Digital copy of Witness 192's Application Form and Supporting Documentation to the Historic Abuse Redress Scheme. [Some details redacted]. For Witness 192's witness statements to the States of Jersey Police, see C/D/AW1/B1/2/2/21.

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November 12th 2008 - April 20th 2012

Scope and Content

Application Form Personal details: Includes place and year of birth. Claimant's representative: Names Alan Collins of Pannone LLP as her Solicitor. Details of care: Refers to placement at Haut de la Garenne between circa 1966 and 1982. Abuse alleged to have taken place: Describes being physically and sexually abused between 1966 and 1982, referring to disclosures in the letter of claim [see below] and police statements [see C/D/AW1/B1/2/2/21]. Names Morag Jordan amongst three perpetrators of abuse. Complaints of abuse: Describes complaining to Mr [Jim] Thomson about Morag Jordan. Criminal proceedings: Confirms to have provided six statements to the States of Jersey Police as part of the historic abuse inquiry. Refers to conviction of Morag Jordan, noting that she gave evidence in Court against Jordan. Previous civil proceedings: Refers to a Letter of Claim sent to Mourant Ozannes dated 31 May 2011. [See below]. Declaration of truthfulness: Signed in the presence of a Solicitor on 20 April 2012. Supporting Documentation to the Application Form: 1. Authority for access to Medical Practitioner Records dated 20 April 2012. Names Dr P Venn of Cleveland Clinic as a past or present medical practitioner with whom she has been registered. 2. Witness 192's witness statement to the States of Jersey Police dated 12 November 2008 providing an account of her experiences in care at Haut de la Garenne. Signature witnessed by [Civilian Investigator] M Pick. Refers to previous statements made to the Police. Provides answers to questions asked by Police about her time in care regarding hospital admissions and operations, injuries including scars and scald marks. Refers to a copy of a photograph showing Jimmy Savile with children at Haut de la Garenne, stating that he has provided names of 8 children that she can identify. 3. Letter of Claim dated 31 May 2011 from Verisona to Advocate B Lacey, Mourant Ozannes. Regards instruction by Witness 192 to claim compensation from the States of Jersey in respect of physical, emotional and sexual abuse suffered whilst in its care between circa 1966 and 1980. Notes that the States of Jersey was responsible for the management, control and administration of Haut de la Garenne. Includes a statutory backdrop outlining the common law duty of care owed by the States of Jersey to children in its care. Gives details of the sequence of events with respect to Witness 192, including year of birth and placement in Haut de la Garenne in circa 1966. Sets out the duty of care and vicarious duties owed to Witness 192 by the States of Jersey with respect to Witness 192's welfare, protection, education, safety, medical treatment, protection from abuse. Includes complaints of abuse by Witness 192. Refers to physical abuse by Morag Jordan, unlawful detention by Jordan or Mr [Jim] Thomson, Superintendent, witnessing ill treatment of children at Haut de la Garenne, sexual abuse by a male individual. Notes that complaints made by Witness 192 about sexual abuse by the man and complaints about Jordan's conduct were met by indifference or disbelief. Sets out grounds upon which the States of Jersey was negligent in its duty of care to Witness 192. Give details of injury loss and damage, referring to a psychiatric report from Professor Anthony Maden. Sets out limitations and requests disclosure of all records relating to Witness 192 and all records relating to Haut de la Garenne. Also gives details of emotional impact of proceedings on Witness 192, mentioning distress caused by media publicity and hope that the claim is resolved following Jordan's conviction.


Collins, Alan
Jordan, Morag
Lacey, Beverley, Advocate
Maden, Anthony, Professor
Pick, Michael, Civilian Investigator
Thomson, Jim
Venn, Philippa, Dr
Children's Services
Cleveland Clinic
Haut de la Garenne
Historic Abuse Redress Scheme
Jersey Home for Boys
Lacey Advocates
Mourant Ozannes
Pannone Solicitors
States of Jersey
States of Jersey Police


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