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Full hearings

Hearing: 25th June 2008, day 41

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ROSEMARY NELSON

PUBLIC INQUIRY

 

 

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held at:
The Interpoint Centre
20-24 York Street
Belfast BT15 1AQ


on Wednesday, 25th June 2008
commencing at 10.15 am


Day 41

 

 

 

 

 

 

 


 

1 Wednesday, 25th June 2008

2 (10.15 am)

3 Housekeeping

4 MR PHILLIPS: Sir, before Ms Farrell gives her evidence, can

5 I just deal with some questions of housekeeping.

6 First of all in relation to the dates for the next

7 session, the full hearings, they have now been provided

8 to the Full Participants and they have been put on the

9 website. The hearings start once more on 1st September.

10 We have also distributed lists of those witnesses

11 who we expect to be called in the first weeks of that

12 session, some nearly 50 names, with dates for questions

13 and lines of questioning to be submitted to the Inquiry

14 during July and August, so that the witness preparation

15 can continue during the summer months in order to make

16 a good start at the beginning of September.

17 So far as further documents we have handed out, we

18 have this morning distributed amended lists of various

19 types of witness, the Lawyers Alliance witnesses and the

20 NGO categories, and we have also handed out a new list,

21 a short one, I think, in relation to Canadian observers.

22 Sir, the final thing I wanted to do, because I won't

23 be here tomorrow, is to give you an update on the

24 information I gave before our last break, and it is

25 this: as far as we can calculate it, by the end of this

 

 

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1 week's evidence, you will have heard from 48 witnesses,

2 and a further 83 will have had their statements taken

3 into account, giving a total of 131 witnesses whose

4 evidence has been considered during this first session.

5 THE CHAIRMAN: Thank you.

6 MR DONALDSON: Sir, before the witness starts, may I make

7 one observation about the lists.

8 I just happened to see the list of witnesses for

9 next term. There are in fact -- and I think the initial

10 list, I think, is a total of 26 witnesses, and we are

11 now required -- the protocol seems to have been changed

12 considerably. Prior to this, we were required to give

13 48 hours' notice of lists of questioning. Now we are

14 asked in a very short time to prepare really 26 lists

15 before 15th July, I think it is.

16 That is quite impossible. In view of the fact that

17 people make arrangements for holidays, sir -- and it

18 just simply isn't possible to do it within that time.

19 And I am just giving notice of that fact now, that, as

20 far as we are concerned, it will not be possible to

21 furnish the lists, bearing in mind that some of those

22 witnesses, their evidence comes to even 40 pages with

23 a vast number of exhibits and that requires a lot of

24 work and consideration. And in the time available, it

25 isn't possible and, therefore -- and we haven't been

 

 

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1 indicated that this protocol is to be changed.

2 THE CHAIRMAN: I myself have not -- nor have my two

3 colleagues -- seen these lists.

4 MR DONALDSON: I see.

5 THE CHAIRMAN: I suggest that you have further discussion

6 with Mr Phillips today and make any further submissions

7 at the conclusion of today's evidence, when I and my two

8 colleagues will have had an opportunity of looking at

9 these lists.

10 MR DONALDSON: Very well.

11 THE CHAIRMAN: Thank you very much.

12 May the witness take the oath, please?

13 MS SHARON FARRELL (sworn)

14 Questions by MR PHILLIPS

15 MR PHILLIPS: Can you give us your full names, please.

16 A. May name is Sharon Anne Farrell.

17 Q. Do you have a copy of the witness statement you have

18 made to the Inquiry in front of you?

19 A. I do.

20 Q. Can we have it on the screen, please? It is RNI-806-037

21 (displayed). Do we see your signature at RNI-806-042

22 (displayed)?

23 A. Yes.

24 Q. And the date of 21st May last year?

25 A. Yes.

 

 

4

 

1 Q. Thank you. Now, returning to the start of the

2 statement, you describe yourself as an attorney. Can

3 I ask you: how long have been qualified?

4 A. 14 years.

5 Q. Do you still practise?

6 A. Yes, I do.

7 Q. What is the field of your practice?

8 A. I have a private practice.

9 Q. Dealing with what sort of work?

10 A. Personal injury.

11 Q. And I think you are based in New Jersey?

12 A. I am.

13 Q. Now, looking at the substance of your statement, can

14 I ask you first: how did you come to hear of the Lawyers

15 Alliance for Justice in Ireland?

16 A. I was attending a seminar they had at Seton Hall Law

17 School in New Jersey.

18 Q. Can you remember when that was?

19 A. The mid 1990s.

20 Q. It looks from your statement as though Mr Lynch, who has

21 already given evidence to the Inquiry, asked you to

22 become involved in cases that he and the Lawyers

23 Alliance were monitoring in Northern Ireland?

24 A. That's true.

25 Q. What role did he wish you to undertake?

 

 

5

 

1 A. As an observer, to come and sit in on the trials.

2 Q. And when was it that you first visited Northern Ireland

3 as an observer?

4 A. I believe it was August of 1995.

5 Q. Right. So that was your first trip to Northern Ireland?

6 A. Yes.

7 Q. The first date you give us in your statement, in

8 paragraph 3, if you see at the bottom of the page, is

9 your first meeting with Rosemary Nelson, and you put

10 that in 1996?

11 A. Yes.

12 Q. So you think you made a previous visit to

13 Northern Ireland, the previous year, do you?

14 A. Yes.

15 Q. Thank you. So far as the reference you make in that

16 same paragraph, 3, to your journal is concerned, have

17 you managed to find your journal?

18 A. No, the journal I have not found. It has been ten years

19 and I had two moves during that time.

20 Q. So, so far as dates are concerned, we have your memory?

21 A. Yes.

22 Q. But we don't have any written record?

23 A. That's true.

24 Q. Thank you. Before we look at the visits you paid and

25 your meetings with Rosemary Nelson, can I just ask you

 

 

6

 

1 about the other organisation that you refer to in your

2 evidence?

3 Now, this is -- I'm not even sure quite how to

4 pronounce it. Is it Brehon?

5 A. Yes, it is.

6 Q. What was your role in that organisation?

7 A. The Brehon Law Society was a group of Irish American

8 lawyers, as founded in New York City under Paul O'Neill.

9 Q. And your role in it?

10 A. I was at one time a vice president.

11 Q. What were the aims of that organisation?

12 A. To assist as well as we could the happenings in the

13 North with the different cases that were presented

14 to us.

15 Q. Assist in what way?

16 A. Assist in observing, assist with the attorneys, with

17 meeting with them, to see what we could do to help them,

18 to publicise cases.

19 Q. What sort of things did you do apart from publicising

20 the cases?

21 A. We would sit in on the trial itself.

22 Q. And see what was going on?

23 A. Yes.

24 Q. Now, before you visited in August 1995, what was your

25 knowledge of Northern Ireland?

 

 

7

 

1 A. The knowledge of Northern Ireland I had was that there

2 was lots of conflict up here that has been going on for

3 a long time. We were aware of the hunger strikes,

4 different pieces of information that would come by way

5 of the Irish community back home.

6 Q. When you first met Rosemary Nelson -- you deal with this

7 in paragraph 3 -- you tell us that at that stage you and

8 Jean Forest, who has also given a statement to the

9 Inquiry, were over in connection with the Colin Duffy

10 case?

11 A. Yes.

12 Q. Can I ask you first, which Colin Duffy case was this?

13 A. I believe that he was accused allegedly of murdering

14 a police officer.

15 Q. Right. At the stage you visited, was there an appeal in

16 progress, do you remember?

17 A. I can't quite remember, but I believe there was an

18 appeal.

19 Q. Right. We know, you see, that there was an appeal going

20 on at some point later in 1996, but that was in relation

21 to a conviction for the murder of a man called Lyness.

22 A. Lyness.

23 Q. Who was an UDR man.

24 A. Hm-mm.

25 Q. Is that the context in which you met Rosemary Nelson for

 

 

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1 the first time, do you think?

2 A. Yes.

3 Q. Thank you.

4 A. In Lurgan.

5 Q. Yes. And can I just ask you about the date.

6 Jean Forest has told us in her statement to the Inquiry

7 that she thinks her first meeting with Rosemary Nelson

8 was the following year, 1997. Now, are you confident in

9 your recollection of it being the previous year, 1996?

10 A. I'm not sure, but I do know that we met in the cafeteria

11 in Lurgan, and it had to be 1996 or 1997 because it

12 wasn't my first trip over.

13 Q. But it could have been 1997?

14 A. It could have been.

15 Q. Yes. At the time you met Rosemary Nelson, what did you

16 know about her practice, the work that she did?

17 A. I knew that she worked with just a couple of other

18 lawyers and that a lot of her work was involved with the

19 Irish Catholic community up here in the North.

20 Q. Is there anything else that you knew about her work?

21 A. No, not at that time.

22 Q. Was her practice, the work that she did, something that

23 you had discussed with other members of the Lawyers

24 Alliance, for example?

25 A. Yes.

 

 

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1 Q. And were some of them at least better informed about it

2 than you were?

3 A. I'm sorry?

4 Q. Were some of them better informed about her work than

5 you were?

6 A. Yes, I'm sure they were.

7 Q. And so when you first met her in the cafe, as you

8 describe it, what was the purpose of meeting her with

9 Jean Forest?

10 A. To discuss the Colin Duffy case and where it was, what

11 stage it was at.

12 Q. Were you at that stage offering her assistance with the

13 case?

14 A. Not at that stage.

15 Q. No. Did you come to offer assistance in relation to

16 that case?

17 A. No, I just came as an observer.

18 Q. So what did you observe on this visit?

19 A. There seemed to be a lot of tension, a lot of resistance

20 from the other sides; uneasiness on her part in the

21 defence of all these cases that she had taken on.

22 Q. And that was something that you observed, was it, at

23 your first meeting with her in 1996 or 1997?

24 A. Yes, and I was wondering why she would take on such work

25 as she did, being that she was a wife and mother.

 

 

10

 

1 Q. You tell us in your statement at paragraph 4 -- this is

2 at RNI-806-038 (displayed) -- that she told you she had

3 a very dangerous career?

4 A. Yes.

5 Q. Now, so I have understood this, was she telling you then

6 that her work was particularly dangerous?

7 A. I believe I asked her.

8 Q. And what was her response?

9 A. Yes, it was dangerous, it was risky.

10 Q. Why did you ask her that question?

11 A. Because I had stayed in the Ardoyne and this was my

12 first exposure to the North, and it was a very different

13 experience than what I have had in the States, of

14 course.

15 Q. Now, you also tell us that she told you that she felt

16 the RUC were following her around and keeping tabs on

17 her?

18 A. In which -- where are you referring to?

19 Q. I am still in paragraph 4. Do you see in the third

20 sentence beginning, "she commented ..."?

21 A. Yes.

22 Q. Can I just ask you first of all, did she give you any

23 examples of being followed around?

24 A. Examples in what way? Showing us a car that was

25 following us, do you mean, sir?

 

 

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1 Q. Did she explain an occasion or occasions in which she

2 had in fact been followed?

3 A. Yes.

4 Q. Can you remember any details?

5 A. She would just say that the cars would be following her

6 and she would be able to identify them. I think she was

7 familiar with the officers' faces.

8 Q. Any further details?

9 A. You mean licence numbers? No.

10 Q. What about the keeping tabs on her? What did she mean

11 by that, as you understood it?

12 A. It seems that when she would appear places, there would

13 be members of the RUC that she would recognise and she

14 would be wondering why they were there.

15 Q. Again, did she give you specific examples?

16 A. She might have mentioned names, but I don't remember

17 them.

18 Q. Now, you tell us that she went on to tell you in general

19 terms that Mr Duffy and his family had been receiving

20 threats because of the accusation that he had killed

21 a police officer.

22 Again, can you remember any more particular details

23 about this and what she told you?

24 A. We were in the house of Colin Duffy and his wife --

25 Q. Yes.

 

 

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1 A. -- and I heard it from Colin Duffy himself.

2 Q. So, I see, this is something which was passed on to you

3 by Mr Duffy, was it?

4 A. As well as Ms Nelson.

5 Q. Right. Okay. And again, can I ask you: can you

6 remember any details of that?

7 A. As far as names, no, I cannot remember names. I can

8 remember them saying that they would not go out at

9 night. They were afraid to go out at night. The wife

10 was afraid to go out by herself.

11 Q. Yes. And was she, Rosemary Nelson, asking you for help

12 or asking your organisation for help or assistance in

13 any way?

14 A. As far as protection? No, we would not be able to

15 protect her.

16 Q. You also tell us that, as I understand it, on this first

17 meeting she told you that she, Rosemary Nelson, had been

18 receiving threats. And this is your paragraph 6, the

19 first line at the bottom of page RNI-806-038

20 (displayed).

21 Again, can I ask you: can you recall now --

22 obviously it is a very long time ago -- any more detail

23 about that?

24 A. At the time I had worked in the Public Defender's

25 Office, so I was on the criminal side, the defence

 

 

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1 criminal side as well as she was, and when she was

2 mentioning that she would receive threats from the RUC,

3 I understood it to be the Royal Ulster Constabulary,

4 which is a recognised force in the North. And I found

5 it quite appalling that they would be so bold as to

6 threaten her outright.

7 Q. But did she give you an example of such a threat?

8 A. Phone calls that she had received, letters.

9 Q. You mention letters on the next page, at the, top of

10 RNI-806-039 (displayed). What can you remember about

11 the information that she gave you about the letters?

12 A. Well, the letters were just stop what you are doing, to

13 that effect. I don't know the exact words, but that was

14 the message.

15 Q. Did she tell you whether they were sent to her house or

16 to her workplace?

17 A. I believe she said her home.

18 Q. And as I understand it, you didn't see any of the

19 letters; is that right?

20 A. No.

21 Q. Did she tell you anything about their contents?

22 A. The contents were just offensive. They were just

23 threats. That is what she said.

24 Q. Can you remember the nature of the threats?

25 A. To her livelihood.

 

 

14

 

1 Q. To her livelihood, to her life?

2 A. To her life, yes.

3 Q. Did you get any impression from her of how many there

4 had been, whether they were regular or whether this was

5 something that had only happened once or twice?

6 A. It would be enough to make me stop.

7 Q. And what was her reaction to all of this, as far as you

8 could judge?

9 A. Courageous.

10 Q. Did she seem to be concerned about them?

11 A. Yes. Yes, she did.

12 Q. How did that manifest itself?

13 A. She mentioned them several times. She spoke about, you

14 know, her children and that she knew that her husband

15 was not fond of her work, that it put her in harm's way.

16 There were other people who would also bear consequences

17 if anything happened to her; namely, her children.

18 Q. So she told you, did she, that her husband was worried

19 about the effect of her work?

20 A. Yes.

21 Q. Now, you say in your statement, in the same paragraph 6,

22 at the top of page RNI-806-039 (displayed), that:

23 "When she spoke of the threat she was fairly matter

24 of fact."

25 A. Hm-mm.

 

 

15

 

1 Q. Is it fair to say that you regarded that as something of

2 a front?

3 A. Could you be more specific about "a front"?

4 Q. Did you think that that was her actual feeling, being

5 matter of fact about it?

6 A. Oh, yes.

7 Q. It was?

8 A. Yes.

9 Q. You see, you say in your statement that she was stressed

10 and concerned. How did that manifest itself in the

11 conversation?

12 A. Chain smoking.

13 Q. Did it seem to you that the threats were getting to her?

14 A. Yes, I did think they were getting to her, but she still

15 displayed a lot of guts and courage by going forward

16 with them, despite them.

17 Q. Earlier in this same paragraph, you mention a specific

18 incident where she tells you -- and this is the second

19 line of paragraph 6 -- that an RUC officer had hit her?

20 A. Yes, assaulted her.

21 Q. Now, you give limited details about that in the next

22 sentences and you say at one point:

23 "... I got the feeling that it was not in private,

24 but in an open place ..."

25 Can you remember anything more about the

 

 

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1 circumstances as they were explained to you?

2 A. Yes, I believe it was when she was involved with

3 Garvaghy Road.

4 Q. We know that that alleged assault happened in July 1997,

5 so does that help you with the dating of this first

6 meeting with Rosemary Nelson?

7 A. Well, it would have been in summer, because that is when

8 I would have my vacation time.

9 Q. If you think now that she was referring to that

10 incident, then your visit must have post-dated that

11 incident, mustn't it?

12 A. You mean after?

13 Q. Hm-mm.

14 A. Yes.

15 Q. So it follows, doesn't it, that it is more likely than

16 not that your first meeting with Rosemary Nelson was in

17 fact in 1997 and not 1996?

18 A. It may well have been.

19 Q. Thank you. Now, having heard all these details from

20 her, you tell us in an earlier paragraph of your

21 statement, paragraph 4, that, as you said earlier, you

22 effectively challenged her and said, as I understand it,

23 "Why do you carry on doing this sort of work if it puts

24 you in danger?"

25 What was her response to that challenge?

 

 

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1 A. She seemed unaffected by it. It seemed that she had

2 a cause that she believed in and that she was going to

3 help these -- and defend these people, and she seemed

4 very strong in her conviction of that.

5 Q. Do you think what she was telling you is that she had

6 a conviction about her work or about the causes of her

7 clients?

8 A. It would be both. I don't know how you would separate

9 one from the other.

10 Q. You make a very specific reference in this same

11 paragraph to Pat Finucane. The words you use there, you

12 say:

13 "I remember that Mrs Nelson also mentioned

14 Patrick Finucane and his fate and said she was following

15 in his desire to protect the Catholic community."

16 Are those, as far as you can recall, the words that

17 she used of herself?

18 A. Yes, because I asked her why would she do this, and she

19 said because there was an attorney, Patrick Finucane,

20 who was defending the Catholic community. I believe he

21 was murdered inside of his house with his children or

22 his son to witness it as well.

23 Q. So she was expressing to you, was she, that she regarded

24 her role as carrying on the work that he had done?

25 A. Yes.

 

 

18

 

1 Q. Is that a fair way of putting it?

2 A. A fair way.

3 Q. But it sounds from the last sentence of this paragraph

4 as though in a sense she regretted that there wasn't

5 anyone else -- specifically, you say, a man -- who could

6 have carried it on in her place?

7 A. I believe I asked -- I posed the question to her, asking

8 her why would she be doing this as she had young

9 children at the time.

10 Q. And that is when she gave you this answer?

11 A. Yes.

12 Q. Is that right? Yes.

13 Now, during the course of this conversation in the

14 cafe in Lurgan, was it clear to you exactly why she was

15 telling you all these things?

16 A. Because I was asking her.

17 Q. So she was responding to questions?

18 A. Yes.

19 Q. Is that right?

20 A. Yes.

21 Q. She wasn't simply making a series of statements to you

22 off her own bat?

23 A. It was kind of a mix. I would ask questions and then

24 she would add different statements as well.

25 Q. Did you discusses with her whether she had reported

 

 

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1 these things?

2 A. Yes.

3 Q. To the authorities?

4 A. Yes.

5 Q. What was her response?

6 A. It was kind of confusing. I think that she said she may

7 have reported them. I didn't see any copies of any

8 letters, though, to that effect.

9 Q. You see, you say in paragraph 6 in the penultimate

10 sentence, which is at the top of RNI-806-039

11 (displayed):

12 "She knew she needed help and I think she knew she

13 wasn't going to get it."

14 Now, can I ask you: what do you mean by that?

15 A. As I remember, Rosemary didn't feel that the community

16 would support her as far as the RUC was concerned.

17 Q. The community wouldn't support her?

18 A. I'm sorry, the RUC.

19 Q. I see. Is that something she said to you?

20 A. I believe she referred to it as the police force.

21 Q. Yes. But presumably that raised the question of whether

22 she could get help from any other source. Did you

23 discuss that with her?

24 A. Any other source, such as?

25 Q. Was any other source discussed? Source of help?

 

 

20

 

1 A. I think that is why we were there: to get support from

2 outside communities as well in the United States.

3 Q. So did you then discuss with her the ways in which you

4 and your organisation might help?

5 A. Yes.

6 Q. And what was discussed?

7 A. Writing to congressmen in the United States, bringing

8 her case, giving it more exposure -- not her case, but

9 anything that was happening, more exposure to the

10 public.

11 Q. So your role in giving help was to make a wider

12 audience, if I can put it that way --

13 A. Yes.

14 Q. -- aware of her situation?

15 A. Yes.

16 Q. And presumably that would be particularly in the

17 United States of America?

18 A. Yes.

19 Q. Yes. When she explained her view, which is that she

20 needed help and she didn't think she was going to get

21 it, did you question that with her, question her

22 attitude in relation to the police, for example?

23 A. No, I was just thinking of ways that we could possibly

24 drum up some exposure in the United States with the

25 congressmen that we had known over there.

 

 

21

 

1 Q. So your focus is on what you could do back in the

2 United States of America?

3 A. Yes.

4 Q. Yes. Now, in relation to the threat letters that we

5 talked about a little while ago, you have told us you

6 were in the public defender's office at this time. Did

7 you discuss with her the idea that the letters

8 themselves ought to be handed in to the police to be

9 analysed, to see if any clues as to their origin might

10 be obtained?

11 A. She may have submitted them. I can't recall.

12 Q. But you didn't make that suggestion to her?

13 A. I may have.

14 Q. Specifically?

15 A. I may have.

16 Q. And are you aware, as a result of your further

17 discussions and meetings with her, whether that was in

18 fact done?

19 A. I only know that I can recall is that we were sending

20 letters to now Senator Menendez over in the States.

21 Q. This is your organisation?

22 A. It isn't an organisation. We have access to our

23 congressmen and senators.

24 Q. So that is your local senator, is it?

25 A. Yes.

 

 

22

 

1 Q. So your reaction when you got back to the States was to

2 raise the matter with your elected representative

3 locally?

4 A. Yes.

5 Q. Did you raise that as a possibility for her: "Why don't

6 you write to your member of Parliament?"

7 A. I may have, I am sure that we did but I can't recall

8 specifically.

9 Q. Now, after these meetings and discussions that we have

10 talked of, did you stay in touch with Rosemary Nelson in

11 the succeeding years?

12 A. Yes, periodically.

13 Q. I think it is right to say -- please tell me if this is

14 correct -- that your next meeting with her wasn't

15 until March 1999. Is that correct?

16 A. I believe that would be correct.

17 Q. Yes. So in the intervening period -- let us say between

18 the summer of 1997 and March 1999 -- how often would you

19 speak to her?

20 A. Well, she came in to New Jersey, I believe, in the

21 summer of 1998.

22 Q. Yes. And on that occasion you tell us you went to

23 a dinner?

24 A. Yes.

25 Q. I think you didn't speak to her but you were both

 

 

23

 

1 attending the same dinner. Is that right?

2 A. Yes.

3 Q. We will come to that in a minute, but can I just ask

4 you: that is the dinner you have told us about in your

5 statement. You have also dealt with the later meeting

6 in March 1999, but in the period between, how regularly

7 were you in contact?

8 A. Perhaps every few months. Jean Forest was more in

9 contact with her than I.

10 Q. Would the contact be by phone, by email?

11 A. By phone.

12 Q. You haven't mentioned any of those conversations in your

13 statement, but what were the sort of topics you would

14 discuss?

15 A. Well, just how things were going over there, what was

16 the climate, how she was, her, her family, personal

17 matters as well as professional.

18 Q. Did you return to any of the topics you had discussed in

19 the cafe?

20 A. I don't think I would have done that over the phone.

21 Q. No.

22 A. No.

23 Q. So you didn't have any further conversations --

24 A. Not that I can recall.

25 Q. Okay. There is something I would like to look up before

 

 

24

 

1 we look at the dinner, at the time she gave evidence in

2 Congress. Can you look, please, at RNI-114-121.503? We

3 will put it up oh the screen (displayed).

4 A. I have it.

5 Q. This is a list of delegates for a Lawyers Alliance visit

6 in February 1998, and you will see on the left-hand side

7 your name appears?

8 A. Yes.

9 Q. Just above Jean Forest's, in fact?

10 A. Hm-mm.

11 Q. As far as we can tell from other material, you didn't in

12 fact come to Northern Ireland that year in the

13 delegation. Is that correct?

14 A. That's correct.

15 Q. So that was obviously a delegate list that didn't in

16 fact reflect the final composition of the delegation in

17 your case anyway?

18 A. Correct.

19 Q. Thank you. So the next time, from your statement at any

20 rate, you met Rosemary Nelson, as you say, is at the

21 time of the dinner, and this is paragraph 7 of your

22 statement at RNI-806-039 (displayed). And as I

23 understand it, you were one of a number of people

24 present who listened to Rosemary Nelson speak to the

25 dinner, but on that occasion she did not give any detail

 

 

25

 

1 of specific threats. Is that correct?

2 A. I believe there wasn't specific threats, but she still

3 was talking about the uncomfortableness and the

4 unsafeness that she felt.

5 Q. What can you remember of what she said?

6 A. I remember specifically that she said -- she was going

7 before Congress, or she'd gone before Congress about

8 different threats on her life.

9 Q. Can you remember anything else about it?

10 A. I think that was kind of after I heard about that she

11 had threats on her life. It just gave me to pause after

12 that.

13 Q. But you didn't speak to her yourself?

14 A. Yes, I did.

15 Q. Oh, you did?

16 A. I was seated with her at the table.

17 Q. I see. Right. You see, you say about six lines down:

18 "I did not speak with Rosemary Nelson personally on

19 this occasion."

20 A. About specific facts? Because I know I spoke with her

21 to say hello, how are you, how was your trip;

22 pleasantries, as such.

23 Q. So you did speak to her but you didn't speak to her

24 about the threats and the other sorts of points you

25 discussed in the cafe?

 

 

26

 

1 A. Yes, there was conversation that took place around the

2 table.

3 Q. Right.

4 A. It is in the statement.

5 Q. Thank you. Now, you say in the final sentence of this

6 paragraph that your sense was that she was:

7 "... serious and business orientated even at this

8 event."

9 A. Yes.

10 Q. Can I ask you to help us: what do you mean by that,

11 "serious and business orientated"?

12 A. She was preparing for the congressional meetings. She

13 spoke just a bit about her family, but she seemed more

14 interested in the task at hand, which was going before

15 Congress. Those sessions I didn't attend.

16 Q. No. Can we then finally deal with your meeting with her

17 in March 1999.

18 A. Yes.

19 Q. Some two weeks before her murder. You were over in

20 Ireland, as I understand it, with your cousin?

21 A. Yes, I was.

22 Q. And he was also a lawyer, I think?

23 A. Yes.

24 Q. Is that right?

25 A. Yes, he was, he was the deputy.

 

 

27

 

1 Q. And he expressed an interest, as I understand it, in

2 meeting Rosemary Nelson?

3 A. Yes.

4 Q. And you contacted her and she was very pleased to meet

5 you on your visit in March that year?

6 A. Yes.

7 Q. You say in paragraph 9, in the last sentence:

8 "I think she felt that she needed support and so she

9 was always keen to meet with people and talk to them and

10 tell them what was going on."

11 That assessment of her state of mind, is that based

12 on this recent, or most recent meeting with her

13 in March 1999?

14 A. No. From the very first I would perceive that Rosemary

15 would like to meet other attorneys. She was very

16 interested in finding out different things about the

17 United States and our defence system there.

18 Q. But in relation to the support that you refer to, how do

19 you think she felt she was getting support from

20 conversations of this kind?

21 A. Because she knew we would act.

22 Q. Is it because she was able to ask you to do things on

23 her behalf?

24 A. Yes.

25 Q. And that she regarded that as a form of support?

 

 

28

 

1 A. Yes.

2 Q. Yes. Now, earlier in the statement at the previous

3 paragraph, you tell us that you had been encouraged to

4 pay her a visit by one or other of the organisations you

5 have told us about, and you say:

6 "Everyone was certainly very concerned for her

7 safety at this time."

8 So this is March 1999.

9 A. Yes.

10 Q. How did you learn of that concern, presumably on the

11 part of other members of the two organisations?

12 A. I think in my statement I said I can't be sure, but

13 I know that we were always concerned about the attorneys

14 and the community over here.

15 Q. Yes. Was there anything in particular about this time,

16 in other words March 1999, which had led to concern?

17 A. I believe this was post the congressional meetings, was

18 it not?

19 Q. Yes, it was.

20 A. Okay, she had said that she was afraid for her life,

21 that there were threats upon her life.

22 Q. So you think that those concerns derived from the

23 evidence she gave to Congress?

24 A. Yes.

25 Q. Were there any other matters leading to concern at this

 

 

29

 

1 stage, that you can remember?

2 A. At the courthouse, when we were there in March? She

3 didn't want to leave the courthouse. She didn't want to

4 go into a public -- she wanted to stay in the

5 courthouse. She felt safer there.

6 Q. We will come to that in a minute. You see, in your

7 statement you mention this concern in the context of

8 your being encouraged to pay her a visit. So that is

9 before your meeting in the courthouse. But what I'm

10 trying to ask you is whether, in addition to the

11 testimony she gave in Congress, there was anything else

12 going on at that time which led to those concerns?

13 A. I think there was always an ongoing series of threats

14 against Rosemary Nelson.

15 Q. Can you remember anything specific?

16 A. In her words?

17 Q. Yes.

18 A. Yes, that they would want to kill her, that they said

19 they would kill her.

20 Q. Those are the words she used at the hearing, as you

21 remember them; is that right?

22 A. I know I heard it from her own self, and I believe

23 I heard it in the congressional meetings as well in the

24 video.

25 Q. Can I ask you when you heard it from her?

 

 

30

 

1 A. On more than one occasion. I believe in the initial

2 meeting.

3 Q. The meeting --

4 A. In the cafeteria.

5 Q. In summer 1997?

6 A. Yes.

7 Q. Now, in relation to the Lawyers Alliance, did you know

8 at the time you were arranging to pay your own visit

9 that the alliance had its own deputation going to

10 Northern Ireland in February 1999?

11 A. Yes.

12 Q. Yes. And were you aware that there was still going on

13 at this point a complaints investigation involving

14 a Lawyers Alliance complaint on Rosemary Nelson's

15 behalf?

16 A. Yes, I believe that Ed Lynch had mentioned that to me.

17 Q. Yes. In your evidence about this meeting in March 1999,

18 you describe meeting Rosemary Nelson at court. Can

19 I ask you, please, who was present apart from yourself

20 and Rosemary Nelson?

21 A. My cousin, John McKenna.

22 Q. Was anybody else present?

23 A. No.

24 Q. And what struck you about Rosemary Nelson's mood on this

25 occasion?

 

 

31

 

1 A. That she didn't want to leave the courthouse. She

2 didn't want to get in a car, she didn't want to go into

3 town to have lunch, that she preferred to stay in the

4 cafeteria. She felt safer there, she said.

5 Q. Compared to the earlier meeting in Lurgan in 1997, what

6 had happened to her mood?

7 A. I can't say. She just seemed more cautious, she didn't

8 want to leave the building because she wanted to be

9 surrounded by a lot of people. We had wanted to go into

10 town for lunch and she declined and said that she

11 preferred to sit in the cafeteria.

12 Q. You say in 10 that -- this is about five lines down:

13 "When she appeared, she was energetic and bubbly as

14 always and immediately started talking."

15 A. Hm-mm.

16 Q. When did it become clear to you that she was in fact, as

17 you put it later, much more frightened?

18 A. Well, initially when she saw us, of course, she was

19 excited and she met my cousin because he was the deputy

20 for the Public Defender's Office, and then she got right

21 into the defence systems in the United States, the

22 defence systems over here.

23 Q. But at some point, clearly, it struck you that she

24 was -- and again, I use the words you have used in your

25 statement -- "much more frightened"?

 

 

32

 

1 A. Yes.

2 Q. At what point in the conversation did that strike you?

3 A. When she didn't want to leave the courthouse.

4 Q. Was it clear to you what she was afraid of?

5 A. She was always afraid for her bodily harm.

6 Q. You see, when you talked earlier about the meeting you

7 had in the cafe in Lurgan, you described the way she

8 talked about threats as being matter of fact. Now, was

9 that the way she talked about these issues when you met

10 her in March 1999?

11 A. She seemed more serious, more sober in her demeanour and

12 more implicit on not leaving the courthouse.

13 Q. In paragraph 12, you tell us that she asked your cousin

14 how lawyers were protected in the United States. Can

15 you remember what prompted her to raise that issue in

16 the conversation?

17 A. No.

18 Q. No. And you then tell us that she returned to the topic

19 of threats?

20 A. Yes.

21 Q. But as I understand it, she did not give you any further

22 details in this conversation in March 1999; is that

23 correct?

24 A. No, I believe that she asked my cousin how the attorneys

25 were protected in the United States, and he said they

 

 

33

 

1 didn't really have to be protected; they weren't met

2 with any kind of threats.

3 Q. What did she say to you in the conversation about her

4 feelings about the threats?

5 A. She was very frightened.

6 Q. When you raised this issue with her on the earlier

7 occasion, challenged her, as we discussed earlier, she

8 told you that she felt she had to carry on. Did you

9 have a similar conversation on this occasion?

10 A. I think by this time I knew that she was set in her mind

11 that this was the work that she chose to do.

12 Q. So in that sense, her approach and her attitude was

13 unchanged; is that fair?

14 A. Maybe it was unchanged in my mind.

15 Q. Now, you say then in paragraph 13 that you noticed

16 a change in Rosemary Nelson from when you had first met

17 her, and you give some examples about the way she

18 carried on her work. In particular, you say that she

19 told you that she was "having to meet clients in

20 secret"?

21 A. Yes.

22 Q. Can you remember any more details about having to meet

23 clients in secret? Did she give you examples?

24 A. I believe she said that there was a case in the

25 Protestant community that she was now taking up.

 

 

34

 

1 Q. And that it was in that case -- is that right? -- that

2 she had had to meet clients in secret?

3 A. Yes, the one that she mentioned to me. There may have

4 been others, but this is what specifically she mentioned

5 to me.

6 Q. Did she explain why she had felt she had had to behave

7 in that way?

8 A. I think it was understood that -- by this time that her

9 life was threatened. She had mentioned many times, so I

10 did not have to question her.

11 Q. But it sounds as though what she was telling you was

12 that she felt the need to hide the fact that she was

13 acting in what you describe as a very unpopular case?

14 A. I don't know what you mean.

15 Q. Well, I am just trying to understand from the way she

16 explained this business of meeting clients in secret.

17 You see, you say later your statement:

18 "This was a very unpopular case."

19 Did you understand her to be telling you that

20 because it was a very unpopular case, she had felt the

21 need to meet her clients in secret?

22 A. Yes, I would think so.

23 Q. And that seems also to have concerned you because, as

24 you put it, if people didn't know where she was and

25 something happened to her, nobody would be able to reach

 

 

35

 

1 her?

2 A. Hm-mm, yes.

3 Q. And did you express that concern in this meeting?

4 A. Yes.

5 Q. And what was her reaction?

6 A. As always, Rosemary continued unafraid.

7 Q. And in relation to what might be done, what might be

8 done to help, it looks as though she asked you -- this

9 is paragraph 14 at the bottom of the page -- to, as it

10 were, keep in touch with your senator, although she

11 didn't give you any specific information to pass on to

12 him; is that right?

13 A. I think the specific information would have been that

14 the cases would have been carried out unbiased, with

15 exposure, as much as possible.

16 Q. In relation to the question of her protection or

17 personal security, you tell us that you don't recall

18 that being raised, but you say this -- and it is the

19 penultimate sentence of this page, RNI-806-041

20 (displayed):

21 "In any event, it was the police who she was afraid

22 of and I know she felt she couldn't trust them."

23 Now, can I just ask you: that last part of the

24 sentence, "I know she felt she couldn't trust them," is

25 that something that she said to you, that she couldn't

 

 

36

 

1 trust the police?

2 A. Could you, please, refer me to which sentence this is,

3 sir?

4 Q. Sorry, it is the penultimate sentence of this page,

5 RNI-806-041 (displayed), in paragraph 14. Perhaps we

6 can highlight it. There. Do you see? It is on the

7 screen.

8 A. I have it.

9 Q. "... I know she felt she couldn't trust them."

10 Now, that lack of trust in the police is what I am

11 asking you about. Is that something she expressed to

12 you herself?

13 A. It could have been my own perception.

14 Q. So it may have been, as it were, an inference that you

15 drew rather than something she said to you herself?

16 A. An inference that I drew from my prior meetings with

17 her, Rosemary.

18 Q. Can I take it, therefore, that you did not have any

19 discussion was with her, that you can recall, about any

20 steps she may have taken in relation to her own

21 protection?

22 A. I believe that she did go into the police precincts in

23 Lurgan. I believe she had mentioned that, that she did

24 send letters to them in Lurgan.

25 Q. Can you remember anything else about that aspect?

 

 

37

 

1 A. No, but that she did approach them, that she did send

2 letters.

3 Q. Right. Those are all the questions I wish to ask you,

4 but, as I say to all the witnesses who come to the

5 Inquiry to give evidence, if there is any matter that we

6 haven't covered but that you would like to draw to the

7 attention of the Inquiry Panel, this is your opportunity

8 to do so.

9 A. Good morning. I would like to say that that was my last

10 time in Belfast, 1st March 1999. Once we heard the news

11 of Rosemary's murder, I really did not desire to come

12 back here out of the stunning and -- boldness of the

13 attack, and this is my first time back and I am glad to

14 be here.

15 Question by THE CHAIRMAN

16 THE CHAIRMAN: Ms Farrell, we are very grateful for you

17 coming over here to give evidence before us. Just one

18 question I would like to ask you, if you can remember

19 this: on 1st March 1999, when you were in the courthouse

20 and you saw Rosemary Nelson in the cafeteria with your

21 cousin, can you remember what sort of case it was that

22 had caused Rosemary Nelson to be in the courthouse?

23 A. No, I can't, sir.

24 THE CHAIRMAN: You didn't discuss the case that she was on

25 at all?

 

 

38

 

1 A. No, she didn't. We were mostly exchanging information

2 about the different defence justice systems, US and

3 the UK.

4 THE CHAIRMAN: Yes. Thank you very much. Thank you very

5 much indeed.

6 Yes? Would you like an adjournment?

7 MR DONALDSON: Yes, a short adjournment, sir, thank you.

8 THE CHAIRMAN: Ms Farrell, if you wouldn't mind remaining

9 here for a few more minutes. We are going to have

10 a quarter of an hour break, and maybe very shortly

11 afterwards you will be able to return, if you wish,

12 today to the United States.

13 A. Yes, thank you.

14 THE CHAIRMAN: We will have a quarter of an hour break.

15 (11.11 am)

16 (Short break)

17 (11.30 am)

18 Further questions by MR PHILLIPS

19 MR PHILLIPS: Now, there are just two matters I want to ask

20 you about in addition to those we covered earlier.

21 First of all -- and perhaps it will help to go back

22 to your statement; if you look at paragraph 6, and it is

23 the part on page RNI-806-039 (displayed) -- you talked

24 in your evidence about threat letters, we discussed

25 those, and also you mentioned calls, and we discussed

 

 

39

 

1 those. Did you understand from Rosemary Nelson when you

2 spoke to her who she believed to be responsible for

3 those threat letters and calls?

4 A. The threat letters or the assaults?

5 Q. You have talked specifically about the assault. I don't

6 want to ask you about that, but about the threat letters

7 first. Did she tell you who she believed was

8 responsible for the threat letters?

9 A. She wasn't sure, I don't think, specifically.

10 Q. Did she suggest to you specifically that she believed

11 the threat letters had been sent by the police?

12 A. She said -- Rosemary said that it could have been

13 a possibility.

14 Q. But she put it no higher than that?

15 A. Exactly.

16 Q. Now, as for the calls, again did she tell you who she

17 believed was responsible for them?

18 A. Members of the community.

19 Q. Thank you very much.

20 Now, the final matter is this: you talk in your

21 statement, in the early parts, about various meetings

22 with Colin Duffy, and the first thing I wanted to ask

23 you is how many times on that visit do you think you met

24 him?

25 A. Twice.

 

 

40

 

1 Q. Twice? So would that be once at his house?

2 A. Hm-mm.

3 Q. And where was the second meeting?

4 A. I believe it was at his house.

5 Q. So you met him twice at his house?

6 A. Yes.

7 Q. Right. And nowhere else, as far as you can remember?

8 A. As far as I can remember.

9 Q. You see in paragraph 5, if we just look at that

10 together -- and that is on page RNI-806-038

11 (displayed) -- you say in the second sentence you

12 recall --

13 A. Yes, I thought maybe it might have been at Long Kesh,

14 but I wasn't sure.

15 Q. Clearly, if he had been in prison at that time, you

16 would only have been able to meet him there. Does it

17 suggest that your recollection of where you met him is

18 somewhat vague at this point?

19 A. No, I remember being at his home.

20 Q. Right.

21 A. For sure, and I believe that we were in Long Kesh as

22 well. I went to Long Kesh several times.

23 Q. And you think on two of those occasions -- is this

24 right? -- that you met Mr Duffy?

25 A. Yes.

 

 

41

 

1 Q. Can I ask you: why did you think it necessary to meet

2 him on those occasions?

3 A. Because when you are looking at a case, there is nothing

4 like face-to-face with the person that is involved, the

5 defendant.

6 Q. Were they meetings suggested by you or by

7 Rosemary Nelson herself?

8 A. A mixture of both. I think I would have liked to have

9 seen the defendant.

10 Q. Thank you very much.

11 Further questions by THE CHAIRMAN

12 THE CHAIRMAN: You actually went inside Long Kesh, did you?

13 A. Yes.

14 THE CHAIRMAN: What is your recollection? How many times

15 inside Long Kesh were you there?

16 A. I believe three occasions, at least three occasions.

17 THE CHAIRMAN: Thank you very much. Well, we wish you

18 a good flight back to the United States, thank you.

19 A. Thank you.

20 THE CHAIRMAN: We will rise now for a quarter of an hour.

21 We will say ten to 12.

22 (11.34 am)

23 (Short break)

24 (11.50 am)

25

 

 

42

 

1 MR PAUL NELSON (sworn)

2 Questions by MR PHILLIPS

3 MR PHILLIPS: Can you give us your full name, please.

4 A. Paul Robert Nelson.

5 Q. Do you have in front of you a copy of the statement you

6 have made to the Inquiry?

7 A. Yes.

8 Q. Can we have it up on the screen, please, at RNI-813-033

9 (displayed)? If we turn over to RNI-813-072

10 (displayed), do we see your signature there and the date

11 of 22nd May this year?

12 A. Yes.

13 Q. Now, turning back to the beginning of the statement, you

14 tell us that you and Rosemary Nelson met at university

15 together?

16 A. Yes.

17 Q. You were, I think, rather ahead of her; is that right?

18 A. That's correct.

19 Q. And I don't think you knew her well at that stage?

20 A. No.

21 Q. But you obviously -- you say:

22 "... began a relationship with her in late 1979 and

23 early 1980."

24 And I think in 1983 you got married?

25 A. That's correct.

 

 

43

 

1 Q. So far as your backgrounds are concerned, you say in

2 paragraph 2 that you wouldn't consider yourself a Lurgan

3 person?

4 A. No, I wasn't educated in Lurgan. I spent all my

5 education either on the outskirts of Lurgan, Newry, or

6 then straight to university. It was only when I left

7 university -- I actually was at boarding school in my

8 secondary education. So it was only when I finished

9 university that I began living in Lurgan full-time.

10 Q. But Rosemary Nelson was a Lurgan person?

11 A. Yes, she was born and bred there.

12 Q. Her family came from there?

13 A. Yes.

14 Q. And she lived and worked there for all of her life?

15 A. Correct, yes.

16 Q. Can I just ask you about her early career, first of all.

17 You tell us that her first legal work, her

18 apprenticeship, was with a firm in Portadown; is that

19 right?

20 A. That's correct.

21 Q. And it was at the time when she'd finished those -- in

22 England they call them articles, the apprenticeship --

23 A. Yes.

24 Q. -- that you got married?

25 A. That's correct, yes.

 

 

44

 

1 Q. As I understand it, thereafter it was difficult for her

2 to find work and, as it were, by way of replacement, she

3 took a job running the community advice centre in

4 Lurgan?

5 A. Yes.

6 Q. Now, reading your statement, it looks as though her plan

7 was always to have her own practice; is that right?

8 A. Well, not her own practice initially, but to practise

9 law, yes.

10 Q. So that she was looking for something more, and more

11 permanent than the local community advice centre?

12 A. Yes.

13 Q. The way you put it in paragraph 5 of your statement is

14 that she needed another year of work in a practice to

15 allow her, as you put it:

16 "... to open up on her own."

17 A. Correct.

18 Q. So do you think then by, let's say, the mid to

19 late 1980s that idea of opening up on her own was very

20 much in her mind?

21 A. Well, after she had worked there for two or three years,

22 she decided she wanted to go back into law and at that

23 time I think lawyers' jobs were very hard to come by,

24 and she thought the best way would be to open her own

25 practice.

 

 

45

 

1 Q. So she found a job in Lisburn, where she was the only

2 assistant solicitor, and worked there in fact for rather

3 less than a year, six to nine months, you say?

4 A. Yes.

5 Q. And then got her practising certificate?

6 A. Practising certificates were issued, I think, in the

7 January of each year. She had been informed that she

8 would have to work for a year, but when she applied

9 in January to renew, they informed her because she

10 already had one, even though it wasn't for a year, she

11 was entitled to then get one in her own right.

12 Q. Now, do you know what sort of work she did in the firm

13 in Lisburn?

14 A. Very little. She was in there for a few months. It was

15 a very small practice. But it was just a mixture, just

16 a mixture. It would have been probably court criminal

17 work on a very small level.

18 Q. But the reason I ask you is because, in fact, as you

19 tell us, what she did after that work in Lisburn, six to

20 nine months, was to open up her own practice in Lurgan.

21 A. Yes.

22 Q. So that at that point, the point in March 1989, where

23 she began her own practice, she had had

24 a post-apprenticeship experience of six to nine months?

25 A. Yes.

 

 

46

 

1 Q. It was a very bold thing for her to do, wasn't it?

2 A. Well, you mean -- her intention was, when she took up

3 the job, to only be there as short a period of time as

4 necessary to get her full practising certificate, so it

5 didn't really matter what work or experience she had.

6 That was her decision.

7 Q. What I meant was that it was a bold thing to set up her

8 own practice after a relatively small amount of

9 practical experience in the job in Lisburn?

10 A. Oh, yes.

11 Q. Was she anxious as to whether she would be able to make

12 a go of it?

13 A. Oh, yes, I mean, there were a few anxious nights

14 thinking about it.

15 Q. No doubt you were privy to that anxiety yourself?

16 A. Yes, we worked out what it would take and we realised it

17 would be a long struggle, as for any practice,

18 especially from her lack of -- her experience as

19 a solicitor. We understood it would be difficult with

20 no client base.

21 Q. And it was the only firm at that time, wasn't it, a sole

22 practice firm, run by a woman in Lurgan; is that right?

23 A. Yes.

24 Q. And I think that may have continued actually throughout

25 the whole of her life; is that right?

 

 

47

 

1 A. In fact, I think -- I don't know of any women running

2 a practice in Lurgan at the moment.

3 Q. No. When she first started, how many people did she

4 have working for her?

5 A. One.

6 Q. Just one. You tell us about those early years and the

7 office in William Street in paragraph 6 of your

8 statement at RNI-815-034 (displayed). As I understand

9 it, when she first started, she didn't own the building

10 but did eventually buy the premises. Is that right?

11 A. Yes, eventually.

12 Q. And there were a number of others in the building when

13 she first started. Presumably she expanded --

14 A. It was subdivided into, like, six or seven different

15 units.

16 Q. Yes. And it looks as though from the start she expected

17 to succeed in this bold venture?

18 A. Well, make a living would be the definition at the time;

19 make a living as a solicitor, that she would have made

20 working for somebody else.

21 Q. But the thing you point up in your statement,

22 paragraph 7 -- and that is at RNI-815-035, perhaps we

23 can get that on the screen for you (displayed) -- is

24 that she thought that a female solicitor would do well

25 in the town.

 

 

48

 

1 A. Yes.

2 Q. Why was that?

3 A. Well, one, she felt that women would be more comfortable

4 coming to a female solicitor for problems that they

5 personally had. But she had also realised that I think

6 through her work in the community centre, where lots of

7 times women would have come with family problems. And

8 she also realised that women deal with a lot of

9 day-to-day legal issues, the husbands working -- well,

10 I suppose, going back 20 years now, you know, sort of a

11 Monday to Friday, couldn't get time off, so it was left

12 to the woman to bring issues to a solicitor, deal with

13 issues on behalf of it, or convention or whatever. But

14 they dealt with it, and she felt they would feel

15 comfortable coming to her.

16 Q. And presumably she felt it was also an advantage being

17 part of a local family; she was a local woman?

18 A. At that stage she had went to school. We had lived, and

19 we had never been more than, probably two miles from

20 where she was born.

21 Q. Now, you describe the early years, the very early years

22 of the practice. It was obviously a bit tough at the

23 beginning, as no doubt it is for many people in that

24 situation. But you tell us in paragraph 8 that after

25 a couple of years things started to improve?

 

 

49

 

1 A. Yes.

2 Q. What type of work was it that helped to bring about that

3 improvement?

4 A. It wasn't anything particular. As I say, you know, when

5 most solicitors decide to open a practice, they have

6 been practising for four or five, whatever number of

7 years and would have some sort of client base. She

8 didn't. I think she had two files when she first opened

9 her doors.

10 So it took that length of time for word to spread.

11 Even in a small community like Lurgan, people would

12 still, two years later, say, "Where are you working

13 now?" That is just the way it works.

14 Just all sorts of work. I mean, the bulk of it

15 after two years would have been matrimonial, small

16 conveyancing, small road traffic accidents, just

17 everything, petty sessions. Well, I suppose of them all

18 matrimonial, would have been the one, so it would have

19 dominated in those first two or three years.

20 Q. So you also mention a particular case in 1992 -- this is

21 paragraph 8 -- where she had acted for local employees,

22 employees of a factory. And it sounds as though that

23 did her reputation some considerable good in the town;

24 is that right?

25 A. Yes, it was put in the national papers, plus -- I mean,

 

 

50

 

1 for no other reason, I think there was something like

2 100/120 people she was acting for, so in one fell swoop

3 she probably had more clients than she had had in her

4 whole client base at one time. So it did her no harm

5 at all.

6 Q. In terms of the growth and the continuing development of

7 the practice, which you describe in your statement, as I

8 understand it, the reputation was passed by word of

9 mouth?

10 A. Yes.

11 Q. It is not something that she sought to advertise or put

12 before the public in any other way?

13 A. There was no way to do it. It was word of mouth.

14 Q. Before we look at the way the practice developed from

15 this point, can I just ask you about your own work. You

16 are not a lawyer?

17 A. No.

18 Q. What work do you do?

19 A. I am an accountant.

20 Q. Was that the work you have done throughout your married

21 life?

22 A. Yes.

23 Q. So all the times we have been talking about in the

24 late 80s and through the 1990s --

25 A. I got my first job and I only left there when this

 

 

51

 

1 Inquiry started.

2 Q. Now, in terms of the way the practice developed, you

3 tell us in paragraph 11 -- and this is at RNI-815-036

4 (displayed) -- that by 1993, so some four years after

5 the start, it had grown to a significant size?

6 A. She needed another solicitor. She needed another

7 professional help.

8 Q. That is what I wanted to ask you --

9 A. 1992/1993.

10 Q. Yes. So more employees in the office?

11 A. Yes.

12 Q. More space required to work?

13 A. Hm-mm.

14 Q. And presumably another solicitor?

15 A. Yes.

16 Q. And we have heard a lot of evidence about the people who

17 worked with and for Rosemary Nelson over the years. It

18 looks as though the maximum number of other lawyers at

19 any one time was two. Does that accord with your --

20 A. Yes, there was never any more than three.

21 Q. In all?

22 A. In all.

23 Q. And that sometimes, even late on, it looks as though

24 there was just Rosemary Nelson and another lawyer, in

25 this case Mr Vernon?

 

 

52

 

1 A. That's correct.

2 Q. Now, looking at what motivated her as the business was

3 expanding, you have given your view about that. Was

4 money a motivating factor for her?

5 A. No, she just got engrossed in the work. She loved being

6 a lawyer and she got the opportunity to be a lawyer, and

7 she just loved the work.

8 Q. So the engagement of the work itself was the reward, as

9 far as she was concerned?

10 A. Yes. Just to be precise, at that time, it would have

11 been a profitable business. It had gone from that leap

12 of being a small, one-person practice to that leap with

13 the normal hiccups development brings with it. But it

14 was gradually developing into a profitable business.

15 Q. So by, let's say, 1993, the concerns that you had had

16 and she had had about whether it was going to work had

17 been, at least to some extent, allayed. Is that right?

18 A. Yes, well, we knew at that stage the business had just

19 other problems then come along, but we knew the business

20 was going to stand as a business.

21 Q. Did that continue to be the position throughout the rest

22 of her life?

23 A. It did, yes.

24 Q. If money wasn't the motivation, it looks as though one

25 of the ways in which the business developed, from your

 

 

53

 

1 perspective at any rate, was that she took on whatever

2 work came her way?

3 A. That's correct.

4 Q. She didn't, as it were, turn away cases as they came

5 through the door?

6 A. No, she started acting whether or not Legal Aid was

7 granted. She just moved a case on.

8 Q. So that the concern to get on with the work was greater

9 than the concern about funding?

10 A. Correct.

11 Q. And it looks from some of the evidence as though her

12 concern about the cases and the work, that was much more

13 important to her than, for example, keeping up with the

14 paperwork or the administration. Is that a fair

15 comment?

16 A. That's a fair comment.

17 Q. Now, so far as work that wasn't paid is concerned, you

18 have mentioned about Legal Aid and not waiting for the

19 forms to come in, as it were. You also tell us that she

20 took on a lot of pro bono work. That is paragraph 12 on

21 page RNI-815-036 (displayed). Can you think of examples

22 of pro bono work that she took on?

23 A. Not precise names, but I know she worked for a lot of

24 communities, went to meetings. You know, she just saw

25 that as an extension, because she probably worked for

 

 

54

 

1 those people on other cases. So she wouldn't

2 necessarily charge for individual cases that she felt

3 couldn't be paid. It was just an extension; call it PR,

4 if you like. That was just the way she operated the

5 business.

6 Q. So she would take on work willingly in those cases

7 without being paid for it?

8 A. Yes.

9 Q. One of the comments that has been made about her and her

10 attitude to her work was a suggestion that she found it

11 difficult to say no. In other words, if somebody said

12 to her, "Would you do this for me, would you act in this

13 way for me?" she tended to say, "Yes, I will"?

14 A. Yes, it is an option, because she then was making

15 a judgment call on that particular case, which she would

16 never do.

17 Q. No. So I am clear on this, she wouldn't, as it were,

18 form her own judgment about the merits one way or

19 another of a case before deciding whether to take it on?

20 A. All -- I couldn't get into her mind, but all I know, she

21 never came to me and said, "I'm not taking this case on

22 because I am unhappy for X, Y, Z reasons with the client

23 or the case". She never once said that.

24 I do know she has dealt with some quite gruesome

25 cases. I just then had to accept the evidence before

 

 

55

 

1 me, that was her feelings: that the case nor the client

2 would make any difference to her.

3 Q. But all of these characteristics of hers, which you

4 obviously knew well, certainly taken together are

5 a recipe for doing more and more and more work, aren't

6 they?

7 A. Correct, yes.

8 Q. And that, presumably, was a concern for you?

9 A. Yes. In 1995, 1996, 1997 the number of cases coming in

10 was growing substantially.

11 Q. And presumably she was having to work longer and longer

12 hours?

13 A. Yes and no. I mean, you couldn't actually say she was

14 doing -- but more intense. In the first two or three

15 years of the business, she had more time and was able to

16 take more time over a case. Everything now had to be

17 done there and then at high speed.

18 Q. The pressure was greater?

19 A. Plus the pressure of running the office, because at this

20 stage she had a lot more staff. So the normal pressures

21 of staff in the office, and the more staff you have, the

22 more problems you have.

23 Q. We will come back to that question when we look at the

24 slightly later years.

25 Can I ask you a question about the sort of people

 

 

56

 

1 she worked for. As I understand it from your statement,

2 the open door policy, if I can put it that way, the

3 willingness to take on work as it came to her, meant

4 that she did work for both sides of the community here

5 in Northern Ireland; is that right?

6 A. Well, she didn't ask them who they were when they walked

7 in the door. They just come in as a client. They were

8 a client, that is it.

9 Q. You give some examples of that in paragraph 13 on

10 RNI-815-036 (displayed), and you suggest that what you

11 call the Protestant client base was still a substantial

12 part of the overall client base at the time of her

13 death?

14 A. Yes, she would have known by -- because I have a deep

15 knowledge of the client base because I have had to run

16 the office after her death, I know by the names and the

17 addresses predominantly that it was, as I say, maybe not

18 50/50, but it wasn't far off that.

19 Q. So in other words, that this pattern continued, at least

20 so far as you are aware, up to the time of her death?

21 A. Yes, it's not just particular to Rosemary. Lurgan would

22 do that. People, when they go to any professional, from

23 my own experience too, they don't make a judgment call

24 on whether a solicitor is Catholic or Protestant. They

25 go to somebody they trust who they reckon can do a good

 

 

57

 

1 job.

2 Q. So in that sense she conformed --

3 A. A professional in --

4 Q. -- with the general approach in that area?

5 A. Yes.

6 Q. Yes. So far as the cases with which a lot of evidence

7 has been concerned; namely, the what other people have

8 called the high profile cases, involving in particular

9 allegations of terrorist-related offences, can you

10 remember when that sort of work started to come her way?

11 A. You can't draw, you know, a line in the sand. It was,

12 I suspect -- Well, I know that sort of -- you started

13 doing particular cases with different people, and as the

14 practice developed, either they got into the different

15 problems and came to her, or people out there had seen

16 how she was dealing with small issues and decided to

17 come to her because they trusted her to deal with major

18 issues.

19 But you can't put your finger on it and say when it

20 was happening. It was just a development at the office:

21 the same way it expanded, the same way as she was

22 getting larger litigation cases. And I suspect that

23 when a person has a small road traffic accident, they

24 are quite happy to go to any solicitor, but if they have

25 a major medical case or something, they think long and

 

 

58

 

1 hard about it. That is just the way, because your

2 reputation -- those are the way those cases presumably

3 came to her.

4 Q. So this was part of the gradual development of practice?

5 A. Yes.

6 Q. Not something that happened suddenly?

7 A. And I noticed that in these high profile cases -- she

8 had actually higher profile cases but, because they

9 weren't terrorist-related, they haven't been mentioned

10 here. So her profile had been known within Lurgan on

11 these other cases.

12 Q. Can you give us some examples?

13 A. I can't remember the name, but I know -- I mean, she had

14 done, I think, two murder cases in 1993/1994, you know,

15 very gruesome murder cases. I know one in particular

16 was very gruesome.

17 Q. There is one you mention in paragraph 16. Perhaps that

18 will help you, if you look at RNI-815-037 (displayed).

19 A. Is that the neighbour next door?

20 Q. Yes.

21 A. Yes.

22 Q. So that was a very high profile case?

23 A. Because of the nature of the case, very unprovoked type

24 of case.

25 Q. Yes. And when you say in this paragraph:

 

 

59

 

1 "After this case she handled three to four attempted

2 murder cases ..."

3 Were those terrorist cases or were they, as it were,

4 ordinary?

5 A. Just ordinary crime cases.

6 Q. Now, one of the themes that emerges very strongly from

7 your statement is your view -- which you have indicated

8 a little earlier -- that the number of high profile

9 cases of the terrorist kind, which she undertook in the

10 course of her practice, was a relatively small number

11 compared to the overall number of her cases?

12 A. Yes.

13 Q. And I think you believe, don't you, that that created

14 a misleading or distorted impression of the sort of work

15 she did day in, day out?

16 A. Yes. I mean, I think there has only been three cases --

17 I may be wrong -- that she mentioned here. I mean, when

18 her practice closed, I know she had close to 1,500 live

19 cases, you know. And these three -- so she must have

20 dealt, 10,000, 15,000, 20,000 cases, and these were two

21 or three cases.

22 Q. Can I just ask you: when the first of these

23 terrorist-related cases came in, did she express any

24 concerns to you about taking it on?

25 A. No.

 

 

60

 

1 Q. Now, at a number of points in your statement you say

2 that you didn't discuss details of her work with her?

3 A. No.

4 Q. On the grounds of client confidentiality?

5 A. Yes.

6 Q. So can I take it --

7 A. Sorry, I should clarify that just before you move on.

8 I mean we didn't discuss cases that I wouldn't have

9 known about. But of course, a lot of cases were, just

10 like I have mentioned, public knowledge, so we would

11 discuss cases like that.

12 Q. But so far as matters that weren't public knowledge were

13 concerned then, this was her policy, was it, throughout

14 her life: not to discuss the confidential details with

15 you?

16 A. That's correct. Presumably on the basis that she wasn't

17 allowed to.

18 Q. So far as the first of the two Colin Duffy cases that we

19 have heard so much about -- this is the Lyness case --

20 was that one of the first murder cases that she had

21 done?

22 A. It was definitely the first terrorist murder case. No,

23 I think that other case pre-dated that. I may be wrong,

24 but I think the other case pre-dated it.

25 Q. The domestic murder --

 

 

61

 

1 A. I would have to check, but I think that it pre-dated it.

2 Q. In relation to that case in particular, can you help: do

3 you know how that case, the first of the Colin Duffy

4 cases, came her way?

5 A. Not precisely, no, but he lived in the area. I am sure,

6 like most cases, it was just family connections or she

7 had done work for them before.

8 Q. You say in paragraph 23 at RNI-815-039 (displayed) that

9 you suspect that she acted for clients such as

10 Colin Duffy because she had acted for other members of

11 his family before, done a lot of work --

12 A. That is the way most of her work come in, through

13 family -- you did petty sessions. They got something

14 else, and as she got more experienced, cases from the

15 same source of people.

16 Q. This case -- and as we all know, it went eventually to

17 an appeal and Mr Duffy was released in 1996 -- when she

18 first became involved in it, was there any sense on your

19 part, not in discussion with her -- you have talked

20 about that -- was there any concern on your part about

21 her becoming involved in a terrorist murder case?

22 A. No.

23 Q. No.

24 A. It was just a case. She was a solicitor. It was

25 a case. There was no ...

 

 

62

 

1 Q. This, of course, was in a period in Northern Ireland

2 long before the Good Friday Agreement and when things

3 were perhaps not as certain or settled as they became in

4 the later years of her life. But you were not concerned

5 about her taking on a case of this kind?

6 A. No, I mean, because we both had lived in

7 Northern Ireland over the worst of the Troubles, and,

8 you know -- and there had been a lot worse happened over

9 the period of time. So I mean, it was nothing

10 extraordinary at that time. There was nothing going on

11 that made it any different to things that had happened

12 years and years before and other solicitors had done

13 numerous times. So ...

14 Q. We have heard that some solicitors were not willing, or

15 not keen at any rate, to take on work of that kind, some

16 solicitors in that area. Were there other solicitors in

17 Lurgan at the time who were doing work of that kind?

18 A. There was bound to be. There was no way Rosemary was

19 doing it all, so there must have been other solicitors

20 doing that type of work, either before, after or during

21 her life.

22 Q. Can I ask you about another of the cases that the

23 Inquiry has been hearing about, and that is the

24 Garvaghy Road work?

25 Am I right in thinking, again, as far as you are

 

 

63

 

1 aware, that this was a pro bono case?

2 A. It was, yes. Sorry, for the community -- I mean, there

3 would have been work out of it from separate

4 individuals.

5 Q. Yes, there were claims cases, weren't there --

6 A. That's correct.

7 Q. -- later on, and they would presumably have been dealt

8 with under the normal Legal Aid rules?

9 A. Yes.

10 Q. But so far as her work for the community and the

11 meetings we have heard about, et cetera, that was pro

12 bono?

13 A. Yes.

14 Q. And how did she come to take on that case?

15 A. Well, by that stage -- I presume you are talking

16 probably 1995/1996 -- she was doing a lot of work in

17 Portadown. Craigavon court covers Lurgan/Portadown in

18 that area, so quite a few people -- there was

19 a crossover. Some Portadown people would have married

20 and have lived in Lurgan and vice versa, so her name

21 would have started going about Portadown, they'd have

22 seen her in court, so she had started to get a lot of

23 work out of Portadown.

24 Q. You say you think she would have known Mr Mac Cionnaith

25 before?

 

 

64

 

1 A. Yes, his family is from Lurgan so she would have known

2 the Mac Cionnaith family.

3 Q. The work she did for that case, some of the witnesses,

4 some of the people who worked in the office, described

5 how that took up a huge amount of her time, certainly in

6 1997 and 1998. Was that something that you yourself

7 were aware of at the time?

8 A. No. Well, it took up time, but in short sharp spasms of

9 time which normally centred around the July period, when

10 most offices are quite quiet anyhow; in Northern Ireland

11 anyhow, July our courts closed.

12 There would have been other times, but most of the

13 focus would have been just before or just prior to the

14 parade, which takes place the first Sunday in July, I

15 think. So July would have been the time but, no -- I

16 mean, devoted, but nothing overly -- I mean, she was

17 still running a practice, you know. But, no, there was

18 short spasms and she would have spent, when she got over

19 there, maybe two to three days at a time. But, no, it

20 was a time when it was quiet in the practice.

21 Q. But clearly, if only from your perspective as an

22 accountant, never mind as her husband, were you not

23 worried that so much time, even in those particular

24 parts of the year, was being devoted?

25 A. No, because, one, it brought her in contact with loads

 

 

65

 

1 of clients. And I mean, if you are looking at if from

2 a purely financial basis, how many cases did she get out

3 of that short period of time? Hundreds of other cases.

4 Plus the fact Rosemary had this knack of being with you

5 for five minutes, but giving you the impression that she

6 had spent the whole week thinking about your case. But

7 before and after you left, she moved on to something

8 else. But she had this knack of making you think you

9 were the only concern in her mind and had been for the

10 last month.

11 Q. It is a very enviable quality.

12 A. Just the way she could cover a case and deal with

13 people. Presumably that is why her practice developed

14 so much, because everybody assumed they were getting

15 personal attention.

16 Q. So it was one of her talents, clearly -- and others have

17 mentioned this -- to, as it were, have the first meeting

18 with the client to get the work in and then it might be

19 that the actual, you know, dogsbody work, if I can put

20 it that way, afterwards would have been dealt with by

21 other people?

22 A. That's actually what happened, yes.

23 Q. Yes. Now, in paragraph 22 of your statement when you

24 are dealing with the Garvaghy Road, you say in the third

25 sentence:

 

 

66

 

1 "She saw it simply as a progression of her existing

2 case load."

3 I wanted to see if you could expand on that for us.

4 What do you mean exactly about that expression?

5 A. Not being involved in the face-to-face discussions, but

6 I would say that somebody came to her, albeit in this

7 case it may have been a group of people who came to her,

8 and said, "We have a problem, could you help us with

9 it?" And it would have been a simple as that.

10 Q. So an extension in the sense of being very like the

11 other pro bono work that you have described earlier; is

12 that right?

13 A. Like any work she did, whether pro bono or not, somebody

14 came, they had a problem and they needed legal help with

15 it and she took it on. There was no real difference --

16 it was just more high profile. There was no real

17 difference in it really.

18 Q. But you say in your statement, as far as you were

19 concerned, it was this case which, in a sense, made her

20 most obviously a public figure, more than all the other

21 cases that we have heard reference to?

22 A. Well, other people made her a public figure out of doing

23 this work.

24 Q. Yes. What do you mean by that?

25 A. I mean, it is like in anything, you know, people talked

 

 

67

 

1 about it. She didn't make herself a public figure out

2 of it. Other people did for, you know, their views on

3 the issue.

4 Q. You describe her as a private --

5 A. She was --

6 Q. -- and as a shy person?

7 A. She was, yes.

8 Q. So, as you saw it at any rate, the publicity which she

9 undoubtedly did receive as a result of this work you

10 believe was not something she herself sought?

11 A. No, not for herself.

12 Q. No. Would she have sought it as part of her work for

13 her clients?

14 A. If she thought her clients needed publicity to help

15 their case, she would have encouraged them to seek it,

16 yes.

17 Q. Now, can we just look forward to the couple of years

18 before her murder, and in particular to, let's say, late

19 1997/98.

20 By that stage, how much matrimonial work and

21 conveyancing work was Rosemary Nelson herself doing, do

22 you think?

23 A. What were those years again?

24 Q. 1997 and 1998.

25 A. She had just reorganised the office I think around

 

 

68

 

1 1996/1997. I think that might have been the time when

2 she had started -- well, 1998 definitely she took on

3 another solicitor. The office had expanded. She had

4 taken on a lot of extra staff, which caused problems.

5 Sometimes the more staff you have, the less work is

6 actually going out the door.

7 So she had reorganised and she had then put herself

8 in place of sort of being what one called the lead

9 figure in it: So, you know, seeing everybody, taking

10 the jobs on. But she now was employing experienced --

11 what you would call them now? -- legal executives, you

12 know? She had some very highly qualified staff who were

13 not solicitors but had worked in solicitors' practice

14 for 10, 15, 20 years, and she was using them to do a lot

15 of the day-to-day work on the case and she was leading

16 all the cases. That is how she was actually managing to

17 deal with the large volume of cases she was dealing

18 with.

19 Q. She was heavily reliant on delegation?

20 A. Yes. I mean, not that she was reliant. It was

21 a decision she made that -- she had ended up and she

22 would sort out three or four -- you wouldn't call them

23 solicitors, but they weren't far off being that

24 experienced. Her decision was it was better to use them

25 than to bring newly qualified solicitors into the

 

 

69

 

1 practice. They were more productive.

2 Q. So how was she spending her working time?

3 A. Well, initially trying to see as many clients as

4 possible and dealing with the intricacies of a case

5 rather than the mundane paperwork presumably we all have

6 to deal with. She was passing that down and getting

7 that done. You could presumably call it a more

8 business-like approach to operating the office.

9 Q. That strategy, was that something that you had discussed

10 with her?

11 A. No, she told me. I think she had discussed it with her

12 own accountant. I imagine that the accountant of the

13 practice, they had looked at this and I think she had

14 decided that this was the way -- she was never going to

15 be able to get to a highly qualified, you know,

16 experienced solicitor into the practice, because the

17 first thing they would ask for is presumably, "When is

18 my partnership coming?" So she knew that that wouldn't

19 work.

20 So she used a different tactic of, "Look, we will

21 take on the work but I have five highly-qualified staff

22 to do it." And that's what she was doing, being the PR,

23 the profile, the person they initially see and,

24 presumably, the person they see last. But in the middle

25 you had all the people doing the work.

 

 

70

 

1 I don't know if it's something that goes on. I know

2 it goes on in accountancy practice all the time. You

3 see the partner at the start, you maybe see him at the

4 end when he is finishing the case and handing you the

5 bill, but in between he may not see your case.

6 Q. Presumably one of the elements of the strategy you have

7 described is she didn't want to have a partner in the

8 practice; she wanted to continue to be a sole

9 practitioner?

10 A. Correct.

11 Q. Were there occasions when you thought that it might have

12 been better for her to have a partner in the practice,

13 somebody to whom she could speak as an equal about the

14 problems of the practice?

15 A. I don't recollect at the time, but I have since, yes,

16 and in hindsight, yes, it would have been far better if

17 there had been, presumably from day 1, an experienced

18 partner with her, yes.

19 Q. Because, as we have heard from other witnesses, when

20 there are pressures and concerns and worries, it is of

21 course, much easier to speak, you know, on the level, as

22 it were, with a partner?

23 A. I think you have to realise that Rosemary's practice

24 only lasted just a day short of ten years, and it took

25 off so slowly that it really -- it got very intense very

 

 

71

 

1 quick. You know, you can't look back now and say --

2 things moved on so fast, but in hindsight, yes, it would

3 have been better if there had been an experienced

4 partner there.

5 Q. Can I just come back to the question of the perception

6 of the practice and this question of which were the

7 cases that shaped that perception.

8 You have said or confirmed already that in your view

9 it was the Garvaghy Road case that was most high

10 profile. You tell us in paragraph 56 -- and this is the

11 at the bottom of page RNI-815-048 of your statement, the

12 very last line (displayed) -- that you think she would

13 have been of the view that it was the work that she did

14 for the GRRC that was the most high profile she ever

15 had?

16 A. Yes.

17 Q. So that was something that you are aware of from what

18 she herself said; is that right?

19 A. Of people that I know she saw, she spoke to, she dealt

20 with, either through her or that was in the papers. The

21 TV coverage alone, I mean, you know -- you know, you

22 have had very few clips of Drumcree, but there are

23 hundreds and hundreds of hours out there of the Drumcree

24 coverage. I suspect that most people even in here would

25 all have heard of Drumcree. They may not have met her

 

 

72

 

1 in any of these other cases. It was known worldwide. So

2 yes, it would have been the most high profile.

3 Q. And you say earlier in your statement -- and this is

4 paragraph 33 at RNI-815-041 (displayed) -- that you

5 think this high profile -- whatever it was that caused

6 it -- did cause her real difficulties in later years, or

7 rather some people's reaction to her high profile did.

8 And can I ask you first: what were the difficulties that

9 you are referring to there?

10 A. You know, harm to her life. I mean, she realised that

11 the profile of the case and her association with it

12 could be difficult.

13 Q. That it might put her in danger?

14 A. Yes.

15 Q. So can I just be clear about this: At the time, she

16 thought, did she, that it was this case, the GRRC case,

17 that led to that sense of her being in danger?

18 A. Yes.

19 Q. And in this same passage, do you see at the very bottom

20 of the page, you say:

21 "She felt that people were making judgment calls on

22 her."

23 Can you help? What do you mean by that?

24 A. It is quite obvious: they saw her with the Garvaghy Road

25 residents and they assumed that because she was acting

 

 

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1 for them, she supported their cause.

2 Q. I see. So that the judgments people were making were to

3 associate her, the lawyer, with the clients in that case

4 and their cause?

5 A. I would suspect -- I would suppose so, yes.

6 Q. Again, is that something, that problem of -- what's a

7 problem of perception essentially, was that something

8 that you discussed with her?

9 A. Yes.

10 Q. And what was her view about that, as you would see it,

11 wrong perception of her?

12 A. She could do nothing about it. You can't change

13 people's perceptions. You can't do anything about it.

14 You either stand up and talk about that you do not agree

15 with them or whatever, but you can't change it. You

16 just have to hope that there is more people out there

17 understand your relationship with your clients than have

18 the opposite view. But there was absolutely nothing --

19 except walk away from it. There is nothing you can do

20 about it.

21 Q. Later in this same paragraph at RNI-815-042, if we look

22 at the top of the next page (displayed), you say you

23 don't think these sort of thoughts really troubled her

24 until about a year or so before her death?

25 A. That's correct.

 

 

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1 Q. Just dealing with that sentence, if you had

2 conversations of this kind, as far as you could see, she

3 was not concerned or worried about the effects of the

4 high profile case until about a year before her death;

5 is that right? The top of the page.

6 A. Well -- no, she always was aware of it. She always was

7 aware that there was a danger. It just got worse in the

8 last year, 18 months.

9 Q. Were you aware at the time of what had led to that

10 change?

11 A. Well, I think -- well, the main reason is because she

12 was now operating directly in an area which had

13 a reputation for gruesome murders.

14 Q. This is the local area?

15 A. The Portadown area.

16 Q. Yes. In other words, because of her work for the

17 Residents Coalition, she was, geographically at any

18 rate -- the focus of her work had shifted in that sense

19 to Portadown?

20 A. Yes.

21 Q. Which was at that time, a year or so before her death,

22 as we have heard, a particularly fraught and

23 conflict-ridden place?

24 A. Correct. And I believe the dates probably coincide with

25 another case she had just started dealing with.

 

 

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1 Q. Do you mean the --

2 A. Robert Hamill case.

3 Q. The Robert Hamill case?

4 A. Yes.

5 Q. I think she started to be involved in that in 1997,

6 didn't she?

7 A. Correct.

8 Q. And that was a murder that had also taken place in

9 Portadown?

10 A. Correct.

11 Q. Yes. Now, at that stage then, a year or so, let's say

12 in early 1998, before her murder, did you talk to her

13 about this change and what it meant for her?

14 A. Well, we were concerned, I mean -- specifically the fact

15 that she had to be in that area on a regular basis and

16 at strange times, you know, late at night, early in the

17 morning, unsociable hours, because of the circumstances

18 of the problems in Portadown, you know, the

19 Garvaghy Road residents had at that time, particularly

20 around the time of the march. And she was also aware,

21 as I said, (inaudible) time before that that had brought

22 her into conflict with the other people in Portadown

23 too.

24 She knew herself the type of individuals that lived

25 and operated out of the Portadown area. So, I mean, she

 

 

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1 knew all these things, but she just couldn't walk away

2 from it. It was a judgment call she had to make.

3 Q. That is the next thing I wanted to ask you: Did you say

4 to her, "Well, shouldn't you give up this type of work?"

5 A. No. If you had known Rosemary -- if you had asked her

6 to give up a case because she was going to be

7 threatened, you had less likelihood of getting her to do

8 it.

9 She was fully aware of it. She was very worried

10 but, you know, the cases had just built up. It is not

11 as simple -- and I think what is probably going through

12 her mind: when you turn down one, where do you stop? Do

13 you stop at the next door neighbour? You don't like him

14 because he's -- You couldn't do it. It was a path you

15 couldn't go on: letting people decide what cases you did

16 or did not do, mainly due to maybe something that was

17 written in the papers or what reporters said. You had

18 to trust that those on the ground knew you as a

19 solicitor. She just couldn't go down that path.

20 Q. So you didn't make the suggestion because you knew --

21 A. Some might say you should have made (inaudible). I knew

22 it would have made no difference. If I would have made

23 it, it would have only been for PR purposes. No, she

24 wouldn't have walked away from any case.

25 Q. And in relation to publicity and what we talked about

 

 

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1 a little earlier, where you said that you drew

2 a distinction between, as it were, publicity for herself

3 and publicity for her clients, did you discuss that

4 particular aspect of it? In other words, was there

5 anything --

6 A. Not as cold-bloodedly as you are putting it there. It

7 has come up through her life. As you say, she was

8 a very shy person. It seems a long time ago now.

9 I watched the clips that you have shown. I don't

10 know -- most of them, except maybe for one, she was

11 talking about clients in all of them. I may be

12 surprised, but I think she only produced one -- and you

13 saw the circumstances that that took place. It wasn't

14 a rational judgment call that she made to profile

15 herself. I think she was more likely doorstepped, and

16 you saw the fear in her eyes when she was giving that

17 interview. I think she may have given one or two

18 interviews to journalists throughout her ten years.

19 I don't see that much of a PR campaign, you know

20 what I mean? The rest, where she was speaking on behalf

21 of clients -- but even then, she didn't actually speak

22 that often throughout her ten years in practice, you

23 know.

24 Q. You will have heard the evidence: that some have said

25 that there were constant television cameras coming in

 

 

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1 and out. Does that accord with your understanding?

2 A. No, and I am sure if it was we would have loads more

3 pictures here. No, there was never a journalist unless

4 there happened to be a journalist who we weren't aware

5 of in our house in the area. We are just not that type

6 of family.

7 As I say, I can't remember her actually sitting

8 down -- I don't know she was ever -- I don't think of

9 any TV programmes with her being on it or anything. No,

10 that wasn't her nature.

11 Q. With the exception of the interview you have mentioned,

12 was that the interview in relation to the Garvaghy Road

13 matters?

14 A. I believe some American was there doing some -- who

15 presumably was there, had been about for a few days and

16 happened to be with Rosemary at the time. But you saw;

17 it was a very professional, organised interview and

18 I suspect that was just after her incident on the road.

19 Q. Turning to another topic, in paragraph 34 you talk about

20 the difficulties she was having with the police and how

21 they developed. Again, it is a very difficult, I know,

22 but can you help us as to when you were first aware that

23 she was having problems with the police?

24 A. It is impossible to isolate it, because like most of

25 these things, like the growth of her practice,

 

 

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1 everything, I mean, it just -- it is just one day it

2 appeared. Probably 1997/1998, she started to think

3 about it more. Up to then, you know, there was -- she

4 had very good relationships with the police. I know

5 that she had many police officers and women as clients.

6 And it just -- I mean, she herself couldn't probably say

7 when it had happened, but she just got the feeling --