochdale Borough Council's relationship with it; 8 THE CHAIR: Mr Brown? 8 third, the investigation into Cyril Smith in the period 9 MR BROWN: Nothing to add, thank you. 9 1969 to 1970; fourth, the then DPP's decision not to 10 THE CHAIR: Mr Ford? 10 prosecute; fifth, the publication of the articles in the 11 MR FORD: No, thank you. 11 Rochdale alternative press. 12 THE CHAIR: Ms McGahey? 12 Insofar as Knowl View School goes, the issues are, 13 MS McGAHEY: No, thank you. 13 first, the establishment of the school; the nature of 14 THE CHAIR: Mr Altman? 14 the care and education it was intended to provide; an 15 Discussion re approach to hearings and witnesses 15 overview as to the needs of the pupils who attended it; 16 Submissions by MR ALTMAN 16 the distinction between the school and the residential 17 MR ALTMAN: Thank you. The fifth and final agenda item, the 17 home for children; the care of children who attended it 18 approach to the hearings and to witnesses. The list of 18 who were in the care of the local authority. 19 witnesses with which everyone has been supplied is 19 Second, Cyril Smith's involvement in Knowl View 20 necessarily provisional and it is necessarily contingent 20 School, including consideration of his governorship of 21 upon the panel determining the scope and approving the 21 the school and whether he had access to it. 22 approach to be taken to the hearings. 22 Third, the early years of Knowl View School and the 23 In this particular investigation, there are multiple 23 sexual abuse of children by another perpetrator by the 24 witnesses who provide evidence on the same issue, in 24 name of David Higgins. 25 part because of the scale of Operation Clifton. 25 Fourth, the exploitation of children from Knowl View

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1 School in the 1970s and the 1980s. 1 to which witnesses will be called to give oral evidence 2 Fifth, Rodney Hilton's contact with the school in 2 will be provided as soon as ongoing reviews of evidence 3 the period. 3 are concluded. I can say that the investigation is 4 Sixth, events in 1989 and 1990. 4 conscious that there is a relatively small number of 5 Seventh, the response to those events by the 5 core participants in this investigation and that the 6 council, including in particular the role that the 6 panel would likely wish to hear a balanced and 7 Social Services Department played in it. 7 representative selection of witnesses. 8 Eighth, the response to those events by Greater 8 The second point is this: Mr Scorer and Ms Hoyano 9 Manchester Police. 9 have asked the investigation to consider pre-recording 10 And, ninth, the closure of Knowl View School. 10 the evidence of two core participants in particular, who 11 Under the heading "Police and political awareness", 11 are very unwell. One of those witnesses lives outside 12 the issues are, first, political awareness that 12 the United Kingdom. It is envisaged that they would be 13 Cyril Smith had been implicated in the sexual abuse of 13 questioned by live videolink by counsel to the inquiry, 14 children; second, the political awareness of events at 14 with all other core participants, and indeed the panel, 15 Knowl View School; and, third, police investigations 15 present, albeit via remote link. 16 into Harry Wild and Cyril Smith after 1970. 16 It appears to counsel to the inquiry that what, in 17 Finally, insofar as the wider picture and the 17 effect, is being suggested inevitably is that a hearing 18 corporate response from the council is concerned, the 18 is convened before the main hearing in October, with 19 overarching issue will be an overview of the allegations 19 evidence provided via videolink by those two witnesses, 20 of other residential provision for children in Rochdale 20 and indeed recorded. 21 during the same timeframe. 21 We have to consider this further. First of all, 22 Finally in this regard, the list of issues, together 22 there are inquiry-wide issues to be considered about the 23 with the provisional list of witnesses, was circulated 23 provision of pre-recorded evidence in general, and, 24 to the core participants within the submissions, and 24 secondly, the panel has, of course, a very full 25 submissions were invited to it. No core participant has 25 timetable, and there are likely to be very real

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1 taken issue with any of the topics or taken issue with 1 logistical difficulties in assembling the panel and 2 the proposed witness list, as such. We will provide, in 2 everyone else for a hearing prior to October 9. Third, 3 due course, the investigation's view as to which 3 it would require a different timetable for disclosure. 4 witnesses ought to be called to give oral evidence as 4 In fact, it would put a pressure on the investigation to 5 soon as the last batches of documents have been subject 5 expedite disclosure to all core participants in respect 6 to review and we are able to come to a final and, 6 of those witnesses. So this is an issue, for all of 7 indeed, informed view as to which witnesses do not need 7 the reasons which I have just raised, which needs to be 8 to be called to give oral evidence. 8 given very careful thought and fuller consideration. 9 On behalf of the complainant core participants, 9 But I invite submissions about it now. 10 Mr Scorer and Ms Hoyano have asked what arrangements 10 THE CHAIR: Ms Hoyano? 11 have been made to ensure that witnesses are actually 11 Submissions by MS HOYANO 12 available. 12 MS HOYANO: Madam Chair, thank you. I am, at the moment, 13 The investigation is in the process of writing to 13 content to park the issue as to whether all nine 14 witnesses at the present time to inform them that they 14 complainants should be afforded the opportunity of 15 have been identified as a witness in the investigation 15 providing oral evidence. I would just simply note that 16 and informing them of the dates of the hearings. We 16 they have waited almost 50 years to tell their stories. 17 hope that, with a three-week window, we will be able to 17 They have made multiple complaints, sworn multiple 18 accommodate any witness difficulty. 18 affidavits in some cases, and have made statements to 19 As regards the core participants which they 19 the police and so forth, always never to have any 20 represent, Mr Scorer and Ms Hoyano have made two main 20 further action taken. They are very keen to be allowed 21 points which are specific to those core participants. 21 to tell their story. 22 First, that all core participant witnesses represented 22 On the issue of pre-recorded evidence, we are 23 by them should be afforded the opportunity to give 23 talking about core participants A4 and A7. If I might 24 evidence at the hearing. 24 provide some medical evidence, just to explain why we 25 Chair, as has already been mentioned, indications as 25 are making what is an unusual application for this

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1 inquiry to adopt basically procedures which are very 1 particular -- all of our clients are keen to give oral 2 common in the criminal courts. 2 evidence, as I have stated, but for these two witnesses 3 If I can go first to A7, he lives in Wigan. He was 3 in particular, if this inquiry were to hold that because 4 at Knowl View from February 1969 until 1974. That was 4 of the length of time that has elapsed since their first 5 during the period when the Crown Prosecution Service 5 complaints were ignored and the consequent illnesses in 6 decided to take no further action against Cyril Smith. 6 the decades in the ensuing intervals that they were too 7 He states that he was abused by Smith and by staff 7 unwell, although they say they are well enough to 8 members and by peers. 8 testify, and both of them are entirely mentally 9 Mr A7 suffers from a chronic obstructive pulmonary 9 competent, I assure you, that this inquiry would not 10 disease which causes severe breathlessness. He is 10 make the effort to receive their evidence, their oral 11 completely housebound. He uses a multitude of inhalers, 11 evidence, when, in the modern era of technology, we do 12 breathing equipment, oxygen tanks, and so forth. He 12 this, as I say, all the time in the criminal courts, 13 can't walk even with a Zimmer frame and he receives 13 including through having witnesses from remote 14 24-hour care from his wife. 14 locations, surely something can be done. 15 He also suffers from severe back pain and also other 15 Now, I understand from Mr Altman that the 16 conditions which are associated probably with his 16 submissions we have made are under active consideration. 17 immobility. 17 I would urge the inquiry to make a swift and reasoned 18 What we would propose is that he be taken by 18 conclusion based upon these two survivors because their 19 ambulance to a Crown Court in Manchester to use their 19 plight is such that I am very concerned we may not have 20 videolink facilities which are standardly used for child 20 them by October. Concerns have been expressed about, 21 witnesses and vulnerable adult witnesses who have 21 you know, perhaps requiring expedited disclosure for 22 physical impairments, and so forth, in order to allow 22 these two witnesses, but surely that is possible, to 23 him to give evidence. That would be set up with the 23 meet their needs. 24 remote link here for all other counsel except myself and 24 As the terms of reference state for the inquiry, all 25 my instructing solicitors. We would like to be present 25 appropriate support will be provided to survivors to

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1 with him to provide him with support. 1 enable them to give their evidence, and as the inquiry 2 The other witness, A4, is rather more complicated 2 has assured core participants, we cannot begin to 3 because he lives in Amsterdam. He is aged 71. He has 3 understand the patterns of institutional failures 4 had a long history of osteoarthritis and narcolepsy. 4 without hearing from those who suffered as a consequence 5 Unfortunately, in March 2009, he was diagnosed with 5 of those failures. 6 cancer of the oesophagus. In 2009, he underwent four 6 If you don't hear from the small number of 7 operations to remove the cancer, and the operations 7 complainants who have come forward from these two 8 didn't go smoothly, so his heart actually stopped three 8 institutions, I would suggest those patterns, as 9 times. When he emerged from the coma, he found himself 9 perceived by the children who were put into them, and 10 to be totally paralysed and partially blind, and after 10 particularly at Knowl View, where they often had no idea 11 ten months he was finally released to go home. 11 why they were put there, you will not find out the 12 He is in severe pain 24 hours a day. He is doubly 12 extent of the vulnerability and you will not understand, 13 incontinent and he uses an electric wheelchair. He is 13 I would suggest, how the responses of the staff members, 14 only able to walk 25 metres using a walking aid. 14 the governors, the local authority, were so inadequate 15 Mr A4 was at Cambridge House, whereas A7 was at 15 that actually they ended up being exposed to abuse and 16 Knowl View, and he went there in 1962, when he was aged 16 their complaints being ignored. 17 15. It is not clear when he left, at this point. 17 So we are talking about two of nine, and if you take 18 He is very keen to actually come to London to give 18 those two away just because of their physical incapacity 19 evidence to the inquiry. We have investigated this, and 19 and disability, I would suggest that that necessarily 20 believe it is not in his best interests to do that. It 20 will inhibit the inquiry in being able to actually make 21 would be a great strain. But what I would emphasise 21 the sound findings that we are all in this room 22 about these two witnesses is not only how precarious 22 dedicated to achieving at the end of this module. Thank 23 their health is, but also how desperate they are to give 23 you. 24 their evidence in person and not just with a flat 24 THE CHAIR: Thank you, Ms Hoyano. Mr Payne? 25 witness statement. For these two witnesses in 25 MR PAYNE: No, thank you.

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1 THE CHAIR: Ms Studd? 1 Submissions by MS HOYANO ...... 22 2 MS STUDD: No, thank you. 2 3 THE CHAIR: Mr Brown? 3 Submissions by MS STUDD ...... 25 4 MR BROWN: No, thank you. 4 5 THE CHAIR: Mr Ford? 5 Submissions by MR BROWN ...... 26 6 MR FORD: No, thank you. 6 7 THE CHAIR: Finally, Ms McGahey? 7 Discussion re treatment of ...... 28 8 MS McGAHEY: No, thank you, madam. 8 allegations of abuse 9 THE CHAIR: Mr Altman? 9 10 MR ALTMAN: We have heard what's been said, and it is under 10 Submissions by MR ALTMAN ...... 28 11 consideration. 11 12 Chair, those are all the matters now dealt with 12 Submissions by MS HOYANO ...... 33 13 within the agenda. There are no more submissions I wish 13 14 to make, and I suspect no more submissions any of 14 Discussion re statements gathered during .....35 15 the core participants wish to make. Therefore, as far 15 Operation Jaguar 16 as we are concerned, that brings to an end this 16 17 preliminary hearing. 17 Submissions by MR ALTMAN ...... 35 18 THE CHAIR: Thank you. Thank you, Mr Altman. Are there any 18 19 other submissions by anyone here? No. Thank you. 19 Discussion re approach to hearings ...... 38 20 Thank you, again, to everyone here for attending 20 and witnesses 21 today, and for your very constructive and impassioned 21 22 submissions. I am especially grateful to those of you 22 Submissions by MR ALTMAN ...... 38 23 who have had to travel. 23 24 We have covered a lot of ground this morning. We 24 Submissions by MS HOYANO ...... 44 25 look forward to continuing our investigations into these 25

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1 very serious matters at the hearing in October. 2 That concludes the preliminary hearing. Thank you 3 very much. 4 (11.51 am) 5 (The hearing concluded) 6 7 8 I N D E X 9 10 Opening remarks by THE CHAIR ...... 1 11 12 Opening remarks by MR ALTMAN ...... 3 13 14 Discussion re scope ...... 13 15 16 Submissions by MR ALTMAN ...... 13 17 18 Submissions by MS HOYANO ...... 18 19 20 Submissions by MR FORD ...... 19 21 22 Discussion re sensitive materials ...... 20 23 24 Submissions by MR ALTMAN ...... 20 25

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A activity 36:5,10 31:10 32:11 35:6 22:4,9 23:6,7 available 1:25 8:11 A4 44:23 46:2,15 acts 33:21 35:11,16 37:11,16 28:22 29:13 32:11 14:5 16:12 21:5 A7 44:23 45:3,9 actual 10:3 27:13 41:19 51:8 34:8 37:23 38:15 29:20 35:24 42:12 46:15 adapted 16:13 alleged 2:15 31:11 38:18,22 51:19 avoid 20:3 ability 15:20 22:1 add 7:15 19:9 allocated 11:25 appropriate 25:25 aware 8:7 20:1 39:21 34:15 38:9 39:25 allow 7:19 45:22 29:17 30:21 47:25 24:15 26:3 27:1 able 5:1 6:19,21 address 6:6 11:21 allowed 7:12 44:20 appropriateness awareness 6:23 15:16 27:2 31:18 18:8 36:9,15 alternative 31:22 30:3 41:11,12,14 42:6,17 46:14 37:12 40:11 approving 38:21 B 48:20 adduce 32:3 Altman 3:5,7,17,18 April 4:22 12:16 abstract 19:15 adduced 12:4 30:2 3:19 13:22,23 apt 29:15 back 27:12 45:15 abuse 1:6,20 2:13 adequately 16:4 20:8,9,12,13 area 21:16 background 7:19 6:1,13 8:12 9:4,18 adjudication 35:16 27:24,25 28:13,19 areas 16:10 19:18 20:24 36:12 9:23 10:3 13:13 Administrative 28:20 34:20 35:2 arises 13:24 20:13 backward-looking 14:12 15:1,5,10 25:3 27:9,16 35:3 38:14,16,17 arising 3:1 6:9 15:14 17:5,9,9 adopt 16:16 45:1 47:15 49:9,10,18 arrangement 25:13 balance 27:2,3 23:25 28:18,21,24 adult 45:21 50:12,16,24 51:10 arrangements balanced 43:6 30:17,23 31:4 adults 31:2 35:18 51:17,22 42:10 balancing 18:20 32:11 35:9,21 advance 5:18 11:11 ambulance 45:19 arrived 30:1 22:1 36:22 39:14 40:23 advanced 24:10 amending 16:16 articles 31:23 40:10 bank 7:15 41:13 48:15 51:8 39:7 amendment 16:23 asked 4:24 8:8 11:3 base 4:18 abused 9:17 15:8 affidavits 44:18 17:3 11:20,21 12:24 based 14:4 36:19 15:13 23:22 29:17 afforded 39:16 amounts 21:23 37:12 42:10 43:9 47:18 33:18 34:4 37:1 42:23 44:14 Amsterdam 46:3 aspect 30:24 basically 45:1 45:7 age 8:15 analysing 2:18 aspects 10:4 11:23 basis 11:6 12:6,10 abuser 15:16 aged 46:3,16 and/or 8:14 14:23 assaulted 35:7 16:20 17:15 22:5 abusers 37:2 agencies 14:23,24 14:24 assembled 8:18 36:13 abusive 36:1,6 14:25 Ann 3:12 assembling 44:1 batches 42:5 academic 4:1 agenda 5:22 13:16 anticipated 12:13 assist 6:7 bear 30:3 acceptable 28:16 38:17 49:13 39:3 associated 30:7 bearing 8:5 access 12:23 15:16 ages 36:2 anybody 22:20 34:4 45:16 behalf 1:10 3:24 15:20 40:21 agreement 2:20 apart 5:12 assure 47:9 5:11 8:9 16:24 accommodate 22:9 apparent 17:4 assured 23:6 27:21 42:9 42:18 ahead 3:17 apparently 4:3 48:2 behavioural 7:7 account 2:15 11:7 aid 46:14 appear 3:19 attended 14:10 believe 18:20 46:20 accountable 24:1 Alan 3:11 appears 7:12 43:16 21:12 40:15,17 belong 21:12 accounts 11:14 albeit 43:15 application 44:25 attending 8:15 best 5:2 21:25 39:8 accused 13:13 Alexis 1:5 applications 23:3 49:20 46:20 achieving 48:22 alive 19:23 24:11,13 attention 4:5 blind 46:10 acknowledge 24:18 allegation 30:5 applies 24:23 author 24:3 blueprint 14:6 Act 32:23 34:10 allegations 2:13 6:1 applying 31:1 authorities 1:16 body 8:17 10:17 action 44:20 45:6 6:2,23 9:9,23 10:3 appreciating 33:11 14:23,24 18:1 book 9:10,13 actions 9:2 14:18 15:4 28:18 approach 4:15 5:6 30:12 35:24 borough 3:14 8:9 active 47:16 28:21,23,24 29:3 5:24,25 6:2,4 8:1 authority 40:18 9:3,7 10:1,13 activities 33:19 29:6,10,23 30:10 11:24 16:16 20:15 48:14 16:24 17:24 18:6

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DTI www.DTIGlobal.com 8th Floor, 165 Fleet Street (+44)207 4041400 London EC4A 2DY IICSA - Rochdale etc Preliminary Hearing 10 May 2017 Page 55 event 36:7 exploitation 7:4 files 21:9,19,21,22 50:20 give 5:2 11:9 17:25 events 31:10 41:4,5 14:12 30:24 31:3 final 4:12 33:12 foreshadowed 4:20 37:4 39:1,17 40:2 41:8,14 40:25 38:17 42:6 form 18:10 29:7 42:4,8,23 43:1 everybody 1:4 exploited 7:11 finally 3:15 6:3 former 35:6,10 45:23 46:18,23 22:17 27:20 15:24 41:17,22 46:11 forth 44:19 45:12 47:1 48:1 evidence 4:17 5:1,3 explored 18:21 49:7 45:22 given 5:3 18:12 9:19 10:18 11:9 exposed 7:4,9 find 5:22 14:15 forum 5:18 21:11,16 24:25 11:19,22,23 12:7 48:15 15:7,8 16:18 forward 48:7 49:25 26:6 30:22 35:19 12:12 13:2,8 expressed 47:20 21:25 48:11 found 46:9 36:2,17 37:22 16:12,13 23:11 extended 14:13 findings 4:18 5:25 founded 14:18 15:5 44:8 29:20 30:2,4 32:4 extent 1:18 6:18 8:22 12:6 13:15 four 46:6 globalise 14:9 35:12 36:17 38:24 7:11 14:17,21 14:19 15:3,18,25 fourth 6:1 14:15 go 3:17 15:11 22:18 39:1,3,14,17,20 17:20 48:12 16:2,11,20 17:5,6 35:3 39:20 40:9 27:12 37:21 45:3 39:21,23 40:3 17:14,15 22:4 40:25 46:8,11 42:4,8,24 43:1,2 F 29:12,15,18,25 frame 45:13 goes 40:12 43:10,19,23 44:15 facilities 45:20 30:4 32:17 33:17 framework 7:23 going 14:7 19:20 44:22,24 45:23 facing 19:18 32:15 34:3,7 39:18 Frank 1:8 25:17 28:10 29:2 46:19,24 47:2,10 fact 5:10 6:1,14 48:21 friend 19:22 37:5 47:11 48:1 15:10,22 29:16 finds 14:17 15:4 friendly 4:2 Good 1:4 3:16 evident 6:17 34:8 44:4 first 2:4 5:23 13:23 fulfilling 33:15 Gordon 3:10 evidential 16:20 fact-finding 18:11 15:21 18:14 19:13 full 2:1 43:24 governors 48:14 17:15 20:3 28:1 29:18 39:13 fuller 44:8 governorship examination 9:15 facts 4:5 8:21 33:4 40:5,13 41:12 function 33:3 40:20 17:22 31:15 factual 18:3 42:22 43:21 45:3 funded 8:15 grain 15:11 examine 1:18 15:19 failed 1:20 47:4 further 2:6 11:8 grateful 5:13 49:22 31:9 failing 17:7 five 4:4 5:20 17:18 22:19 24:13 great 2:12 5:15 example 16:4 20:20 failings 14:22 15:3 fixed 14:6 37:18 43:21 44:20 46:21 20:24 23:3,12 15:9,20 16:2 17:6 flat 46:24 45:6 Greater 3:11 9:1,2 26:16 28:9,24 36:18 flexible 14:3 16:9 future 1:23 9:21,25 19:7 30:4 failure 17:8 16:16 23:7 22:11 25:12 32:5 examples 15:14 failures 15:12 focus 9:12 11:22 G 37:6 41:8 existence 36:16 17:16 35:20 48:3 31:8 35:20,23 gaps 23:17 ground 49:24 existing 11:7,13 48:5 36:17 Garnham 8:7,8,17 group 21:12 exists 16:20 fairly 29:21 focused 9:24 10:15 13:4 guidance 16:10 expedite 44:5 fairness 39:16 focuses 1:14 gathered 9:19 10:6 guide 14:3 39:12 expedited 47:21 fall 5:20 32:8 37:14 follow 12:21 10:19 35:1,4 experiences 1:15 families 28:10,14 following 3:8 39:10 37:23 51:14 H 9:14 family 21:16 40:4 general 13:12 happen 16:6 experimentation far 15:6 27:8 28:3 foot 33:23 31:23 43:23 happened 24:10 36:3 49:15 forces 22:15 32:7 generally 10:12 happening 16:1,7 explain 44:24 February 2:5 45:4 Ford 3:14 16:24 generated 9:6 harmful 36:1 explained 10:22 feel 40:1 17:11 19:10,11,12 generous 24:25 Harry 30:8 41:16 22:14 fifth 38:17 40:10 20:5 27:22 32:13 geographical 7:18 heading 41:11 explains 37:8 41:2 33:6 34:16,17,23 31:7 health 36:13 46:23 explanation 25:24 figure 6:19 38:10,11 49:5,6 gist 21:21 hear 2:22 43:6 48:6

DTI www.DTIGlobal.com 8th Floor, 165 Fleet Street (+44)207 4041400 London EC4A 2DY IICSA - Rochdale etc Preliminary Hearing 10 May 2017 Page 56 heard 26:18 32:13 33:11 38:2 42:10 indicated 3:22 5:5 21:10 22:13 29:19 7:24 8:1,5,6,25 49:10 42:20 43:8 44:10 14:14 16:23 32:14 30:20 37:19 9:12,20 10:2,8,9 hearing 1:11 2:18 44:11,12 48:24 37:24 inquiry-wide 43:22 10:24 11:2,6,7 2:20,24 3:1,3,3 50:18 51:1,12,24 indications 42:25 insofar 16:9 37:21 12:4,13 13:6,7,12 4:11,16 5:4,15,19 Hydrant 25:14 individual 13:20 40:12 41:17 13:25 14:4,7,8,10 11:25 12:5 29:8 16:14 20:17 29:16 instance 15:21 15:15 16:15 17:21 33:23 39:2 42:24 I 30:22 39:15,16 instant 29:15 18:9 20:18,21 43:17,18 44:2 idea 23:18 24:12 individuals 11:15 institution 7:8 21:4,6,18,24,25 48:4 49:17 50:1,2 48:10 13:12 21:3,11,12 institutional 2:13 29:14,15 30:6,9 50:5 identification 21:15 22:3 26:15 9:16 17:16 29:6 30:10,14,24 31:7 hearings 2:1,4,7,9 26:22,23 27:4 28:2 32:12 36:18 48:3 31:9,14,15,16,21 4:9,12 6:4 8:6 identified 5:2 8:19 33:18 37:5,9 institutions 1:15,19 32:2,3,8,19 35:6 10:23 11:17 12:11 36:24 42:15 individuals' 39:13 6:11,12,14 7:17 35:11,17,19,20 17:21 18:2,5,12 identify 36:25 inevitably 43:17 14:13 29:9 34:4 36:8,18,19 37:3,6 32:21 38:15,18,22 identity 21:2 inferred 33:4 48:8 37:15,17 38:23 40:3 42:16 51:19 ignored 47:5 48:16 inform 39:5 42:14 instructing 33:21 39:24 40:8 42:13 hears 16:12 ill-suited 35:16 information 2:12 45:25 42:15 43:3,5,9 heart 46:8 illnesses 47:5 8:10 9:4,6 14:5 insufficient 21:11 44:4 heavily 24:9 immobility 45:17 15:13 16:4 20:19 intelligence 14:24 investigation's 5:24 Henderson 3:20 immunity 23:3 20:22 21:5,19,23 intended 7:15 5:25 6:2,4 20:15 Higgins 40:24 24:11 27:11,15 35:23 11:17 14:2,5 16:8 42:3 Hilton 15:15,18 impairments 45:22 informed 8:2 42:7 17:2 18:2 37:22 investigations 7:1 30:16 impassioned 49:21 informing 42:16 40:2,3,14 8:2 13:4 16:14 Hilton's 41:2 implicated 31:2 inhalers 45:11 intends 10:8 12:9 19:19 24:16 30:6 historical 7:24 18:3 41:13 inhibit 48:20 37:6,18 41:15 49:25 history 23:18 46:4 implications 36:14 inhibited 33:2,15 intention 11:22 investigative 26:13 hold 23:1 47:3 important 4:14 Inquiries 34:10 interest 7:24 23:3 invite 3:4,7 13:20 holds 22:3 26:12 11:19 23:19,23 inquiry 1:6,8,10,17 24:11 30:18 31:24 18:15 22:19 37:25 home 6:14 40:17 30:23 39:19 1:24 2:1,12 3:4,20 interested 6:18 39:6 44:9 46:11 inability 29:22 3:23,23 4:16,21 interests 46:20 invited 4:18 5:9 8:4 hope 18:22 27:7,14 inadequate 48:14 6:17,25 7:19 9:22 internal 25:4 12:5 41:25 42:17 inappropriate 11:18 12:9,24 internally 25:5 involved 8:14 15:21 hoped 12:19 33:25 36:2 13:2 14:17 15:4,6 interpreted 16:25 31:19 36:3 37:9 hostel 6:15 incapacity 48:18 15:11 16:9,20 intervals 47:6 39:15 hours 46:12 include 36:11 17:4,20 18:21,22 interviewed 8:19 involvement 2:15 house 1:11 2:10 3:6 included 2:25 8:10 19:18 22:1,3 23:1 11:5 30:12 40:19 6:14,16 9:11,14 9:2,6 35:5 23:8 24:1 25:1 interviews 10:18 irrelevant 33:24 14:11 21:7,14 including 13:18 27:3,6,18 29:13 introduce 11:19 34:9 33:19 40:5,6 14:12,21 29:22 32:17,22,24 33:2 investigate 15:12 Irrespective 36:7 46:15 30:4,7 40:20 41:6 35:15 37:22 38:3 investigated 9:8 issue 13:3,24 16:22 housebound 45:11 47:13 43:13,16 45:1 16:5,10 32:6 37:8 18:15 19:5 20:4 Hoyano 3:10,25 incontinent 46:13 46:19 47:3,9,17 46:19 20:10,13 22:18 18:17,18 19:3 independent 1:5 47:24 48:1,20 investigation 1:12 24:17,18 28:20 22:21,22,23 25:7 8:9 inquiry's 3:2 7:16 1:13 2:10 3:6 4:9 32:10 33:11 35:4 27:25 28:13 33:10 indicate 24:20 12:14 13:10 18:19 4:11 6:8,10 7:10 38:24 39:22 41:19

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DTI www.DTIGlobal.com 8th Floor, 165 Fleet Street (+44)207 4041400 London EC4A 2DY IICSA - Rochdale etc Preliminary Hearing 10 May 2017 Page 59 probably 34:19 15:9 17:8,23 question 14:13 redactions 26:11 remove 46:7 45:16 protocol 30:21 31:2 questioned 43:13 refer 13:25 28:9 rendered 7:23 problems 7:20,22 37:20 questions 31:25 reference 29:19 repeat 29:2,8 33:5 19:20,21,24 proved 15:7 quite 25:11 33:16 37:15 47:24 report 8:20 33:15 procedures 45:1 provide 3:5 5:1 6:7 referred 28:15 reports 9:6 proceed 3:21 11:3 16:17,19 R 30:15 31:3 35:8 represent 42:20 proceeding 22:24 17:14,21 20:24 raise 35:17 refers 24:5 representations proceedings 13:2 27:10,14,20 37:7 raised 19:24 28:1 refined 17:18 26:18,24 27:5 33:22 34:6,9 38:24 39:21 40:14 32:21 36:9 44:7 reflected 5:21 representative 43:7 proceeds 11:6 42:2 44:24 46:1 raises 4:7 regard 2:20 6:18 representatives 14:20 provided 4:22,23 reach 18:22,22 32:16 36:16 39:10 12:23 process 13:7 17:17 5:11 11:13 12:25 read 39:4 39:17 41:22 represented 3:9 22:6 39:6 42:13 21:21,21 25:17,24 real 43:25 regarded 5:1 12:7 42:22 produced 25:6 27:14 35:14 43:2 reality 12:2 12:12 request 28:5 professional 24:22 43:19 47:25 really 33:24 regarding 7:3 require 12:23 24:23 27:8 provides 16:10 reason 11:2 19:25 31:10 37:15 15:25 17:9 29:11 Professor 1:8 3:22 32:23 33:1 reasoned 47:17 regardless 36:5 29:25 44:3 programme 1:25 providing 5:14 reasons 6:20 24:9 regards 17:7,23 requires 11:8 39:16 programmes 2:6 44:15 44:7 28:5 36:4 37:10 requiring 47:21 prolonged 30:19 provision 41:20 receive 23:17 47:10 39:22 40:4 42:19 resided 6:12 7:3,11 prominent 31:18 43:23 received 2:14 13:19 relate 20:17 21:3 9:14 21:7 31:8 proof 17:1,9 provisional 4:24 23:14 related 9:11 30:16 residential 7:5 proportionate 38:20 39:9 41:23 receives 16:13 31:12,20 35:18 40:16 41:20 11:24 36:23 public 1:19 2:4,9 45:13 relates 28:2 35:12 residents 7:9 8:14 proportionately 6:19,22 10:7 recipients 24:4 relation 24:16,20 35:6,8 11:1 14:24 18:2,5 23:2 recite 14:7 25:1,14,21 26:4,6 resolve 18:3 36:23 propose 45:18 24:11 30:25 31:18 recognise 28:8 27:25 respect 6:1 13:15 proposed 5:10 39:2 recognised 28:8 relationship 17:5 26:11 28:25 29:4 16:23 17:3 18:14 publication 31:22 recommendations 40:7 31:4 35:10 44:5 19:2 42:2 40:10 1:22 4:19 33:5 relatively 18:4 43:4 respectfully 16:15 proposes 28:13 publicity 2:15 record 3:21 22:10 released 46:11 29:24 prosecute 10:11 publicly 1:25 5:18 recorded 10:21 relevant 5:1 12:3,7 respecting 34:2 25:3,4 40:10 30:22 43:20 12:12 13:7 20:24 respond 5:9 29:23 prosecuted 7:2 published 3:1 records 20:16,18 21:4,23 23:1,2 34:21 35:21 prosecuting 14:23 pulmonary 45:9 20:20,22,23 21:3 25:17 29:18 37:13 responded 29:9 prosecution 3:13 pupils 8:14 30:25 22:3 28:6 rely 10:8 31:17 32:1,5 10:11 24:21,24 35:10 40:15 redact 13:9 remain 6:21 17:13 responding 39:15 26:12 29:4 37:10 purpose 10:23 redacted 21:22 18:25 31:18 response 9:4,25 45:5 35:23 24:9 26:20 remained 4:2 10:12 16:3,22 Prosecutions 10:7 put 10:19 44:4 48:9 redacting 21:9 remaining 19:14 23:4,10 29:6 41:5 prosecutors 35:14 48:11 28:14 remarks 1:3 3:18 41:8,18 protect 1:20 14:25 redaction 13:3,10 50:10,12 responses 9:16 15:12 17:8 22:2 Q 13:11 22:13,18 remit 9:8 31:7 10:20 13:18 22:8 26:15 36:4 QC 3:5,12,13,14 25:16,21,23 26:1 remote 43:15 45:24 32:9 37:21 48:13 protection 7:20,23 8:7 30:21 31:2 37:20 47:13 responsibility

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DTI www.DTIGlobal.com 8th Floor, 165 Fleet Street (+44)207 4041400 London EC4A 2DY