Lewisham Council and its managers told dozens of lies about me and defended these lies in Court.
In particular it denied knowledge of my disability, (despite having clear evidence of it) and then used this as an excuse to dismiss me.
During the course of the Tribunal and Court proceedings, Lewisham Council and its managers put forward so many contradictions and inconsistencies.
There is ample evidence of dishonesty which they are not in a position to rebut in the light of the facts and matters set out in my Particulars of Claim, Reply to the Defence, and my seventh and eighth witness statements.
| I informed the Court that statements made by Unison representatives, (which are depicted in my covert recordings), support my contention that Lewisham Council is guilty of wrong-doing and that I am an innocent party. I submitted these covert recordings to the High Court. |
Lying to and misleading is contempt of court.
The Defendants’ relied on false evidence for their High Court Defence to my defamation action.
- They asserted that all the false allegations made about me, (which are disproved by my covert recordings and transcripts), are true.
- I argued that this constituted provision of a fraudulent statement of case to the Court and/or the publication of matters calculated to prejudice a fair trial.
I advised the Court that the Defendants’ had submitted a Defence containing false statement(s) and/or references to false and inconsistent evidence.
I also advised the Court that the Defendants’ had submitted a false disclosure statement which relied on false information/evidence.
I argued that there was intent to mislead the Court by using fraudulent evidence and/or evidence unlawfully obtained against the European Convention to unlawfully make an application for a cost order and civil restraint order against me.
In this document you can read all of my legal arguments in relation to my contempt of court allegations.
1. The Defendants’ admitted they defamed me.
2. Judge Eady stated the following, (at paragraph 33 of his judgment striking out my claim):
…it would hardly be possible to rule in relation to the pleaded case in malice that it is bound to fail.
Please note that my extensive documentary evidence and my covert recordings and transcripts disprove all of the allegations made against me by the Defendants.
I was dismissed before Lewisham Council became aware that I had been covertly recording their managers.
Click on the names of the Defendants’ in the case to see some examples of their inconsistencies, contradictions and lies.
The full extent of their lies is set out in my witness statements.
D1: Lewisham Council
D2: Ralph Wilkinson & D6: Elaine Hattam
D3: Christine Grice
D4: Elaine Smith
D5: Valerie Gonsalves
D7: Kate Parsley
Lewisham Council
Background Context
| I had never received any formal warnings before I was suspended, no formal complaints had been made about me and no one had ever taken out a grievance against me.I was not fired for misconduct. Lewisham Council trumped-up some other charge against me: ‘some other substantial reason’, (whatever that means!) |
On 10 August 2011, Lewisham Council offer me £40,000 to settle my tribunal claims.
During a meeting on the same day, (which I attended with my Unison rep Jackie Lynham), Christine Grice suspended me from work. I covertly recorded the meeting.
In the course of the meeting Chrisitne Grice stated that my employment was unsustainable: she then appointed herself the investigating officer to investigate whether my employment was sustainable.
When I complained about this in writing to her, (copying in her superiors), and stating that it demonstrated bias and the fact that she had pre-determined the outcome of the investigation, she responded in writing, refuting the fact she had even made the statement that my employment was unsustainable.
At the beginning of October 2012, I sent the covert recording of Christine Grice (making the very statement that she denied making), to Lewisham Council’s legal department.
Lewisham Council’s Head of Law responded in writing, essentially stating that my covert recording didn’t prove any wrong-doing.
Lewisham Council managers (Christine Grice, Elaine Smith, Valerie Gonsalves and Kate Parsley), referred to my alleged inappropriate conduct during team meetings.
I covertly recorded all the team meetings. The recordings do not depict me acting in the manner described by them.
The Hearing Officer, (Ralph Wilkinson) was not been presented with any documentary and/or objective evidence supporting their allegations.
It is important to note that Elaine Smith, Valerie Gonsalves and Kate Parsley maintained during Lewisham Council’s internal hearing that my alleged conduct/behaviour did not warrant any complaints being made about me: (I covertly recorded this, and this is also recorded in Lewisham Council’s own official notes to the hearing); and
Indeed, that no formal complaints had been made about me, as was confirmed by Elaine Smith during the internal hearing.
I told the Tribunal that Lewisham Council and its managers defamed me: this was in relation to the claims that I withdrew in March 2013, after the Tribunal refused to allow me to rely on all my covert recordings and the High Court refused to allow me to proceed with my defamation case first.
Lewisham Council’s Employment Tribunal pleadings dated 24 July 2012 deny that they made any defamatory statements about me, yet its High Court defamation defence admits that it did defame me.
Does this mean that the Lewisham Council submitted a false statement of case to the Tribunal in relation to my claims which included the allegation that I was defamed?
You can draw your own conclusions!
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Lewisham Council’s pleadings also states that:
it proposed and/or made ‘reasonable adjustments
It also makes reference to:
addressing a disability situation
On 16 May 2011 Rita Lee, (Lewisham Council’s HR officer), sent me Lewisham Council’s Occupational Health referral form, which also set out it’s acceptance that I was disabled.
I told the Court that this was evidence of inconsistent/untenable evidence which is designed to mislead the Court and that it was evidence that the Defendants’ submitted a false statement in a document verified by a statement of truth.
Lewisham Council’s own notes of Christine Grice’s investigation interview with Elaine Smith dated 10 February 2010 states the following:
Christine Grice: What did you know about her disability?
Elaine Smith: We have the OH report which told us she had ‘reactive depression’…The report said that the reactive depression was brought on by stressful situations so we did the stress risk assessment and other forms of adjustments to support her. I think it was described as depression which was reactive to stressful situations.
Christine Grice, (the investigating officer) stated that they would continue to have difficulties in obtaining information about my condition, (which completely contradicts what Lewisham Council’s hearing officer (Ralph Wilkinson) said in relation to my disclosure of my full medical records):
…and whilst it does highlight the health problems you had.
In light of all of this, it is incomprehensible why the Defendants’ continued to refute the issue.
To top it all off, Lewisham Council then decided to use the alleged issue of ‘on-going difficulties regarding ascertaining the precise nature of my condition’, as part of the reason for dismissing me.
It is important to note that Lewisham Council and the other Defendants’ denied in their Tribunal pleadings, that their treatment of me was in any way related to my (‘whistleblowing’/protected disclosures), i.e. concerns regarding the endangerment of my health and safety and their alleged failures to comply with other legal obligations.
Lewisham Council and the other Defendants’ also denied in its Tribunal pleadings that their treatment of me was due to my disability.
Contrary to this, their particulars of justification in their defence to my defamation claim (which covers the same events), demonstrate that the treatment I was subjected to, was based on and/or related to the reasons which they had previously denied.
They stated that the treatment I received was justified and they relied on the following allegations to support this:
Her frequent unjustified and disproportionate complaints in regard to aspects of her employment’.
The inclusion of those complaints of highly personal attacks upon her fellow employees, whom she often accused of bullying, victimising and harassing her and discriminating against her on the basis of her avowed disability. Whether she was disabled or not, such attacks were grossly unfair and/or caused considerable distress to LBL/D1’s employees.’
Her tendency to react to any act or statement with which she disagreed by alleging that the person was carrying out the act or making the statement was bullying, victimising and harassing her and discriminating against her on the basis of her avowed disability. Whether she was disabled or not, such attacks were grossly unfair and/or caused considerable distress to LBL/D1’s employees.’
The Claimant’s use of her avowed disability as a lever to get her own way. When she was asked to so something she did not want to do, she would then threaten that if she were made to do it her health would be seriously damaged and allege that she was being subjected to ‘disability discrimination’. Whether she was disabled or not, such attacks were grossly unfair and/or caused considerable distress to LBL/D1’s employees.
I think that it is fairly obvious from the Defendants’ above statements that my treatment was related to my disability and whistleblowing.
Does this mean that the Defendants’ submitted false statements of case to the Tribunal in relation to my discrimination and unfair dismissal claims?
You can draw your own conclusions!
The law states very clearly that you are not allowed to be subjected to detriments or dismissal for rasing concerns in the workplace, particularly when you are covered by disability legislation.
Workers are also supposed to be protected by the Public Interest Disclosure Act (PIDA).
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D2: Ralph Wilkinson & D6: Elaine Hattam
Ralph Wilkinson (D2), was a Defendant in the case. He is Lewisham Council’s Head of Public Services.
Ralph Wilkinson was appointed as the hearing officer for the internal hearing which took place to decided whether or not I should be dismissed.
Elaine Hattam (D6), was also a Defendant in the case. She is Lewisham Council’s HR Officer and assisted Ralph Wilkinson during Lewisham Council’s internal hearing.
On 28 February 2012, during Lewisham Council’s internal hearing, Ralph Wilkinson, Elaine Hattam and Christine Grice made statements, (which was contrary to what I advised them):
She said that this was her investigation report so I believe that what I stated in that email is correct
I was essentially being called a liar in relation to my assertion that Christine Grice had stated that she had done an investigation report. They stated the following:
Ralph Wilkinson:
Well…it isn’t her investigation report…it is her script that’s used for her presentation.
Christine Grice:
That’s what I said.
Elaine Hattam:
She actually said that she didn’t do a report
Lewisham Council, Ralph Wilkinson, Christine Grice and Elaine Hattam asserted that an investigation report was not produced:
Ralph Wilkinson: I was referring to the document that CG handed out, which she used to make her presentation. It was a courtesy. It was not an investigation report
Me: I stand by what I said
Elaine Hattam: CG has said she did not do an investigation report.
Lewisham Council’s notes to my investigation interview on 4 November 2011 record Christine Grice stating that she was going to prepare a report, (I submitted this evidence to the Court).
I also advised the Court of the following facts and submitted evidence to support them:
Christine Grice had in fact advised myself, Ralph and Elaine, (and in the presence of other individuals at the hearing), on 27 February 2012 that she had done an investigation report. This was even recorded by the note-taker in Lewisham Council’s official notes.
I also covertly recorded Christine Grice making this statement. She specifically stated that the investigation report was in the bundle we had all been given.
Lewisham Council’s official internal hearing notes (which had been taken the previous day when Christine Grice made the statement), reads as follows
Me: Did you provide anyone with a copy of your investigation report?
Christine Grice: No.
Me: Did you do an investigation report?
Christine Grice: Yes, it is contained in your bundle, and the written report is my presentation, which I have just read
Christine Grice: The investigation report is in the bundle you have all been given. When we hear the case, we will know if there is anything more
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I contacted Frankie Sulke, (Lewisham Council’s Executive Director) and Kath Nicholson, (Lewisham Council’s Head of Law) to complain and advise them that my character was being defamed, but they failed to act, despite me having provided them with evidence of this.
Instead they allowed the internal proceedings to continue in the same manner.
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Lewisham Council deliberately failed to follow its own rules and allowed the defamatory statements about me to be made/published.
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D3: Christine Grice
Christine Grice (D3) was Defendant in this case: she was the person who suspended me, investigated me and recommended my dismissal.
Christine Grice was also Elaine Smith’s manager at the time when these events took place.
Christine Grice was Lewisham Council’s former Head of Access and Support, who Lewisham Council continued to legally represent until December 2013, even though she stopped being employed by them in July 2012.
Christine Grice mysteriously partied ways with Lewisham Council a few months after I revealed I had been covertly recording Lewisham Council’s managers conduct towards me.
During Lewisham Council’s internal hearing Christine Grice made the following false statement about me:
…there was a culture of fear and they were afraid of managing you
A culture developed where managers felt powerless and fearful of dealing with Adele’
During Lewisham Council’s internal hearing, Elaine Smith and Kate Parsley (senior managers) gave oral evidence. This was recorded in Lewisham Council’s official minutes) and I also covertly recorded it. I submitted both sets of evidence to the Court.
Elaine Smith and Kate Parsley contradict Christine Grice’s statement. They make it clear that in their opinion, managers were not scared / afraid of me.
These were inconsistencies and it highlights the obvious fabrication by Christine Grice.
During Lewisham Council’s internal hearing Christine Grice also made the following false statement about me:
Adele has not provided sufficient disclosure to her managers or occupational health to enable managers to understand her condition and to decide what level of reasonable adjustment may be made.
I advised the Court of the following facts which disprove Christine Grice’s statement, and submitted evidence to support this contention:
Just 2 months prior, on 20 December 2011 at 9.37, I received a letter from Rita Lee, (Lewisham Council’s HR officer). This cover was sent to me via post with a package containing Lewisham Council’s copy of my full medical records,(over 70 pages).
I had given consent for Senior managers (including Christine Grice), to have access to my records.
Lewisham Council had access to my full medical records since September 2011.
I also complied with 3 Occupational Health consultations which Lewisham Council required me to attend, which all took place within just a 6 month period.
I sent numerous e-mails setting out information relating to my condition and advising what adjustments needed to be made.
The Defendants’ took exception to these e-mails, stating that they were unjustified and they relied on this as part of their Defence.
My former employer’s (Babcock’s) tribunal pleadings, confirmed that it had sent Lewisham Council information advising it of my disability and the reasonable adjustments made:
…The information sent by e-mail on 1 April 2011 disclosed details such as the Claimant’s salary, pay date, annual leave entitlement and continuous employment start date. It also included information about the fact that the Claimant was disabled, that she suffered from depression…
All Lewisham Council had to do was refer to the risk assessment that it had received from Babcock in relation to this and have it reviewed by the Occupational Health Consultants who they arranged for me to see. But instead Lewisham Council delayed reviewing the risk assessment and then failed to implement the reasonable adjustments recommended by the Occupational Health consultants. I submitted evidence of all this to the Court.
During Lewisham Council’s internal hearing Christine Grice also made the following false statement about me:
I have heard that she would not engage in dialogue but was over focused upon writing detailed notes. I saw this behaviour in my interviews with Adele
Christine Grice had also made another statement about me in her referral form to an Occupational Health consultant- she stated that I had been talking at some speed during the investigation interviews. This referral form was included as part of her evidence during Lewisham Council’s internal hearing.
On the one hand, according to Christine Grice, I hadn’t engaged, then on the other hand, also according to her, my engagement and dialogue, was a bit too much!
The interactions during the 3 investigation interviews that I attended (and which I covertly recorded) on 25 October 2011, on 1 November 2011 and 4 November 2011, disprove her statement. This evidence was submitted to the Court.
The evidence shows that I answered endless questions totalling over 8 hours, during a 3 day period. This shows engaging in dialogue.
Christine Grice also made the following false statements about me:
Adele was not willing to attend any investigations and have her allegations investigated and put to scrutiny where appropriate
In addition, Adele has raised a number of serious complaints against her managers, yet she has refused to participate in any process seeking to investigate and resolve these issues
…she is unwilling to participate in any process which seeks to resolve her complaints
Contrary to the above, it is important to note that Lewisham Council’s response to my Equality form questionnaire states the following:
Christine Grice agreed to discuss all of your outstanding concerns, including the alleged breach of Data Protection, at your meetings on 28th and 30th June 2011. At the meetings you explained the details of your allegations. Christine Grice agreed to investigate your concerns and report to you.
On 14 July 2011, I received a letter from Frankie Sulke (Lewisham Council’s Executive Director), regarding my internal appeal. She informed me that she would treat my e-mail response to Christine Grice’s outcome on my grievance as an appeal, and that she would forward it to Ian Smith to investigate.
It is clear from this that my complaints went through Lewisham Council’s grievance procedure right up to the appeal stage.
I submitted this evidence to the Court.
The Defendants’ defence to my defamation claim, (the document which they signed as being true), relied on the fact that I sent numerous e-mails setting out my complaints’ and that they felt that this was unacceptable.
However, in the same defence, confusingly, they then assert that I did not follow through with my complaints and/or engage with them.
I informed the Court that in addition to this, my other evidence, (which I also submitted to the Court), disproved Christine Grice’s statements and the Defendants’ official line of defence.
The other evidence consisted of the following:
I met with a senior manager (Chris Threfall) on 26 April 2011 and discussed my concerns with him and sent him evidence. I covertly recorded this meeting. I submitted the covert recording and transcript to the court. I also submitted Lewisham Council’s own minutes of this meeting
I met with Christine Grice and Elaine Smith (another senior manager and Defendant in the case) on 28 and 30 June 2011 to discuss my concerns. I also covertly recorded the meeting on 30 June 2011. I submitted the covert recording and transcript to the court. I also submitted Lewisham Council’s own minutes of the meetings on 28 and 30 June 2011.
I attempted to meet with Valerie Gonsalves on numerous occasions, but she avoided those meetings.
In addition, I met with Elaine Smith on 5 and 20 July 2011. During these meetings I discussed my concerns. I also covertly recorded the meetings. I submitted the covert recordings and transcripts to the court. I also submitted Elaine Smith’s own minutes of the meetings on 20 and July 2011.
I attended Team managers (the managers/defendants’ attended). At these team meetings, I contributed and offered solutions in relation to any concerns that I had. I covertly recorded these team meetings. I submitted the covert recordings and transcripts to the court. I also submitted Lewisham Council’s own minutes of the team meetings.
I contacted Lewisham Council’s Executive Director (Frankie Sulke) and it’s Chief Executive (Barry Quirk) via e-mail and letter, on numerous occasions in order to try to resolve issues. I submitted this evidence to the Court.
I sent e-mails to managers regarding issues, attaching evidence and offering solutions. This evidence was also submitted to the Court.
I also attended three internal hearings at Lewisham Council, where I submitted over 300 pages of evidence, which included my correspondence with managers that sought to try to resolve issues. This was of course ignored.
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During Lewisham Council’s internal hearing Christine Grice also made the following false statement about me in relation to a meeting I attended with her, Elaine Smith and my union rep:
Despite the fact that I had asked her not to, Adele continued to copy her e-mails to Frankie and Barry
The interaction during meeting I attended, (which I covertly recorded), Christine Grice’s own notes to that meeting, and my union rep’s notes to the meeting clearly shows that she did not ask me not to copy e-mails to Frankie and Barry. I submitted this evidence to the Court.
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D4: Elaine Smith
Elaine Smith (D4) was a Defendant in this case and Lewisham Council’s Head of Positive Activities for Young People and Joint Interim Head of Youth Support Services at the relevant times when these events took place.
Elaine Smith line managed me for only 1 month before I was suspended. Her line manager was Christine Grice.
I have evidence that another member of staff made a complaint about Elaine Smith.
Background Context
A few weeks before I was suspended, during the meeting with Christine Grice and Elaine Smith, (which was also attended by my union rep and which I covertly recorded), I requested mediation for myself and Elaine Smith.
In response she stated that she did not know why I felt that mediation was required and Christine Grice also questioned why we needed it.
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Lewisham Council had all this information at its disposal during the internal hearing, because the Elaine Smith admitted that she had asked me this question.
I also submitted this information and the covert recordings of the meetings to the High Court.
On 30 June 2011, I attended a meeting with Elaine Smith and Christine Grice, which I covertly recorded.
It is clear from the recording and transcript that the statement later made by Elaine Smith during Lewisham Council’s internal hearing in February 2012, (asserting that Valerie Gonsalves had regular face to face one to ones with me) was false.
During my meeting with Elaine Smith and Christine Grice on 30 June 2011, I had informed them that Valerie Gonsalves had failed to hold regular face to face meetings with me.
I asked Christine Grice why I had not received supervision from Valerie for over a month, and she simply informed me, ‘I am not here to answer your questions’.
My Unison rep (Jackie Lynham’s) notes to the meeting also record her saying this to me.
I had also provided the hearing officer with copies of e-mails that I had sent to management regarding their failures to hold regular supervision. This evidence was ignored during Lewisham Council’s internal hearing.
Elaine Smith also made the following false statement about me in response to Christine Grice’s question about Elaine’s supervision meeting with me on 20 July 2011, (which I covertly recorded). This was submitted as evidence for Lewisham Council’s internal hearing.
…she wouldn’t really expand on her responses to any of the questions I was giving her. If we asked her for additional information then she could often be obstructive in providing that information.
During the meeting in question, I fully engaged with Elaine Smith, so much so, that Elaine Smith raised it as an issue with the hearing officer, stating that I had asked her to stay longer at the supervision meeting so that we could continue the discussion and that she felt that this was unreasonable of me to expect this.
I submitted the relevant covert recordings and documentary evidence to the High Court.
Elaine Smith also made the following false statement about me:
I did not instruct her not to work from home
The above statement was set out in Elaine Smith’s e-mail to Christine Smith, on the day I was suspended and the e-mail was included in evidence submitted by Christine Grice, (the investigating officer) for Lewisham Council’s internal hearing.
I had advised Christine Grice and the hearing officer (Ralph Wilkinson) that Elaine Smith had stated that I could not work from home.
Elaine Smith’s own statement, (which was submitted as part of the evidence for Lewisham Council’s internal hearing) states clearly that she rejected my request to work from home, more than once.
Lewisham Council ignored this clear evidence that the statement Elaine Smith’s made about me was false.
Elaine Smith gave a conflicting account of the circumstances surrounding her contact with Marina Waters, (the Occupational Health consultant who Lewisham Council arranged for me to see).
Elaine Smith met with Marina Waters, (before Marina Waters met with me), in order to discuss me, without my consent or knowledge.
Elaine Smith advised me that Marina Waters had specifically requested a meeting with her to discuss my case- because Marina Waters’ allegedly had concerns about the stress risk assessment that she was going to do on me, (I recorded this conversation I had with Elaine) and Elaine also recorded this in her notes for the supervision.
Contrary to the advise I was given by Elaine Smith, Marina Waters stated in her witness statement to Lewisham Council dated 10 August 2011, (before Lewisham Council’s internal hearing), that she was unsure why Elaine Smith stated that she had requested a meeting with her (and informed me that this was the case) and that this was clearly incorrect and unhelpful.
Marina Waters added that she can advise that she did not ask anyone to arrange the meeting and she was unsure prior to meeting Elaine Smith, who or what she would be discussing.
I provided the hearing officer with a copy of Marina Waters statement and Elaine Smith’s supervision notes, and once again, this evidence was ignored.
I also provided the High Court with this evidence and a copy of my covert recording of my meeting with Elaine Smith, which depicts her providing me with the false information.
Elaine Smith made the following false statement about me during Lewisham Council’s internal process, (in relation to a question from Christine Grice asking whether I saw young people face to face):
She did not see any….She had no face-to-face meetings in 4 months
I presented evidence of my face-to-face meetings with young people to Elaine Smith, during my supervision meeting with her on 20 July 2011, (I also covertly recorded this meeting with her). This evidence was also submitted to the High Court.
Elaine Smith also made the following statement about me during Lewisham Council’s internal process:
She would not give us her job description
As my employer, Lewisham Council shoul have and would have already had a copy of my job description, which it would have obtained from my previous employer when I transferred.
No manager had ever asked me for a copy of my job description.
However, nearly a year before Elaine Smith made this false statement about me, I had e-mailed several managers, (including Elaine Smith), a copy of my job description, without ever having been asked for it, and Lewisham Council managers and HR acknowledged receipt of it.
Elaine Smith made the following statement to Christine Grice during her investigation interview with her, and this was submitted as evidence for Lewisham Council’s internal hearing:
If she could not manage communication with her adult colleagues I do not see how she would be able to communicate with a vulnerable young person.
I have a BA (Hons) degree in Communication Studies, which Lewisham Council and its managers were aware of.
Before Elaine Smith made this statement, just 3 months prior, Christine Grice had made the following statement, in her Occupational Health referral for me:
Adele takes detailed notes during meetings with managers and communicates with management frequently through long e-mails.
This Occupational Health referral form was included in the evidence that Lewisham Council managers relied on during Lewisham Council’s internal hearing. The hearing officer ignored the contradiction.
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D5:Valerie Gonsalves
Valerie Gonsalves (D5) was a Defendant in this case and Lewisham Council’s Team Leader at the relevant times when these events took place.
Valerie Gonsalves was also my line manager for a brief period of time when I first transferred to Lewisham Council in April 2011, and she had only 1 supervision meeting with me. Valerie Gonsalves ceased to have any contact with me as a line manager in May 2011.
During Lewisham Council’s internal hearing in February 2012, Valerie claimed that during my employment at Lewisham Council, 85% of her time was spent ‘seeking advice about me’, (someone who she barely had any contact with).
Valerie Gonsalves was line managed by Elaine Smith.
I have evidence that other members of staff had also made complaints about Valerie Gonsalves and I submitted some of this evidence during Lewisham Council’s internal hearing.
Despite having submitted this evidence, Christine Grice falsely claimed that no other member of staff had made complaints.
Valerie Gonsalves was questioned by Christine Grice, as part of the investigation process after I was suspended.
On 17 November 2011, when questioned by Christine Grice, Valerie Gonsalves stated the following in response to Christine Grice’s question:
‘Did she say you were not capable?’
Valerie:
Yes. On one occasion, while doing the workstation assessment actually
Valerie Gonsalves also made the following false statement about me:
AV said that I was not capable as a manager
During Lewisham Council’s internal hearing I questioned Valerie about this statement, and asked her the following:
You have stated that during a workstation assessment which you undertook, that I stated…to your face that you were not capable. Do you still stand by that?
She replied:
Yes I do
Unbeknown to Valerie, I had covertly recorded the entire workstation assessment meeting I had with her. It is clear from the recording and transcript that I did not make the statement she claims I made about her.
Valerie Gonsalves also made the following statements about me (AV)- in relation to how I allegedly conducted myself during a team meeting, where a guest speaker named Lillian attended:
As soon as Lillian started speaking AV went into attack mode
but erm as soon as Lillian started her presentation Adele kind of jumped all over it
In reference to my alleged conduct during that same team meeting, Valerie Gonsalves made the following statement to me and several other people, (including the hearing officer and the external note-taker) during Lewisham Council’s internal hearing:
Can we be really clear here…I didn’t take issue, your colleagues took issue and they shouted you down…I was sitting in the meeting.
No such interaction took place in the manner described by Valerie Gonsalves.
I hardly spoke during the meeting and my two colleagues both addressed the guest speaker before I did.
Unbeknown to Valerie, I had covertly recorded the team meeting with the guest speaker and it is clear from the recording and transcript and Lewisham Council’s notes to this team meeting that her statements about my alleged conduct are false.
I submitted the covert recording and transcript and Lewisham Council’s own minutes to the team meeting to the Court.
Valerie Gonsalves also made the following statement about me to Christine Grice during the investigation interview:
She would sit back in her chair busy taking notes. She would not be involved in discussions’
I clearly engaged in team meetings and I covertly recorded my interactions during the team meetings I attended on 8 June 2011, on 21 June 2011, and on 13 July 2011, (this evidence was submitted to the Court and highlighted in my witness statements)
Lewisham Council’s minutes to team meetings also record me as being involved in discussions. I submitted this evidence to Lewisham Council for the internal hearing which took place in order to highlight the lies which were being told by managers about me. However, this evidence was ignored.
It is important to note that the statement Valerie makes accusing me of not engaging in team meetings is actually contrary to the earlier false statement she made about me to Christine Grice during her same investigation interview with her, in which she claimed I was ‘dominating’ the team meeting on 13 July 2013.
I guess she just couldn’t make up her mind which lie she wanted to go with!?
Valerie Gonsalves implied that I was incompetent:
I do not know her to be a competent worker. That did not come across to me
Valerie Gonsalves also stated:
She wouldn’t meet face-to-face with any young person…..very poor work output’
There is no evidence of the work she was doing
I had never had never received any complaints about my work or performance.
Lewisham Council’s official letter informing me that there would be an internal hearing, did not state that this was one of the charges against me and/or an issue.
The hearing officer advised me that I was not investigated for capability, (he is depicted sating this in my covert recordings and in Lewisham Council’s own notes to the hearing).
When an employee has poor work output, the employer invokes the Capability Procedure, but this did not happen in my case.
I had never been informed formally under the disciplinary procedure, (verbally or in writing – as is my right), of any concerns regarding my performance- because there were none!
Valerie could have easily checked/collated evidence of my work through her own efforts, which simply would have involved accessing the database that we all used.
The Defendants had evidence of my work in their possession.
During Lewisham Council’s internal hearing I supplied extensive documentary evidence of my work and am clearly depicted in the recordings evidencing my work.
I made a very specific statement in relation to this issue, (which is evidence by my covert recording of the internal hearing):
Now part of running a service properly is being able to adequately monitor the work of your team i.e. key workers. Now these two managers have both stated that I wasn’t doing any work and I’ve provided evidence that shows clearly I was working very hard, so that’s a systemic issue when they can’t even get information to support their allegations that i.e. I’m doing no work.
When I tried to address these false allegations during Lewisham Council’s internal hearing, by questioning Valerie about them, the hearing officer (Ralph Wilkinson) prevented me from doing so and advised me that I was not being investigated in relation to this and that Valerie’s statements regarding this served no purpose.
| Despite all of this, during Lewisham Council’s internal hearing, the Defendants’ had long discussions regarding my alleged poor work output. I submitted clear evidence to the Court which disproved the allegation of incompetence. |
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D7: Kate Parsley
Kate Parsely (D7) was a Defendant in this case and Lewisham Council’s Head of Teenage Pregnancy and Joint Interim Head of Youth Support Services at the relevant times when these events took place.
On 1 July 2011, I had an advanced workstation risk assessment undertaken by an external consultant (Belinda Whippey). I covertly recorded my meeting with her.
During the assessment, I did not make any objections to the assessment being done.
During Lewisham Council’s internal hearing, Kate Parsley told the hearing officer, that Belinda Whippey told her that I told her that I didn’t need the assessment done.
This is clearly false, as my covert recording and transcript proves. I provided the High Court with a copy of the covert recording and transcript.
During the assessment Belinda Whippey and Kate Parsley spoke on the telephone in my presence and Belinda Whippey merely told Kate Parsley that there was a slight problem over whether what she was doing was the right thing for me, because her company just does the workstation assessments, rather than my other issues.
Belinda Whippey then confirmed with Kate Parsley that it was okay to proceed.