CRIMINAL LITIGATION, EVIDENCE &

SENTENCING
UNIT 7 - R V QUINN CASE PAPERS PART ONE

IN THE CROWN COURT AT

MANCHESTER

REX
V
JONATHAN QUINN
----------------------------------
BRIEF TO COUNSEL
FOR THE DEFENDANT
----------------------------------
COUNSEL: A Counsel
REPRESENTATION ORDER

Solicitors: TREVOR PHILLIPS & Co

7th Floor
South Central
22 Peter Street
Manchester M2 5PT

Ref: SO/24
Tel: 0161 833 4557

730266559.docx 1
©The University of Law
IN THE CROWN COURT AT MANCHESTER Case No: T:2023/0087

BETWEEN

REX
v
JONATHAN QUINN
BRIEF TO COUNSEL

Mr Quinn is charged with one count of robbery. At his first hearing at Manchester City
Magistrates’ Court on 7th December 2023, his case was sent to Manchester Crown
Court under section 51 of the Crime and Disorder Act 1998 and a Plea and Trial
Preparation Hearing was set for 11th January 2024. Bail was applied for and refused.
A further bail application was made before His Honour Judge Terry at Manchester
Crown Court on 14th December 2023 and was similarly refused.

Counsel will find herewith the various documentation served by the prosecution
pursuant to section 51 of the Crime and Disorder Act 1998 on 21 st December 2023.
Initial prosecution disclosure was also served on 21 st December 2023. Counsel will
also find herewith an initial proof of evidence.

Those instructing understand that the police are currently preparing a map of the
area which, it is anticipated, will be agreed with the defence. It is hoped counsel will
be able to use the map when taking the defendant through his evidence and in cross-
examination of the prosecution witnesses.

Counsel is instructed to attend Manchester Crown Court to represent Mr Quinn at his

Plea and Trial Preparation Hearing on 11th January 2024 and at trial thereafter. A
conference has been booked for 23rd December 2023 at 5pm at HMP Manchester.
Those instructing would be grateful if counsel could draft a defence statement
following the conference.
Cecilia Abong
Trevor Phillips & Co.
21st December 2023

730266559.docx 2
©The University of Law
 THE KING

-V-

JONATHAN QUINN

_____________________________________________

PAPERS SERVED PURSUANT TO s.51 CDA 1998

_____________________________________________

730266559.docx 3
©The University of Law
 INDICTMENT NUMBER: T:2023/0087

INDICTMENT

IN THE CROWN COURT AT MANCHESTER

THE KING v JONATHAN QUINN

JONATHAN QUINN is charged as follows:

STATEMENT OF OFFENCE

Robbery, contrary to section 8(1) of The Theft Act 1968

PARTICULARS OF OFFENCE

Jonathan Quinn, on the 5th December 2023, robbed Helen Taylor of a

Samsung Galaxy mobile phone, a Natwest Visa Debit card and a Natwest
Credit card

17th December 2023

Crown Court Officer

730266559.docx 4
©The University of Law
 Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)

Statement of ...............Helen Taylor URN 06 AT 40451 23

Age if under 18 over 18 (if over 18 insert ‘over 18’) Occupation.... Nurse
This statement (consisting of .2. page each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be
liable to prosecution if I have wilfully stated in it anything which I know to be false or do not
believe to be true.

Dated 5th December 2023 Signature

Tick if witness evidence is visually recorded □ (supply witness details on rear)

I am the above named person and I live at the address overleaf. On 5 th December
2023, I was working nights so I left my place of work at The Royal Hospital in the
centre of Manchester at 6.00 a.m. and walked towards my home address. The route
takes me along Northumberland Avenue.

Approximately half-way down Northumberland Avenue, I heard footsteps running

behind me and I was suddenly grabbed from behind. I felt a strong grip around my
mouth and I felt the other arm grab me around my shoulder. A male voice said,
“Don’t say a word or I’ll do you”.

I understood that to mean that he would hurt me or do something even worse. I was
really petrified. I was shaking, but just stood very quietly. The man grabbed my bag,
which was over my shoulder and ran back down the road. I did not put up a struggle
as I was very scared about what he might do to me. Once I heard the man’s
footsteps disappear I ran to my house and dialled 999 for the police.

I only saw the man very briefly. He was taller than me, I should think about 6’, white

Signature Signature Witnessed by M Gilbertson

730266559.docx 5
©The University of Law
Continued Page 2

and young. He was quite thin. He was wearing a blue denim jacket and blue denim
jeans. I caught a glimpse of his head from behind briefly and remember that he had
short, cropped red hair. He also had white trainers on. I would not be able to
recognise him again as I did not see his face. I don’t think that I would be able to
recognise his voice either.

My bag was a “Gucci” black leather bag with a bamboo design shoulder strap. It had
my purse in it with about £80 in cash, my Natwest Visa Debit card, account number
45780001, my Natwest credit card, account number 6374 2859 4736 4567 and also
my white Samsung Galaxy mobile phone.

I was extremely scared by the whole incident and I am now petrified of walking to
work. I am willing to attend court if necessary.

Signature Signature Witnessed by M Gilbertson

730266559.docx 6
©The University of Law
 Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)

Statement of ...Mike Gilbertson 06 AT 40451 23 URN

Age if under 18 Over 18 (if over 18 insert ‘over 18’) Occupation .Police Constable
This statement (consisting of 2 pages each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable
to prosecution if I have wilfully stated in it anything which I know to be false or do not believe
to be true.

Dated 5th December 2023 Signature M Gilbertson

Tick if witness evidence is visually recorded □ (supply witness details on
rear)

I am Mike Gilbertson PC 700 CM attached to Manchester City Police Station. On 5 th

December 2023 at about 6.35 hours I was on uniform duty on mobile patrol on
Lancashire Road in Manchester. I turned into Victoria Avenue and I saw PC Foster
pursuing on foot a male who I now know to be Jonathan Quinn who was running
along Victoria Avenue towards Lancashire Road between Northumberland Avenue
and Blackmore Drive. I drove up to PC Foster who told me he had seen the male
turn out of Northumberland Avenue and that the male he was pursuing was about 6’,
white or mixed heritage, aged about 20, had short red hair and was of a slim build.
He was wearing a blue denim jacket and blue denim jeans. He was also wearing
white trainers. PC Foster told me that the male fitted a description of a suspect who
had recently committed a robbery a few streets away.

I drew up alongside Jonathan Quinn and I alighted from my vehicle. As I approached

him he stopped running. I saw that he was wearing blue jeans and a blue denim
jacket with white trainers. He also had short, reddish-brown hair. I walked up to Mr
Quinn, I activated my body worn video equipment and explained that I was recording
the stop. I further explained that he matched the description of a man involved in a

Signed M Gilbertson . Signature witnessed by .

730266559.docx 7
©The University of Law
Continuation of statement of M. Gilbertson .

recent robbery, cautioned him and asked him his name and address to which he
replied “I haven’t done anything”. I asked him where he was coming from and he
said, “From work. I’ve just got out five minutes ago, so I wouldn’t have had time to
commit no robbery would I?” I asked him where he worked and he replied, “I’m a
night cleaner at the Royal Kensington Hotel on Peter Street”.

I then informed him that I was going to search him, administered GOWISELY and
conducted a search of his jacket pockets. I found a Natwest Visa Debit card, number
45780001 (exhibit MG/1) and a Natwest Credit card, number 6374 2859 4736 4567
(exhibit MG/2) both in the name of ‘H Taylor’ and a white Samsung Galaxy mobile
phone (exhibit MG/3). I said to him, “Where did you get these?” He replied, “I’ve just
found them.”

I then arrested Mr Quinn on suspicion of robbery and re-cautioned him, to which he

replied, “I don’t believe this, I haven’t done no robbery. I never did it. I would never
nick stuff”. My body worn video camera was recording throughout my time at the
scene. I now produce the footage from my camera as my exhibit MG/4.

Mr Quinn was then placed in a police vehicle and conveyed to Manchester City
Police Station. While Mr Quinn was being taken to the police station, he said, “Fuck, I
am going down for this.”

At 10.09 hours, together with DC 321 Raymond I commenced a recorded interview

with Mr Quinn. The interview was recorded on a disc using the disc reference
number BB/P12/267/Quinn/23. Mr Quinn answered “No comment” to the majority of
questions put to him. The interview was then terminated at 10.20 hours. The disc of
interview is produced as exhibit MG/4 and the subsequent written summary as MG/5.

Mr Quinn was then taken to the Custody Sergeant at 11.00 hours and charged with
robbery at 11.05 hours. He made no reply to charge.

Signed M Gilbertson Signature witnessed by .

730266559.docx 8
©The University of Law
730266559.docx 9
©The University of Law
 Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)
Statement of ......Luke Foster URN 06 AT 40451 23
Age if under 18 Over 18 (if over 18 insert ‘over 18’) Occupation … Police Constable
This statement (consisting of 1 page each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable
to prosecution if I have wilfully stated in it anything which I know to be false or do not believe
to be true.
Dated 5th December 2023 Signature L Foster
Tick if witness evidence is visually recorded □ (supply witness details on rear)

I am Luke Foster PC 650 CM attached to Manchester City Police Station. On 5 th

December 2023 at about 6.30 hours I was on uniformed foot patrol duty in Mount’s
Place, Manchester. Acting on information received I headed towards Northumberland
Avenue, via Victoria Avenue. I observed a male, I now know to be Jonathan Quinn,
walking quickly out of Northumberland Avenue into Victoria Avenue. The male
closely fitted the description of a suspect who had recently committed a robbery
close by. I called out to the male, “Stop, police”. The male then began to run towards
Lancashire Road and I pursued him on foot. The male was about 6’, white or mixed
heritage, aged about 20, had short red hair and was of a slim build. He was wearing
a blue denim jacket and blue denim jeans. He was also wearing white trainers.

Whilst I was pursuing the male on foot a police vehicle drew up alongside me and I
told the officer who was driving that vehicle, PC Gilbertson 700 CM, that I was
pursuing a male who fitted the description of a suspect who had recently committed a
robbery close by. PC Gilbertson then pursued the suspect in the vehicle. I saw PC
Gilbertson alight the vehicle further along Victoria Avenue and stop to talk to the
suspect. The male stopped running at this point.

I continued along Victoria Avenue and joined PC Gilbertson and the suspect. I
activated my body worn video camera at this point, shortly before Mr Quinn was
placed in the police vehicle. I produce the footage as my exhibit LF/1.

Signed L Foster Signature witnessed by

730266559.docx 10
©The University of Law
 Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)
Statement of ......Mike Gilbertson URN 06 AT 40451 23
Age if under 18 Over 18 (if over 18 insert ‘over 18’) Occupation … Police Constable

This statement (consisting of 1 page each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable
to prosecution if I have wilfully stated in it anything which I know to be false or do not believe
to be true.
Dated 6th December 2023 Signature M Gilbertson
Tick if witness evidence is visually recorded □ (supply witness details on rear)

Further to my statement dated 5 th December 2023, I confirm that on the 6 th

December, Helen Taylor attended Manchester City Police Station for the purpose of
identifying items she alleged to have been stolen from her during an incident on 5 th
December 2023.
I attended Ms Taylor and showed her the following items:
1. Natwest Visa Debit card, account number 45780001 (exhibit MG/1).
2. Natwest Credit card, account number 6374 2859 4736 4567 (exhibit
MG/2).
3. White Samsung Galaxy mobile phone (exhibit MG/3).

730266559.docx 11
©The University of Law
Signed M Gilbertson Signature witnessed by .
Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)
Statement of ......Helen Taylor URN 06 AT 40451 23
Age if under 18 Over 18 (if over 18 insert ‘over 18’) Occupation … Nurse

This statement (consisting of 1 page each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be liable
to prosecution if I have wilfully stated in it anything which I know to be false or do not believe
to be true.

Dated 5th December 2023 Signature

Tick if witness evidence is visually recorded □ (supply witness details on rear)

Further to my statement dated 5 th December 2023, I confirm that on the evening of

6th December 2023, I was shown the following items by PC Gilbertson:
1. Natwest Visa Debit card, account number 45780001 (exhibit MG/1).
2. Natwest Credit card, account number 6374 2859 4736 4567 (exhibit
MG/2).
3. White Samsung Galaxy mobile phone (exhibit MG/3).

I confirm that these items belong to me and were in my handbag when it was stolen
on the 5th December 2023.

Signed Signature Witnessed by M Gilbertson

730266559.docx 12
©The University of Law
730266559.docx 13
©The University of Law
IN THE MANCHESTER CROWN COURT

REX

-V-

JONATHAN QUINN

__________________________________________

LIST OF EXHIBITS
__________________________________________

1. Natwest Visa Debit card number 45780001 MG/1

2. Natwest Credit card number 6374 2859 4736 4567 MG/2

3. White Samsung Galaxy mobile phone MG/3

4. Summary of interview MG/4

5. Interview disc MG/5

730266559.docx 14
©The University of Law
Trevor Phillips & Co Solicitors
7th Floor, South Central
22 Peter Street
Manchester M2 5PT
CPS

21 December 2023
URN: 06 AT 40451 23

Dear Sirs

LETTER TO DEFENCE WHERE THERE IS NO MATERIAL TO DISCLOSE (CROWN COURT)

R v Jonathan QUINN

COURT AND NEXT HEARING DATE: Manchester Crown Court 11th January 2024

I am required to disclose to you any prosecution material which has not previously been
disclosed, and which might reasonably be considered capable of undermining the prosecution
case against the accused or of assisting the case for the accused.

Attached to this letter is a copy of a schedule of non-sensitive unused material. The disclosure officer
in this case is PC BRADLEY

Where the word ‘evidence’ appears alongside any item, the items listed on the schedule are intended
to be used as part of the prosecution case. You will receive a written notice should the position
change.

At this stage there is no prosecution material which requires disclosure to you.

** If you supply a written defence statement to me and to the court within 28 days, any undisclosed
material will be further reviewed in the light of that statement.

The defence statement must comply with the requirements of section 6A of the CPIA:

(1) For the purposes of this Part a defence statement is a written statement-
(a) Setting out the nature of the accused’s defence, including any particular defences on which he
intends to rely,
(b) Indicating the matters of fact on which he takes issue with the prosecution,
(c) Setting out, in the case of each such matter, why he takes issue with the prosecution,
[ (ca) setting out particulars of the matters of fact on which he intends to rely for the purposes
of his defence, and ]
(d) Indicating any point of law (including any point as to admissibility of evidence or an abuse of
process) which he wishes to take, and any authority on which he intends to rely for that
purpose.

(2) A defence statement that discloses an alibi must give particulars of it, including-
(a) Indicating any point of law (including any point as to admissibility of evidence or an abuse of
process) which he wishes to take, and any authority on which he intends to rely for that
purpose.
(b) Any information in the accused’s possession which might be of material assistance in
identifying or finding any such witness in whose case any of the details mentioned in
paragraph (a) are not known to the accused when the statement is given.

730266559.docx 15
©The University of Law
** A defence statement is required in Crown Court cases. In accordance with my continuing duty, I will
review the information you provide in the statement to identify any remaining material which has not
already been disclosed. The statement will also be relied on by the court if you later make an
application under section 8 CPIA.

If you do not make a CPIA-compliant defence statement where one is required or provided, or do so
late, the court may hear comment and/or draw an adverse inference.

You are also required to give advance details of any witnesses you intend to call at trial within 28 days,
which can be extended on application. If you do not give details, or do so late, the court may comment
and/or draw an adverse inference.

Yours faithfully

J. G. Achariya

Senior Crown Prosecutor

730266559.docx 16
©The University of Law
 OFFICIAL (when complete) MG6
C

POLICE SCHEDULE OF RELEVANT NON-SENSITIVE UNUSED MATERIAL

R v QUINN Jonathan
FOR CPS USE:
The Disclosure Officer believes the following RELEVANT MATERIAL which does not form part of the prosecution case is NOT SENSITIVE. *Enter
For further detailed guidance refer to the Disclosure Manual and Attorney General’s Guidelines. D = Disclose to defence
I = Item disclosable and defence may inspect
CND = Clearly not disclosable (by description)
ND = Document viewed and not disclosable
Item Record below MATERIAL of any kind, including information and objects, which is obtained in the LOCATION
course of a criminal investigation and which may be relevant to the investigation; and Sate precisely where the
No. RELEVANCE is that it has some bearing on any offence under investigation or any person being item can be found/located
investigated or on the surrounding circumstances of the case, unless it is incapable of having any
impact on the case. Do not speculate. If it is not considered relevant do not record it on the * REASON FOR DECISION
schedule. Give a sufficiently detailed DESCRIPTION of the relevant material for the prosecutor to
make a decision on whether or not it should be examined.
1 The relevant material is CAD 43526. Call to police from Helen TAYLOR, member of public, Police ND
reporting a robbery. CAD shows Police units dispatched to the scene, updates & arrest of suspect
2 The relevant material is C5536/199 JD Crime Report. Report created by Police for the offence. Police ND
Report indicates those involved: suspect, victim, Police Officers and MO of crime
3 The relevant material is: Custody Record for QUINN, CR7988639024. Details reason, time and Police PACE
place of arrest. Contains personal information about QUINN. Custody risk assessment and
detention log with updates in regard to period in Custody
4 The relevant material is interview plan and interview notes of DC RAYMOND. Lists questions put Police PACE
to QUINN in interview and records his responses
5 The relevant material is: BWV PC FOSTER 650CM. Footage from arrival of Officer at scene with Nice Investigate ND
PC GILBERTSON. Footage shows PC GILBERTSON talking to the suspect. Officer conducts
checks for the suspect, cautions and arrests.
6 The relevant material is: BWV PC GILBERTSON 700CM. Footage from moment the officer arrives Nice Investigate ND
at the scene with PC GILBERTSON. Shows the Officers talking to the suspect, caution and arrest.
7 The relevant material is: Occurrence Enquiry Log. Records attending Officers’ reports, lines of Police ND
enquiry, outstanding actions & case progression, incl. interview summary and contact with victim.

Reviewing Lawyer’s Signature

Print Name J.G.ACHARYA
Signature Date: Date 21 December 2023

OFFICIAL (when complete) MG6

C

730266559.docx 17
©The University of Law
 Supervisor’s Endorsement
I have discussed the file with the OIC and am satisfied that:

1. The descriptions of relevant unused material on the MG6C are sufficient to allow an assessment to be made.

2. There is no material listed on the MG6C that is to be used in evidence.

3. The descriptions of relevant unused material on the MG6E sufficiently describe how, and why the material may undermine the prosecution case, or may
assist the defence case.

4. I understand the relevancy test and have discussed this with the OIC. I am satisfied that they understand it.

5. The OIC is aware of their obligations with regards to Reasonable Lines of Enquiry and relevant unused material in their role as disclosure officer for this
case.

Signature: Date:

730266559.docx 18
©The University of Law
 Form MG15(T)
Manchester City Police - Record of Interview
__________________________________________________________
Person Interviewed ..Jonathan Quinn.............................. Police Exhibit
No.....MG/4
Place of Interview .......Manchester City Police Station.... Number of Pages......4..
.............................................................................. Signature of interviewing
Date of Interview ...........5th December 2023 ............. officer producing exhibit
M.Gilbertson...............

Time Commenced ....10.09 hours....Time concluded ....10.20 hours........................

Duration of Interview .......11 minutes......... Disc Ref Nos ...BB/P12/267/Quinn/23..
Interviewing Officer(s) ...DC 321 Raymond PC 700 Gilbertson...........................
Other persons present ..Legal Representative, Julia Melnick, Trevor Phillips & Co
Solicitors
DISC PERSON TEXT
COUNTER SPEAKING
TIMES
Persons present in the interview introduced themselves, the
recording procedure was explained and the caution was given.
Legal Rep Mr Quinn will be making a no comment interview on the basis of
legal advice.
Quinn was reminded of the reason for his arrest, namely
robbery on the morning of 5th December 2023.
PC OK then. I hear what your legal adviser says about you not
wishing to answer questions, but I hope you’ll answer a few
basic questions for me, just for the benefit of the recording. So,
you are 20 years old, is that right?
QUINN Yeh
PC And you live at number 16 Blackmore Drive? Right?
QUINN Yeh
PC And you told us that you work at the Royal Kensington on Peter
Street as a night cleaner, is that right?
QUINN Yeh

730266559.docx 19
©The University of Law
 DISC PERSON TEXT
COUNTER SPEAKING
TIMES
When I asked you where you were coming from you said, “From
work. I’ve just got out five minutes ago, so I wouldn’t have had
time to commit no robbery would I?”. Do you remember saying
that?
QUINN Um … yeh
Legal Rep Mr Quinn, as discussed, I advise you to say no comment to all
questions. Please say if you would like the interview stopped
so that we can have another private consultation.
QUINN No, you’re all right. I’m gonna do no comment now.
PC OK. Let’s begin by talking about the robbery shall we? When I
arrested you on suspicion of robbery earlier this morning I
cautioned you to which you replied, “I don’t believe this, I
haven’t done no robbery. I never did it. I would never nick
stuff.”
Do you confirm or deny making this statement?
QUINN No comment.
PC OK. Can you just tell me then, in your own words, what
happened this morning?
QUINN No comment.
PC Mr Quinn, I have to remind you that you are being
questioned under caution for the offence of robbery.
Although you have the right to remain silent, a court may
draw an inference from your failure to answer questions. A
record is being made of this interview and may be given in
evidence. Do you understand?
QUINN Yeh
3m50s DC Right. Can you tell me what you were doing and where you had
been when we stopped you?
QUINN No comment.
DC What were you doing in Victoria Avenue?
QUINN No comment.

730266559.docx 20
©The University of Law
 DISC PERSON TEXT
COUNTER SPEAKING
TIMES
DC When we stopped you, you were running, why was that?
QUINN No comment.
DC You were running from Northumberland Avenue where a
robbery had just taken place, did you know that?
QUINN No comment.
DC You do not have to say anything but I must tell you that a
court may draw an inference from your failure to give a
reason for your presence close to the scene of the robbery
at this time in the morning. A proper record is being made
of this interview and it may be given in evidence if you are
brought to trial. OK?
QUINN No comment.
PC When I searched you, you were in possession of two Natwest
cards and a mobile phone, do you agree?
QUINN No comment.
PC The Natwest cards had the name, “H Taylor” written on them.
Where did you get those?
QUINN No comment.
PC “H Taylor” is the name of the person who was robbed this
morning and very soon afterwards, probably a matter of
minutes, you are found with two credit cards and a mobile
phone taken during the robbery. What do you say to that?
QUINN No comment.

DC You do not have to say anything but you are entitled to

know that a court may draw an inference from your failure
to give an explanation for being in possession of these
items. I am investigating an offence of robbery and those
items may have been in your possession because you
committed the robbery. A proper record is being made of
this interview and it may be given in evidence if you are
brought to trial. Do you have anything to say at all?

730266559.docx 21
©The University of Law
 DISC PERSON TEXT
COUNTER SPEAKING
TIMES
QUINN No comment.
DC Can you give a description of yourself and what you are
wearing for the recording?
QUINN No comment.
DC Well I shall then. Mr Quinn is wearing a blue denim jacket and
blue jeans. He is mixed heritage, 20 years old, approximately 6’
tall. He has red-brown coloured hair, quite short. He is thin to
medium build. Now let me read you the statement of the victim.
(READS out statement). This is the description of her attacker.
It is identical almost to you isn’t it?
QUINN No comment.
DC Mr Quinn, I am investigating an offence of robbery and I am
asking you to account for the fact that you were arrested
very close to where it took place shortly afterwards. This
fact may be due to you taking part in the commission of
this offence. You have a right to remain silent, but a court
may draw an inference if you fail or refuse to account for
this. I remind you that a proper record is being made of
this interview and it may be given in evidence if you are
brought to trial. Do you have anything to say?
QUINN No comment.

DC Oh come on! Give it up! What are the chances of some other
little scrote, looking exactly like you, and dressed exactly like
you, robbing our victim a few minutes’ walk away from where
you were? I know you did it, my colleague here knows you did
it, and you know-
Legal Rep With all due respect, your views and commentary are irrelevant.

Mr Quinn continues to give no comment replies to all questions

asked of him.

INTERVIEW TERMINATED AT 10.20 HOURS

730266559.docx 22
©The University of Law
05/12/23 09:59

DATA PROTECTION LEGISLATION

THESE PERSONAL DATA ARE PROVIDED TO YOU FOR THE AGREED
SPECIFIED PURPOSE(S).
KEEP THE DATA SECURE AND PROTECT THEM AGAINST LOSS OR
UNAUTHORISED ACCESS.

**************************************************************

DEFENCE PRINT

**************************************************************

PRINT OF PNC RECORD – PNCID: 22/490839Z

PRINT FOR: 700CM

TOTAL NUMBER OF PAGES ATTACHED 3

PLEASE NOTE THAT IN THE ABSENCE OF FINGERPRINTS, IDENTITY CANNOT

BE POSITIVELY CONFIRMED WITH THE SUBJECT OF YOUR ENQUIRY AND
YOU SHOULD CONFIRM THE INFORMATION WITH THIS PERSON

YOUR ATTENTION IS DRAWN TO THE PROVISIONS OF

THE REHABILITATION OF OFFENDERS ACT 1974

730266559.docx 23
©The University of Law
05/12/23 09:59
PAGE 1 OF 3
YOUR ATTENTION IS DRAWN TO THE PROVISIONS OF
THE REHABILITATION OF OFFENDERS ACT 1974

DATA PROTECTION LEGISLATION

THESE PERSONAL DATA ARE PROVIDED TO YOU FOR THE AGREED
SPECIFIED PURPOSES.
KEEP THE DATA SECURE AND PROTECT THEM AGAINST LOSS OR
UNAUTHORISED ACCESS.
-------------------------------------------------
SURNAME: QUINN
FORENAME(S): JONATHAN
BORN: 18 JUNE 2003, PRESTON
ADDRESS: 16 BLACKMORE DRIVE, MANCHESTER

CRO NUMBER: 22/76365 PNCID: 22/490839Z

ALIAS NAMES: NONE KNOWN
--------------------------------------------------------------
SUMMARY OF CONVICTIONS AND REPRIMANDS/WARNINGS/CAUTIONS
---------------------------------------------------------------
CONVICTION(S): 2 OFFENCE(S): 2
DATE FIRST CONVICTED: 13/07/22 DATE LAST CONVICTED: 27/11/22

2 THEFT AND KINDRED OFFENCES (2022 – 2022)

--------------------------------------------------------------
NO REPRIMANDS/WARNINGS/CAUTIONS
--------------------------------------------------------------
END OF SUMMARY OF CONVICTIONS AND
REPRIMANDS/WARNINGS/CAUTIONS
NOTE:
DETAILS OF ANY NON-CONVICTION OR NOT GUILTY DISPOSALS HELD FOR
THIS SUBJECT ARE NOT SUMMARISED HERE. IF ANY SUCH DISPOSALS
EXIST, FULL DETAILS ARE LISTED IN THE FOLLOWING PAGES

730266559.docx 24
©The University of Law
05/12/23 09:59 PAGE 2 OF 3
NAME: QUINN, JONATHAN PNCID: 22/490839Z
-------------------------------------------------------------------------------------------------------------
CONVICTION(S)

1. 13/07/2022 ROCHDALE MAGISTRATES’ COURT

1. THEFT ON 25/06/22 FINE 50.00

THEFT ACT 1968 s.1 (PLEA: GUILTY)

------------------------------------------------------------------------------------------------------------

2. 27/11/2022 MANCHESTER CROWN COURT

1. BURGLARY ON 10/09/22 12 MONTHS IMP.

THEFT ACT 1968 s.9(1)(b) (PLEA: NOT GUILTY)

-----------------------------------------------------------------------------------------------------------------

END OF CONVICTION REPORTS

730266559.docx 25
©The University of Law
05/12/23 11:15 PAGE 3 OF 3
NAME: QUINN, JONATHAN PNCID: 22/490839Z

--------------------------------------------------------------
LAST PERIOD IN CUSTODY
--------------------------------------------------------------

RELEASED 27/05/2023
--------------------------------------------------------------

END OF CUSTODY DETAILS

730266559.docx 26
©The University of Law
 PROOF OF EVIDENCE

Name: Jonathan Quinn

Date of birth: 18.6.2003 (aged 20)
Address: 16 Blackmore Drive, Manchester
Occupation: Unemployed

Background
I was born in Preston but moved to Manchester when my parents split up. My father
left my mother when I was 14 and from that time onwards I lived in Manchester with
my mother. I left school aged 16 with no GCSE passes. I have been unemployed
since then. Around that time, I got into the wrong crowd of friends and started taking
drugs now and again. This started with cannabis, spice, and legal highs at first but
then I moved on to ecstasy and amphetamines. When I was 17, I then started to
take smack (heroin).

The Robbery Offence

I am charged with one count of robbery that on the 5 th December 2023, I robbed
Helen Taylor contrary to section 8 of the Theft Act 1968. I deny any involvement in
this offence and intend to plead not guilty.

The night before my arrest I had been to a party at my friend Jordan Wright’s house.
I had left Jordan’s house at approximately 6.30am the following morning and started
to walk to my house. On my way home, I walked through Mount’s Place. This road
leads to Victoria Avenue and then onto Blackmore Drive where I live. Whilst walking
along Mount’s Place, I noticed a black object on the ground under the bushes. I bent
down and pulled out a black leather handbag. I looked inside and found a Samsung
mobile telephone, and two Natwest cards. I searched thoroughly through the bag but
there was nothing else in there. I put the items in my jacket pockets. My first thought
was that I would go home first and give it to the police later. However, on reflection, I
decided to make my way to Manchester City Police Station which was only 10
minutes out of my way (see attached map of the area).

730266559.docx 27
©The University of Law
I continued walking into Victoria Avenue. I was not running. Whilst walking along
Victoria Avenue, I suddenly noticed a police car pull up beside me. I was curious
because I knew I hadn’t done anything wrong. I was approached by the police who
asked to search me. I was fully co-operative. When they searched me, they found the
two bank cards and the Samsung phone. I told the police that I had just found them,
but they didn’t believe me and arrested me on suspicion of robbery. I was really
shocked by this and denied the offence. When I was stopped I told the police officer
two things that weren’t true. I said I worked at the hospital as I didn’t want them to
think I was ‘a scum bag’, I thought they’d just leave me alone if I said that as I hadn’t
done anything. I also said that I wouldn’t nick stuff when I was arrested which isn’t
true as I have in the past, but I wouldn’t now, that’s what I meant when I said that.

I have two previous convictions, as follows:

1. Theft
I was charged with theft of a wallet containing credit cards and £30. It was alleged
that I was standing at a bus queue and pick-pocketed a member of the public who
was waiting for a bus. My solicitor showed me the CCTV evidence which was pretty
clear so I pleaded guilty. I took the wallet because I had no money and my Universal
Credit was due the next day. I was fined £50 for this offence which I paid in full.

2. Burglary
This relates to the burglary of a house in 21 Halecroft Avenue, Manchester. I went
out for a drink with some mates and I owed £70 to one of them. I felt desperate so I
decided to find a house where I could get something to sell. When I entered, the
burglar alarm went off and the police arrested me near the scene. I pleaded not guilty
to this and gave evidence at trial, but I was subsequently found guilty at Manchester
Crown Court and received a custodial sentence of 12 months. I am deeply ashamed
of this. I committed it because I was desperate to get money to fund my heroin habit.

730266559.docx 28
©The University of Law
Comments on Prosecution Statements

Statement of Helen Taylor

I have no comment to make on this statement other than to say that the person she
describes who robbed her is not me. Lots of people wear denim jackets and jeans,
especially people my age.

Statement of PC Gilbertson
I accept the content of this statement save for the fact that I did NOT say “Fuck, I am
going down for this” when I was being taken to the police station.

21 December 2023

730266559.docx 29
©The University of Law
 IN THE CROWN COURT AT
MANCHESTER

REX
V
JONATHAN QUINN
----------------------------------
BRIEF TO COUNSEL
FOR THE DEFENDANT
----------------------------------
COUNSEL: A. Counsel
REPRESENTATION ORDER

Solicitors: TREVOR PHILLIPS & Co

7th Floor
South Central
22 Peter Street
Manchester M2 5PT

Ref: SO/24
Tel: 0161 833 4557

730266559.docx 30
©The University of Law
IN THE CROWN COURT AT MANCHESTER Case No: T:2023/0087

BETWEEN

REX
V
JONATHAN QUINN

BRIEF TO COUNSEL

As Counsel is aware, Mr Quinn is charged with one count of robbery. At his first
hearing at Manchester City Magistrates’ Court on 7th December 2023, his case
was sent to Manchester Crown Court under section 51 of the Crime and
Disorder Act 1998 and a Plea and Trial Preparation Hearing Date of 11th
January 2024 set. Bail was applied for and refused. A further bail application
was made before His Honour Judge Terry at Manchester Crown Court on 14 th
December 2023 and was similarly refused.
Evidence and initial prosecution disclosure were served on 21 st December 2023,
and Mr Quinn was subsequently seen in conference by Counsel on 23 rd
December 2023. Following on from that conference, and as a result of
concerns raised by Counsel over Mr Quinn’s mental health, those instructing
have obtained an expert report addressing this issue.
Counsel will find herewith the following documentation:
1. Police station attendance notes
2. Expert report prepared by Professor Isabel Buckingham dated 7th January
2024
3. A notice of additional evidence served on 7th January 2024
Acting in accordance with Counsel’s advice, no defence statement has as yet
been served, pending the outcome of the expert report.
Counsel is kindly instructed to attend Manchester Crown Court to represent Mr
Quinn at his Plea and Trial Preparation hearing on 11 thJanuary 2024 and at trial
thereafter.
Cecilia Abong
Trevor Phillips & Co.
7th January 2024

730266559.docx 31
©The University of Law
IN THE CROWN COURT AT MANCHESTER Case No: T:2023/0087

BETWEEN

REX
V
JONATHAN QUINN
_______________________________________
NOTICE OF ADDITIONAL EVIDENCE
TENDERED SECTION 9 OF THE
CRIMINAL JUSTICE ACT 1967
_______________________________________

Name of witness Lorraine Keeble

Date of witness statement 4 January 2024
Details of documentary Computer printout of staff records for period
exhibits produced under the December 2023
statement
Date of service upon 7th January 2024
defence
Signature and contact Sarah Knight
details CPS,
of CPS case worker Greater Manchester,
PO Box 237,
Manchester M60 3PS
0161 768 3445

730266559.docx 32
©The University of Law
 Form MG 11
WITNESS STATEMENT
(Criminal Procedure Rules, r.16.2; Criminal Justice Act 1967, s.9)

Statement of Lorraine Keeble 06 AT 40451 23 URN

Age if under 18 Over 18 (if over 18 insert ‘over 18’) Occupation Housekeeping Manager
This statement (consisting of 2 pages each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall be
liable to prosecution if I have wilfully stated in it anything which I know to be false or do
not believe to be true.
Dated 4h January 2024 Signature L. Keeble
Tick if witness evidence is visually recorded □ (supply witness details on
rear)

I work at the Kensington Royal Hotel, a four star hotel on Peter Street in
Manchester, as Housekeeping Manager and have done so in this capacity
since June 2015. The Housekeeping Department includes Room Maids,
House Maids, House Porters, Cloakroom Attendants and Cleaners. My
duties include ensuring HR best practice in my department, interviewing
and monitoring new staff, managing shifts, and scheduling daily task
rotas. I have personal knowledge of each and every member of our
housekeeping staff. No one could be employed in this department without
my knowledge.

I also keep computerised records of all staff, both permanent and temporary,
who work in my department. These records include their full names,
addresses, disclosure of criminal history, and their eligibility to work in the
UK. Supporting documentary evidence is required. These records are kept
Signed L.Keeble Witnessed by S. Kelly
for employment law purposes and administrative purposes. They may be
referred to from time to time by other Hotel Administrative and Managerial

730266559.docx 33
©The University of Law
 staff. From my personal knowledge of my staff members I can confirm
that no person by the name of Jonathan QUINN works for this hotel as a
Cleaner. I have also been asked to check the Housekeeping Records from
December 2023 and can confirm that no person by the name of
Jonathan QUINN appears on these records. I attach the relevant print out
of the Housekeeping Records for night shift cleaning staff in December
2023 to this statement as my exhibit LK/1. I am responsible for compiling
and maintaining these records and can confirm that they are accurate and
up to date. The records are protected by a password and are accessible only
to me, to the Deputy Hotel Manager, Mr Philip Carsons, and to the Hotel
Manager, Ms Nicola Flaherty.

Signed L.Keeble Witnessed by S. Kelly

730266559.docx 34
©The University of Law
 CORN MERCHANT’S HALL, PETER STREET,
MANCHESTER M60 5PD TEL: 0161 835 4479
STAFF RECORDS - CLEANING STAFF – NIGHT SHIFT
All documentary evidence demonstrating eligibility to work in the UK must be seen
prior to each member of staff starting work (Immigration and Asylum Act 1996).
Where applicant has a criminal record, see and apply Staff Policy 3.9 before
employing.
Name Contact (incl. phone Crim Eligible Doc.
numbers) Record? to Ev
work? seen?
Mamadou N’Dour 42 Bridge Street, No Yes Yes
Lightbourne M22 4PT
07786 336589
Melissa Fisher 19a Royce Road, Hulme No Yes Yes
M15 4YU 0161 224345
Sarah Parker 46b Royce Road, Hulme No Yes Yes
M15 4YA 0161 223487
Olumide Adebowale 19, Mount Place, Ardwick Yes* Yes Yes
M18 3PP 07988 343897
Shanika Martins Flat B, Newstead Gardens, Yes* Yes Yes
Lightbourne M22 6YA
0161 798455 / 07886
345456
Thomas Ma 162 Princess Street, Moss No Yes Yes
Side M16 9TT
No tel
Gabriela Verdugo 11a, Fleming Drive, Hulme No Yes Yes
M15
07966 458211
Grace Okeke 3 Effingham Road, Moss No Yes Yes
Side M16 3RR

730266559.docx 35
©The University of Law
 Name Contact (incl. phone Crim Eligible Doc.
numbers) Record? to Ev
work? seen?
0161 544 786
Cecilia Gamboa 35 Cavendish Street, No Yes Yes
Harpurhey M9 7CV 0161
789478 / 07888 347967
Nadia Perez 149 Alexandra Place, No Yes Yes
Harpurhey M9 7DF 07992
378778
Yolanda Plazas de 14a, Mandela Buildings, No Yes Yes
Lozada Harpurhey M9 5FG 07335
477987
Martin Pratts 11 Cobbersbolt Lane, Yes* Yes Yes
Lightbourne M22 7YA
07235 789234

730266559.docx 36
©The University of Law
 Trevor Philips & Co Solicitors

Regulated by the Solicitors Regulation Authority

Criminal Law, Motoring Law, Conveyancing, Personal Injury Law
FREE Telephone: 0808 154 4898
ATTENDANCE NOTE
Name of Legal Rep. Julia Melnick
Police Station Manchester City
Date and Time of Call Out 5 Dec ’23, 8.02am
Time of Arrival 9.09am
Name of Client Jonathan Quinn
Disclosure Victim: Helen Taylor; Arresting officer: PC Gilbertson; Disclosure
Sheet received and signed. Copy pre-cons & print out of custody record seen.
CON:
- Jonathan is known to the firm. (History of Special Needs at school and some
learning disabilities).
- has seen F.M.E. who confirms fit to be interviewed.
Robbery – denies involvement. Given victim’s bag at a party. Found it on way back
from party?/ in a bush? Was not running. Was on way to police station (to hand in?).
Was on way home. On way to police station.
- Told police that had been working at a hotel because did not want them to think
he was ‘a scum bag’
- Def does not appear to be under influence of drink / drugs but is visibly
distressed. Appears to be having great difficulty in concentrating on what I am
saying (wants to talk about the football!) and keeps going off track. Almost
impossible to get a straight story out of him. Very confused.
- ADVICE GIVEN: No comment interview on basis that would not be able to give
clear and coherent account of events due to state of mind at present. Defendant
stated that wished to follow this advice.

Trevor Philips & Co. Solicitors are regulated by the Solicitors Regulation Authority.
Trevor Philips & Co. Solicitors is the Trading Name of Trevor Philips Solicitors
Limited Company Number: 61689997
Registered Office at 22 Peter St, Manchester.
WITNESS STATEMENT OF PROFESSOR ISABEL BUCKINGHAM
730266559.docx 37
©The University of Law
This statement (consisting of 7 pages each signed by me) is true to the best of my
knowledge and belief and I make it knowing that, if it is tendered in evidence, I shall
be liable to prosecution if I have wilfully stated in it anything which I know to be false
or do not believe to be true.

Dated 7th January 2024 Signature

__________________________________________________________________

1. I am a Professor of Forensic Psychology and a Chartered Psychologist at the

Institute of Psychiatry, Psychology and Neuroscience at Manchester
University. I have held this role since April 2012. I am a fellow of the British
Psychological Society (FBPsS) and a Doctor of Philosophy (PhD).

2. My areas of expertise are: clinical psychology, fitness to plead, reliability of

confessions, and ‘suggestibility’ in police interviews. I am the author of the
standard text, ‘Forensic Psychology, A Guide to Good Practice’ (2015) Oxford
University Press, am a Chartered Psychologist and have acted as an expert
witness in a number of high-profile cases. In June 2017 I received from the
European Association of Psychology and Law an ‘Award for Life-time
Contribution to Psychology and Law’. In May 2016 I received a
Commendation from the West Yorkshire Police for ‘Innovation and
professionalism whilst assisting a complex murder investigation’. Please see
my attached curriculum vitae1 for full details of qualifications, expert evidence
experience and papers published.2

3. I have been asked by Trevor Phillips & Co. Solicitors to see Jonathan Quinn,
with a view to assessing his:
(a) fitness to plead
(b) ability to manage questioning under caution at the police station; and
1
Note to students, this CV has not been included in your papers
2
NB Instructing solicitors can provide a statement that checks have been made on the use and history
of expert testimony of this expert witness. That statement would confirm that Professor Isabel
Buckingham is being paid the same fee irrespective of the outcome of the case, that there are no
cases where the evidence of this expert witness has been criticised by the judge or an appeal has
been allowed on the basis of the testimony or professional standards of this witness.

730266559.docx 38
©The University of Law
 (c) ability to give a coherent account when giving evidence at trial.
I conducted this assessment on 4th January 2024.

Background

4. Mr Quinn has been charged with one offence of robbery on 5 th December

2023. He was interviewed by police on the same date and gave what
effectively amounted to a ‘no comment’ interview.

5. I have been provided with a copy of all relevant papers served on Trevor
Phillips & Co. to date, namely: witness statements of Helen Taylor dated 5th
and 6th December 2023; witness statements of Mike Gilbertson dated 5 th and
6th December 2023; transcript of recorded interview and a list of Mr Quinn’s
previous convictions, consisting of one theft in July 2022 and one burglary in
November 2022.

6. Mr Quinn is a young man of 20 years of age. He received a statement of

special educational needs when attending Maplehurst Primary School in
Preston, St Saviour’s Community School in Preston, and Kingley Road
Community School in Moss Side, Manchester. His attendance at school was
poor, resulting in severe disruption to his education. Mr Quinn left school at
the age of fifteen without obtaining any qualifications. I have had sight of eight
separate assessments of Mr Quinn carried out by the Preston and Manchester
City Council SEN Casework Departments whilst he was in school. Since
leaving school Mr Quinn has not been in employment.

7. Mr Quinn occasionally uses what he referred to as ‘party drugs’ on a casual

basis, namely methylenedioxymethamphetamine (MDMA), a synthetic,
psychoactive drug that produces feelings of increased energy, euphoria,
emotional warmth, and distortions in time, perception, and tactile experiences
and amphetamine, a central nervous system stimulant that increases energy
and decreases appetite. He estimates that he takes such drugs in what he
described as ‘small’ quantities (one to two tablets of ecstasy and/or approx. 2g
amphetamines) on average once to twice every few months.

730266559.docx 39
©The University of Law
8. I conducted a number of neuropsychological tests designed to measure
attention, impulsivity, IQ, memory and cognitive function on Mr Quinn during
my consultation with him. All tests used are endorsed and approved by the
International Society of Clinical Psychology and the Royal British
Psychological Society. I attach a summary detailing the methodology and
rationale for each of the tests I conducted on Mr Quinn, a breakdown of his
scores and performance, and my analysis of such to this witness statement3.

Summary of Findings
9. My conclusions are as follows:
a. Mr Quinn suffers from Attention Deficit Hyperactivity Disorder (ADHD)
b. Mr Quinn's current residual symptoms of attention and impulsivity fall
within a level of significant impairment on neuropsychological
measures.
c. Mr Quinn does not have, and never has had, a general learning
disability or 'mental handicap'. However, he has mental impairment in
terms of both verbal and performance intellectual abilities
d. Fitness to Give Evidence: Subject to certain safeguards being put in
place, Mr Quinn is fit to give evidence.
e. Fitness to Plead: In my opinion, Mr Quinn is fit to plead.
f. Ability to Cope with Police Interview: Without appropriate safeguards in
place, it is my opinion that Mr Quinn would have found it hard to answer
questions and express himself clearly in police interview.

Attention Deficit Hyperactivity Disorder

10. ADHD is a neurodevelopmental disorder. Because of their cognitive deficits,

individuals are predisposed towards poor impulse control, an attention deficit
and a desire for immediate gratification without consideration for the
consequences. There is a significant risk for anti-social outcomes, including
criminal behaviour, disinhibited and aggressive behaviour. In addition to these
behavioural problems, they suffer a range of neurocognitive impairments,
including attentional, executive (i.e. poor planning, sequencing and
organisational ability) and memory dysfunction. Although these deficits appear
3
Note to students, this summary has not been included in your papers
730266559.docx 40
©The University of Law
 widespread, it is thought that their neuropsychological basis involves
dysfunction in working memory, the self-regulation of cognition and future
directed behaviour. (See further: Attention Deficit/Hyperactivity Disorder in
Adult Male Offenders: Prevalence, Psychiatric Cormobidity and Psychosocial
Implications, Vol 2, pp. 79-108, Reuter, Michel; Pabler, Khalid, 2014,
Routledge)

Fitness to Plead

11. Mr Quinn obtained a score of 64 on the Wender-Utah Rating Scale which

means he self-rated himself to have a childhood history consistent with ADHD.
This finding is strongly supported by the contemporaneous childhood
documentation completed by multi-disciplinary professionals between the
ages of 8 to 16 years. These documents consistently record Mr Quinn having
problems with attentional control and poor behavioural controls (impulsivity)
from a very young age.

12. Objective testing indicated he continues to have severe deficits of attention

(95th percentile on the Letter Cancellations Test) and impulse control (98th
percentile on the Matching Familiar Figures Test and 99th percentile for errors
of commission on the Continuous Performance Test).

13. He has an IQ of 80, suggesting that he is functioning in the ‘low average’

range of intellectual ability. Although he apparently had difficulty in
communicating with his solicitor at the time of arrest, he was able to give a
coherent account of his version of events to me during our consultation.
Based on this, I have come to the conclusion that he understands the charges
that he faces and is able to give instructions to his legal representatives. It is
therefore my opinion that he is fit to plead.

Fitness to Give Evidence

730266559.docx 41
©The University of Law
14. Mr Quinn scored low on all the suggestibility tests I conducted indicating that
he is resistant to leading questions and interrogative pressure and is not likely
to accept suggestions ‘on trust’.

15. Despite this, the implication of having ADHD and significant cognitive
impairments of this type means that Mr Quinn will have difficulty sustaining
attention over a prolonged period. He is likely to become easily distracted and
his mind may wander onto different and/or irrelevant topics. His verbal deficits
mean that he will be disadvantaged in terms of his understanding of what is
being said (i.e. not understanding the meaning of some of the words used). I
noticed that Mr Quinn does not always admit to not understanding a word, but
will attempt to answer a question regardless. This tendency is likely to be
more marked when giving evidence in an intimidating formal environment.

16. Aside from concentration problems, there is a risk that Mr Quinn may be
inconsistent and give conflicting evidence. He may become distressed or
angry when giving evidence and is likely to have difficulty in inhibiting a
verbally aggressive response. These vulnerabilities are likely to be
misinterpreted by a jury.

RECOMMENDATIONS
17. I recommend that Mr Quinn receives regular ten minute breaks (say every
hour) during his trial in order to help him attend to and follow the court
process. I advise counsel to avoid lengthy questions and complex sentence
structures and suggest that questions are expressed in relatively simple
language and broken down into small stages. I suggest that important
information is put across directly and simply, avoiding long-winded
complicated explanations. Provided these precautions are taken, Mr Quinn is
fit to stand trial and to give evidence.

Ability to cope with questions in police interview

18. Although I have not been provided with a copy of the interview recording, the
same considerations set out at paragraphs 15 and 16 above apply to the
interview process. Mr Quinn was, he tells me, distressed and anxious at the

730266559.docx 42
©The University of Law
 time of the interview and this would have further hampered his ability to
answer questions clearly and coherently.

Further Information

19. All records of the assessments carried out are available for inspection upon
request.

20. In compiling this witness statement, I can confirm that I have complied with my
duty to provide the court with independent assistance by way of objective
unbiased opinion on matters within my expertise. If my opinion changes, all
relevant parties and, if appropriate, the court, will be informed.

Statement of compliance / conflicts of interest

I (Professor Isabel Buckingham) DECLARE THAT:
1. I understand that my duty is to help the court to achieve the overriding
objective by giving independent assistance by way of objective, unbiased
opinion on matters within my expertise, both in preparing reports and giving
oral evidence. I understand that this duty overrides any obligation to the party
by whom I am engaged or the person who has paid or is liable to pay me. I
confirm that I have complied with and will continue to comply with that duty.

2. I confirm that I have not entered into any arrangement where the amount or
payment of my fees is in any way dependent on the outcome of the case.

3. I know of no conflict of interest of any kind, other than any which I have
disclosed in my report.

4. I do not consider that any interest which I have disclosed affects my suitability
as an expert witness on any issues on which I have given evidence.

5. I will advise the party by whom I am instructed if, between the date of my
report and the trial, there is any change in circumstances which affect my
answers to points 3 and 4 above.4

4
Not all of the declaration is reproduced here, but you should assume that it complies with the
requirements of the CrimPR and with the sample declarations on The Academy of Experts website.
730266559.docx 43
©The University of Law
…

12. I have read part 19 of the Criminal Procedure Rules and complied with its
requirements.

13. I confirm that I have acted in accordance with the code of practice and

conduct for experts of my discipline, namely the BPS Code of Ethics and
Conduct and BPS guidelines and procedures for psychologists acting as
expert witnesses as well as the HCPC Standards of Conduct, Performance
and Ethics for Practitioner Psychologists.

STATEMENT OF TRUTH
I confirm that the contents of this report are true to the best of my knowledge and
belief and that I make this report knowing that, if it is tendered in evidence, I would be
liable to prosecution if I have wilfully stated anything which I know to be false or that I
do not believe to be true.

Signed
Date 7th January 2024

730266559.docx 44
©The University of Law
 (MAP OF AREA)

TO POLICE STATION,
ROYAL KEN. HOTEL
& CITY CENTRE

PICTON AVENUE MOUNT’S PLACE

NORTHUMBERLAND NETHERLAND CLOSE

AVE
AVE.
VICT-ORIA

BLACKMORE DRIVE

WESTLAKE DRIVE

LANCASHIRE ROAD

730266559.docx 45
©The University of Law