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Digital copy of Witness 171's Application Form and Supporting Documentation to the Historic Abuse Redress Scheme as supplied by Lacey Advocates. [Some details redacted]. For Witness 171's witness statements to the States of Jersey Police dated 13 March 2008 and 15 March 2009 respectively, see C/D/AW1/B1/2/1/15/WS000133 and C/D/AW1/B1/2/1/15/WS000134.
July 7th 1999 - April 18th 2012
|Scope and Content|
Application Form Personal details: Includes Witness 171's year and place of birth. Claimant's representative: Names Alan Collins of Pannone LLP Solicitors as Witness 171's legal representative. Details of care: Refers to placement at Haut de la Garenne between 1962 and 1979. Refers to placement at Haut de la Garenne and Norcott Villa [Family Group Home], mentioning placement of siblings in care and a care order made in 1968. Abuse alleged to have taken place: Refers to physical, sexual and emotional abuse between 1962 and 1979, mentioning Mr [Colin] Tilbrook [Superintendent, Haut de la Garenne]. Comments on lack of witnesses to abuse. Complaints of abuse: Notes complaint made to [Child Care Officer] Mr [David] Castledine. Criminal proceedings: Confirms to have provided statements to the States of Jersey Police dated 7 July 1999, 13 March 2008 [C/D/AW1/B1/2/1/15/WS000133] and 12  March 2009 [C/D/AW1/B1/2/1/15/WS000134]. Previous civil proceedings: Refers to Letter of Claim sent to Mourant Ozannes on 21 April 2009. Declaration of truthfulness: Signed on 18 April 2012. Supporting Documentation to the Application Form: 1. Authority for access to Medical Practitioner Records dated 18 April 2012. 2. Witness 171's witness statement to the States of Jersey Police dated 7 July 1999. Refers to placement in Haut de la Garenne and foster placement between the ages of 4 to 14, citing alcoholism and neglect by parents. Mentions physical and sexual abuse suffered whilst at Haut de la Garenne, noting decision to not comment on this abuse. Refers to placement at a residential school from 1974/1975. Includes recollections of the property, mentioning dormitories, houses, scullery and a secure unit. Also includes recollections of other boys placed in the secure unit whilst in residence. Gives details of sexual abuse by a male member of staff at the secure unit, including a physical description of his abuser. Includes description of the long term impact of abuse, mentioning medication to cope with associated trauma. Notes that he was never physically abused whilst in the secure unit, commenting on solitary confinement. Names David Castledine as his social worker. 3. Witness 171's witness statement to the States of Jersey Police dated 13 March 2008 providing an account of physical and sexual abuse suffered whilst at Haut de la Garenne and Norcott Villa. Witnessed by [Detective Constable] [Jim] McGranahan. [For a copy of this witness statement, please see C/D/AW1/B1/2/1/15/WS000133. Please note that the level of redaction of the copies differ]. 4. Witness 171's witness statement to the States of Jersey Police dated 13  March 2009 providing an account of physical and sexual abuse suffered whilst at Haut de la Garenne and Norcott Villa. Witnessed by [Detective Constable] [Jim] McGranahan. [For a copy of this witness statement dated 15 March 2009, please see C/D/AW1/B1/2/1/15/WS000134. Please note that the level of redaction and formatting of the copies differ]. 5. Letter of Claim from Mark Temple, Partner at Ozannes to Advocate B Lacey of Mourant du Feu and Jeune, dated 21 April 2009. Relates to instruction made by Verisona Law [Dyer Burdett Gray Purdue Ltd], solicitors and advocates acting for Witness 171, to claim compensation from the States of Jersey in respect of physical, sexual and emotional abuse that Witness 171 suffered whilst in its care at Haut de la Garenne and Norcott Villa between 1 November 1965 and 30 October 1977. Sets out statutory provisions of the States of Jersey in respect of a child in its care, mentioning child protection, corporal punishment and standards of care. Includes a sequences of events, including the dates of Witness 171's admissions and discharges from Haut de la Garenne and Norcott Villa. Includes an overview of the duty of care owed by the States of Jersey to Witness 171 whilst he was in its care, including vicarious duties such as the duty of care owed by social workers and members of staff employed by the States of Jersey at Haut de la Garenne and Norcott Villa. Includes complaints of abuse, detailing physical, sexual and emotional abuse Witness 171 suffered whilst in residence at Haut de la Garenne and Norcott Villa. Gives details of physical and sexual abuse by Colin Tilbrook [Superintendent, Haut de la Garenne], sexual abuse by a male member of staff at Norcott Villa and sexual abuse by fellow residents at Haut de la Garenne. Sets out the grounds on which the States of Jersey was at breach of its duty of care and/or negligent. Sets out Witness 171's claim for damages for personal injury loss as a result of the negligence and/or breach of duty of the States of Jersey. Also requests disclosure of all records relating to Witness 171 and all records relating to Haut de la Garenne and Norcott Villa.
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