The Billy Wright Inquiry Oral Hearings

Hearing: 2nd July 2008, day 83

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BILLY WRIGHT

PUBLIC INQUIRY

 

 

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held at:

The Court House

Banbridge

County Down

 

on Wednesday, 2 July 2008

commencing at 10.00 am

 

Day 83

 

 

 1 Wednesday, 2nd July 2008

2 (10.00 am)

3 MR DONALD McCALLUM (cont.)

4 THE CHAIRMAN: Morning, Mr McCallum. Can I remind you that

5 you are still on oath.

6 Mr Hunter?

7 Questions from MR HUNTER

8 MR HUNTER: Thank you, my Lord.

9 Mr McCallum, I represent Raymond Hill, who was the

10 officer who was stood down from the A/B tower. First of

11 all, can you confirm, are you aware or were you aware

12 that he was, in fact, stood down from the A/B tower on

13 two occasions on the morning of 27 December?

14 A. I can't really say.

15 Q. Can I refer you, first of all, to WS074-0045? If that

16 can be put up on the screen, please. Can I inform you

17 that this is part of the statement to the police made by

18 Mr Hill in the immediate aftermath of the murder. This

19 was his police statement. You will see there, about

20 a third of the way down, he indicates:

21 "On 27 December 1997 at 8.15 am I started duty at

22 H6. I reported to the PO's office in the staff area.

23 I then went to the Block Control Room and drew the keys

24 [entered the tower]."

25 About halfway down you will see there:

1
 1 "At about ten minutes to nine I received a call on

2 my intercom to come down from the tower and report to

3 the PO's office."

4 Do you see that?

5 A. Yes.

6 Q. Does that surprise you, that at 8.50 an officer was

7 being stood down or asked to come down from that tower?

8 A. Well, it sort of does, because, I mean, my recollection

9 is that it was around 9 o'clock I went up to

10 Governor McKee to seek standing the towers down, you

11 know. So that would be -- I mean, that would be a wee

12 bit earlier than what I ...

13 Q. This is actually the first time this man is stood down.

14 A. Uh-huh.

15 Q. I am going to come to the second time in a moment. You

16 are not aware of any order going from your office or any

17 instruction from your department, before your

18 discussions with Governor McKee, to stand this man down?

19 A. No.

20 Q. Am I correct in assuming, as per your evidence

21 yesterday, that someone will only be stood down on

22 receiving the word from you to the Block Control Room

23 and then to the tower? Isn't that right?

24 A. Well, it should be through the line manager in the

25 block.

2
 1 Q. Sorry. Yes. Through the line manager in the block.

2 But that instruction should come from you and from

3 no-one else, you having discussed that matter with the

4 Governor, your line manager, as it were.

5 A. Yes, but I also said yesterday that local managers had

6 a tendency to do their own things too.

7 Q. And you wouldn't necessarily know anything about that.

8 A. No.

9 Q. You will then see that he said:

10 "I did as I was told, but at the main gate of H6

11 I was informed by one of my colleagues that there had

12 been a charge of heart and I was to return to the tower.

13 I returned to the tower."

14 Do you see that?

15 A. Uh-huh. Yes, I do.

16 Q. You will see then what he says, and I wish to explore

17 the timings with you. He then says:

18 "At approximately 9.30 am I was again contacted via

19 intercom and told to report to prison visits."

20 You will see he goes on to deal with the question

21 then of the discussion of contacting Officer Blundell of

22 the POA.

23 Yesterday, in relation to times, if I can refer

24 you -- your first reference to time in relation to the

25 contact from the POA at draft page 134, line 8, [final

3
 1 133/3] you indicated it was 9.15, some time around then.

2 The timings you have, Mr McCallum, were you checking

3 a watch or is that a guestimate or what is it?

4 A. We were quite aware of timings. I wasn't obviously

5 watching the clock all the time, but the priority was to

6 have the visits opened early on a Saturday. So the

7 priority was to get it sorted as soon as possible.

8 Q. Can you be precise about times? Is that a guess or was

9 there a wall clock or did you check a watch?

10 A. Well, there is a clock in my office, but that's the

11 times that were in my head. I mean, I may be slightly

12 off by a minute or two. It wouldn't be precise timings.

13 Q. If I suggest to you that possibly it could have been

14 nearer 9.30 than 9.15.

15 A. No. The way I remember it, it was nearly done and

16 dusted by around 9.30. As I said yesterday, maybe

17 a few minutes before, a few minutes after.

18 Q. You see, your second reference as regards times, from

19 yesterday's transcript, was at draft page 137, line 6,

20 [final 135/4] where you were asked:

21 "What time would it have been that you told

22 Mr Gallagher that the towers should remain manned?"

23 Your indication was:

24 "Approximately 9.30, maybe a few minutes before or

25 a few minutes after."

4
 1 A. Yes.

2 Q. Again, how precise is that? Is that a rough time or is

3 there anything which ties that with precision to that

4 time in your mind?

5 A. Well, I mean, that's the way I remember it, around 9.30,

6 you know.

7 Q. Because again can I refer you to the page that's up on

8 the screen?

9 A. Uh-huh.

10 Q. Where Mr Hill's evidence will be, if you see there

11 two-thirds of the way down, he says:

12 "I contacted Officer Blundell of the Association

13 from the PO's office in H6 by phone. Mr Blundell told

14 me to sit tight whilst he spoke to the Duty Governor."

15 Then he says:

16 "Around five or ten minutes later Mr Blundell

17 returned my call and advised me that they were going to

18 reassess the situation. At around 9.50 am SO Witness BP

19 [I think that's Officer Gallagher] informed me to return

20 to the tower."

21 He then returns to the tower at that time. The word

22 only comes through to him, it would appear, shortly

23 before 9.50 am.

24 A. Yes. Well, I wouldn't agree with that.

25 Q. Uh-huh. But again, are your timings in any way precise

5
 1 at all?

2 A. As precise as they can be.

3 Q. Uh-huh. If we then explore some of the evidence that

4 the Inquiry has already heard. Governor Barlow

5 indicated that he had the phone call from Mr Blundell

6 about 9.25 am. His indications are he gets the Blundell

7 phone call at about 9.25, not around 9.15. You are not

8 able to comment on that?

9 A. No.

10 Q. In relation to timings again, Governor McKee indicates

11 in his statement, and I assume it to be his evidence,

12 that the decision to stand down the towers except H6

13 were at 9.30 am and not about 9.15.

14 A. Well, my recollection is it was earlier than that.

15 Q. Uh-huh. Again, from his statement Governor McKee

16 indicates he was in his own office about 9.30 am when

17 Mr Blundell burst in. Again, those timings, none of

18 that assists you in any way with your recollection,

19 Mr McCallum?

20 A. No.

21 Q. As regards Mr Blundell and his statement, if we can have

22 it up on the screen, WS008-0027, and if we could bring

23 up paragraph 75, please, you will see there that

24 Mr Blundell in his statement says:

25 "Later in the morning I received a phone call from

6
 1 Officer Ray Hill telling me he had been stood down

2 a second time from his post in the A and B watchtower of

3 H Block 6. He had got as far as the gate before being

4 told to turn around and return to the tower."

5 So again there is Mr Blundell indicating that

6 Officer Hill had been told not once but twice to come

7 down.

8 A. Uh-huh, yes.

9 Q. But again, as far as you are concerned the only

10 instruction that came from your Control Room was that

11 only once was he to be stood down. Is that right?

12 A. That's correct.

13 Q. You see, in relation to the timeline, if I use that term

14 from Mr Hill, his evidence will be that he is called

15 down at 9.30. At about 9.50 he is informed to return

16 back up the tower. He is in the tower around about 9.55

17 and then he sees the murderers coming back over the

18 wall, back into the yard a few minutes later. So again

19 could I suggest that that timing perhaps would maybe

20 suggest that the timings he suggested were more likely

21 than the times that you have given us for those various

22 phone calls and contacts?

23 A. Well, I can't comment on that.

24 MR HUNTER: Thank you.

25 THE CHAIRMAN: Mr Dunn?

7
 1 MR DUNN: No questions, my Lord.

2 THE CHAIRMAN: Mr O'Connor?

3 Questions from MR O'CONNOR

4 MR O'CONNOR: Thank you, my Lord. I appear on behalf of

5 Mr McKee, who would have been the Acting Governor at the

6 time of this incident on this morning.

7 I just want to take you to your statement at

8 WS124-0015. If that could be called up. Paragraph 43.

9 You say you went to Governor McKee's office. Would

10 that have been standard procedure on that particular

11 morning? Would it have been standard procedure for you

12 to go to the office to appraise him of the situation in

13 relation to staffing levels, etc?

14 A. Usually.

15 Q. So this was a routine visit for you then?

16 A. Not this one, no.

17 Q. But it would be usual for you to go to the office to

18 appraise him, say how many staff were short, etc?

19 A. It depended what Governor was on. Some Governors liked

20 me to give them a brief of what the state of the prison

21 was in and some didn't.

22 Q. What about Mr McKee?

23 A. I can't really remember, but on this occasion I went up

24 to see him specifically for a reason.

25 Q. So you went into him on this particular day. Who else

8
 1 was in the room?

2 A. I can't remember anyone else being there.

3 Q. Is that to say there was nobody else there or is it

4 simply you can't remember?

5 A. Well, I can't recall, so there wasn't anybody else there

6 in my mind.

7 Q. In relation to the conversation that occurred, you

8 indicated you accepted that you said to him

9 something along the lines of, "Governor, the prison is

10 up and running but we're eight posts down in the

11 visits".

12 A. Well, I would have said to him, "The visits aren't going

13 to open". That was the crisis, that the visits weren't

14 going to open, and you needed to get the visits open,

15 especially on a Saturday, as early -- as soon after

16 8 o'clock as possible, because the visitors arrived very

17 early on a Saturday.

18 Q. So is it the case that you actually remember

19 specifically the exact conversation with Governor McKee

20 at that time?

21 A. No. It is nearly going on 11 years now. No.

22 Q. Because yesterday you said that your memory was quite

23 vague --

24 A. Uh-huh.

25 Q. -- as to what exactly the contents of the conversation

9
 1 was.

2 A. Yes.

3 Q. But you accepted that you probably would have said to

4 him along the lines that you were eight persons down and

5 that you needed eight people for the visits.

6 A. No, I would have said to him that the PO in charge of

7 visits is not opening the visits unless he gets more

8 men. That was the crisis that morning, at that time.

9 Q. In your statement yesterday you were asked to explain

10 why in your police statement at WS124-0013 you stated:

11 "Governor McKee then told me to close both H6 yard

12 towers and send both men over to visits."

13 Can you remember exactly what the police asked you?

14 Did the police simply ask you what was the conversation

15 and what did Governor McKee say to you, or can you

16 simply just not remember?

17 A. To be honest, I can't remember giving the police the

18 statement at all.

19 Q. But your explanation yesterday was that you thought that

20 really the police focused on the H6 yard towers, as the

21 inquiry was about the death of Billy Wright in H6, so it

22 was all about H6. That was your explanation given

23 yesterday.

24 A. Yes.

25 Q. But your evidence when pushed on the point was that, in

10
 1 fact, Governor McKee had told you to stand all towers

2 down.

3 A. All the yard towers, yes.

4 Q. There was a slight area of confusion then arose

5 yesterday. Was it rare for the towers to be dropped?

6 I think at WS124-0012, at paragraph 29 of your statement

7 you stated that it would have been rare for all the

8 towers to have been dropped.

9 A. Yes. I think I said on occasions they would have been

10 dropped.

11 Q. I think --

12 A. Well, that's in the context that in my position we were

13 dropping posts all the time, every day, daily.

14 Q. I think when you were shown the document NP31-0043, in

15 fact you accepted that, indeed, you were incorrect in

16 that assertion and really, in fact, both A and B, and C

17 and D towers from the H6 block had been dropped on

18 a regular basis, yesterday. Isn't that correct?

19 A. Well, this document here, I mean, I was thinking about

20 this last night. I can't recall ever seeing a document

21 or ever producing this document.

22 Can I describe ... we inputted the day after what

23 posts were dropped throughout the prison. It was

24 inputted into the system. We did a back-up after the

25 week and that was sent to the Northern Ireland Office.

11
 1 They ran the computer system. To be quite honest,

2 I can't recall having seen something like this before.

3 That's a spreadsheet, I assume. I mean, I can't recall

4 now, but we certainly would have collated the

5 information or inputted the information into the

6 computer system daily for the day previous. Then after

7 the week had been inputted, there was a back-up done and

8 it was sent to the Northern Ireland Office and they did

9 all the ... so I assume -- I mean, I don't know where

10 that was produced from. No-one has been able to tell me

11 where that came from, that document.

12 Q. Just to clarify this point, I think it is an important

13 point, that yesterday you had -- once this document was

14 shown to you, ultimately you accepted that really that

15 showed that indeed both the A and B, and C and D towers

16 from H Block would have been dropped together on

17 a regular basis.

18 A. Yes.

19 Q. Are you standing by that or is your evidence now that it

20 is still your evidence that it would have been extremely

21 rare for both of those, in fact any of the towers, to be

22 dropped?

23 A. You are showing me some of it, so ... I mean, over the

24 year how many times had it been dropped? I don't know.

25 I mean, in my mind, because my job was dropping posts

12
 1 daily, that's why say yard towers weren't dropped

2 frequently. They were infrequently dropped. You know,

3 maybe my understanding of "frequently" and

4 "infrequently" is different from others, because my job

5 was dropping posts every day.

6 Q. Would it be fair to say that when you spoke to

7 Governor McKee at that time, you would have been

8 extremely surprised by him saying to you to drop the

9 towers, drop the posts of the towers?

10 A. No. As I said earlier, the visits weren't going to

11 open, and it was quite a contentious area of the prison

12 and we needed to get them open. So we needed to find

13 men from somewhere.

14 Q. Well, if I take you back, you have accepted that, in

15 fact, your recollection of the conversation with

16 Mr McKee at that time is vague, the exact conversation.

17 You have indicated that to your memory you can't

18 remember or recall anybody else being present at that

19 meeting, at the first meeting.

20 If I could refer you to WS130-0023, paragraph 62.

21 THE CHAIRMAN: I don't think it has been put up. Would you

22 repeat it again?

23 MR O'CONNOR: WS130-0023.

24 THE CHAIRMAN: No. It doesn't register up there somehow.

25 MR O'CONNOR: It is Mr McKee's statement. I am sorry.

13
 1 That's the only reference I have at the bottom of the

2 page.

3 THE CHAIRMAN: We will get it. We can wait for it.

4 MR O'CONNOR: I am obliged, my Lord.

5 MR MACLEOD: It does appear to be at WS130, my Lord, the

6 statement, so it should be capable of being brought up

7 on the screen.

8 THE CHAIRMAN: So it is WS ...

9 MR MACLEOD: 130.

10 MR FORTT: The Inquiry was given a hard copy rather than the

11 police witness statement form of Mr McKee. It may be on

12 the disc.

13 MR O'CONNOR: I believe there may be a difficulty that it

14 may not be on the disc. Perhaps, if we can proceed by

15 me reading the extract, if that would be suitable.

16 THE CHAIRMAN: And lo, what's on the screen?

17 MR O'CONNOR: That's a police statement, my Lord.

18 THE CHAIRMAN: What you are looking for is Governor McKee's

19 own statement.

20 MR O'CONNOR: Yes, paragraph 62.

21 THE CHAIRMAN: Proceed. Read it out.

22 MR O'CONNOR: I am obliged, my Lord. At paragraph 26

23 Mr McKee will state:

24 "I was with Brian Barlow. I recollect I was sitting

25 at my desk and Brian Barlow was silting to my left-hand

14
 1 side."

2 So he is quite specific about that.

3 Paragraph 64:

4 "Donald McCallum came in. He said to me, 'Governor,

5 the prison is up and running but we're eight posts down

6 in the visits'."

7 You have accepted that you would have said words to

8 that effect, but you can't exactly remember the whole

9 conversation and that you can't recall whether or not

10 anyone else was in the room. Could it have been that

11 really your recollection during this routine visit that

12 Mr Barlow was in the room?

13 A. No, I don't think so, because, I mean, Brian Barlow is

14 a pretty large character and if he was sitting beside

15 Governor McKee he would have been -- as far as I can

16 remember, it was just Governor McKee and myself whenever

17 I went up to tell him visits weren't going to open.

18 Q. In paragraph 65 Mr McKee will state:

19 "I said to him [speaking to you], 'Okay, Donald,

20 stand down the towers but leave H6'. Those were the

21 exact words that I used. I am 100% positive that that

22 was what I said."

23 Could it have been -- given that you've given

24 evidence today that your recollection of the

25 conversation is vague -- that you simply made a mistake

15
 1 or misheard Mr McKee when he said that last phrase "but

2 leave H6"?

3 A. No, I remember him saying, "Close the yard towers".

4 Vague or not, it was the yard towers.

5 Q. Yes, but that's quite a short phrase, "but leave H6".

6 Could it have been something you just missed or just

7 can't recall?

8 A. I don't think so.

9 Q. You didn't raise any question or query to this, though.

10 A. Sorry? I don't quite understand.

11 Q. Do you remember did you raise any query or any question?

12 Did you question Mr McKee at that time when he said to

13 stand down all the towers?

14 A. No.

15 Q. Well, if I could then refer you to your statement at

16 WS124-0015, paragraph 43. In the latter half of that

17 paragraph you state:

18 "I have been asked whether I recall Governor McKee's

19 instructions, for example, whether he said to drop all

20 towers or just H6 towers. I do not recall, but the

21 statement refers to H6 towers."

22 I believe you are referring to your police

23 statement:

24 "However, I believe I would have been told to stand

25 down all towers."

16
 1 You have stated in that statement that you do not

2 recall.

3 A. Yes. My memory is vague, but ...

4 Q. So if you do not recall whether or not specifically it

5 was in relation to all towers or just the H6 towers,

6 would it not also be fair comment that you could have

7 been mistaken in relation to the phrase "but leave H6",

8 which Mr McKee will say he said to you?

9 A. I don't think I was mistaken.

10 Q. But in your actual statement you state that you do not

11 recall exactly what was said. Isn't that correct?

12 A. That's that my statement says, yes.

13 Q. How many staff were actually posted in the various

14 towers that day overall? Can you remember?

15 A. I can't remember.

16 Q. Would it have been ten or more or fifteen or more

17 or ...?

18 A. I assume they were all manned but, as I said yesterday,

19 I mean, H6 as an example, I went to stand the two towers

20 down and one had already been stood down and I didn't

21 know anything about that. So, you know ...

22 Q. Would it have been possible, though, to source the eight

23 staff required for the visits from the other towers

24 without actually having to stand down H6 tower, either A

25 and B or C and D?

17
 1 A. I don't know.

2 Q. In any event, you gave evidence yesterday, at I believe

3 draft page 132 line 19 [final 131/5], that the first

4 tower contacted by you was H6 as they were next on the

5 list, and you spoke to SO Gallagher, although after

6 questioning by Mr O'Donoghue QC you accepted it may not

7 have been Senior Officer Gallagher, it may have been

8 someone else.

9 You stated very shortly afterwards that the POA were

10 on the phone and they had instructed the staff to stay

11 put in the block and that they shouldn't be stood down.

12 You indicated that John Blundell communicated that to

13 you.

14 So are you actually aware as to whether any officers

15 actually physically left the tower, or is it the case

16 that the men were never actually stood down due to

17 John Blundell's intervention?

18 A. I can't say, not being down at H6, what went on.

19 Q. But you go on in your statement at WS124-0016, which is

20 the following page, paragraph 47, to state:

21 "I told John Blundell that I would inform

22 Governor McKee that he had told H6 staff not to stand

23 down the tower."

24 In that same paragraph you state:

25 "At this subsequent discussion were Governor McKee

18
 1 and John Blundell and maybe Jim Duffy. I am not sure if

2 Jim Duffy was there but I think he was involved at some

3 stage. I cannot recall the conversation but it

4 concluded with the decision to man the towers."

5 That was obviously a discussion that you were

6 involved in, but could there have been other discussions

7 and other meetings between your first meeting with

8 Mr McKee and this subsequent discussion that you weren't

9 aware of?

10 A. I don't know.

11 Q. But it is possible there could have been other

12 discussions and other meetings; just simply you were not

13 party to them and not aware of them?

14 A. Obviously, yes.

15 Q. Once again there is an issue as to who exactly was

16 present. You are not completely sure as to who was

17 present at that meeting. Isn't that correct? You are

18 not completely sure whether or not Mr Barlow was

19 actually there.

20 A. I'm not totally sure.

21 Q. It was put to you yesterday that Mr McKee will say that

22 "H6 is not stood down, and if it's stood down, get it

23 back on right away". You responded by saying:

24 "I can't really remember the exact words, but I

25 certainly remember coming back down into my office and

19
 1 saying that, 'He's telling porkies up there'."

2 By "porkies" obviously you meant he was telling

3 lies, essentially.

4 A. Yes.

5 Q. Who did you say that to?

6 A. I think it was the officer or whoever it was in my

7 office when I got back down.

8 Q. Who was that?

9 MR MACLEOD: May I just interrupt there? It may be this is

10 an officer who has not yet had the opportunity to apply

11 for anonymity. So if the witness could be asked to

12 write down the name, that might assist the Inquiry.

13 THE CHAIRMAN: Right.

14 MR MACLEOD: My Lord, I am informed by the gentleman sitting

15 to the witness' left that this person doesn't appear on

16 the cipher list. Accordingly, he will have to be given

17 a letter. I don't think we have used the letters ZZZ

18 yet, so perhaps the witness can be given that rather

19 inelegant pseudonym.

20 THE CHAIRMAN: All right.

21 Yes, Mr O'Connor.

22 MR O'CONNOR: I am much obliged, my Lord.

23 In any event, I think the crux of your evidence

24 yesterday was that you came back down to the office and

25 you remember thinking that you were not terribly

20
 1 pleased.

2 Did you raise any issue in relation to this matter

3 at that time?

4 A. No, I don't think so. With whom? What do you mean,

5 raise an issue?

6 Q. With anyone. Surely, if your evidence essentially is

7 that you were aggrieved by the fact that it was now

8 being stated that the H6 block should not have been

9 stood down, and your evidence is that you were told it

10 should be stood down.

11 A. Well, I am sure I discussed or mentioned it to people

12 that I wasn't best pleased, but then, I mean ...

13 Q. Did you discuss it with Mr McKee?

14 A. I can't really remember but, I mean, everybody knew what

15 Billy was like, you know.

16 Q. Did you not raise it because you thought that perhaps

17 you had made a mistake and that you had missed the fact

18 that Mr McKee had said to you, "but leave H6"?

19 A. No.

20 THE CHAIRMAN: Can I ask you who Billy is? You said

21 everybody knew what Billy was like.

22 A. Yes, my Lord.

23 THE CHAIRMAN: The reference is to ...?

24 A. Well, he tended to make up stories.

25 Q. But who was Billy?

21
 1 A. Oh, Governor McKee.

2 MR O'CONNOR: Once again you have said that your memory of

3 the second meeting is again quite vague. This second

4 meeting, who exactly was present at that meeting?

5 A. The second meeting?

6 Q. Yes, the one that you said you left and you felt

7 aggrieved.

8 A. I can't really remember. Brian Barlow was hovering

9 about, certainly, at that stage.

10 Q. Who else?

11 A. Possibly John Blundell. I'm not sure entirely.

12 Q. So you are not sure exactly who was at that meeting?

13 A. Well, not really, no.

14 Q. Could it be that your actual memory of this second

15 meeting is entirely vague and that really this was not

16 a point put to you directly by Mr McKee, but rather it

17 was a point put to you by Mr Blundell?

18 A. What point would that be?

19 Q. Unfortunately Mr McKee's statement is not available

20 online, but I refer you to paragraph 73 of Mr McKee's

21 statement. Although he has not given evidence yet, he

22 will say:

23 "Nor was Donald McCallum present when John Blundell

24 spoke to me."

25 THE CHAIRMAN: Can I interrupt you? I think we now have the

22
 1 statement.

2 MR O'CONNOR: If I can have WS130-0024, paragraph 73.

3 "Nor was Don McCallum present when John Blundell

4 spoke to me. I did not speak directly to Don McCallum

5 at that time. John Blundell would have gone to the AMIS

6 office [next page, WS130-0025] to speak to him.

7 Don McCallum would then have issued instructions to the

8 block. Had Don McCallum been there, I would have been

9 asking him why H6 was stood down, but he was not there."

10 Is the fact that the reason your memory is so vague

11 as to who was present at this meeting and what exactly

12 was said was because maybe this wasn't an actual meeting

13 you were at, but rather during this short time-frame

14 instructions had been passed by Mr McKee to Mr Blundell,

15 who in turn passed those instructions on to you?

16 A. I was up in Governor McKee's office with Mr Blundell

17 discussing why the towers had been dropped.

18 Q. You cannot say exactly how many meetings or how many

19 discussions took place during that time-frame, can you?

20 A. Well, Governor McKee's story changed at some point.

21 There may have been another meeting, but certainly

22 I remember coming down to the office.

23 Q. Well, in relation to your recollection then of the

24 meetings that morning, it's somewhat vague as to exactly

25 what was said and you are somewhat vague as to exactly

23
 1 who was present. Is that fair comment?

2 A. Not really, no. I don't think so. I mean, given that

3 it is over ten years ago, I can't remember every

4 specific detail of the meetings, but I know what in

5 general went on, because it was a major day in the life

6 of the prison and my life.

7 Q. Just finally to confirm in relation to timing, it is

8 your evidence to say that the instruction, whether or

9 not that instruction was to you via Mr Blundell or

10 directly from Mr McKee, the instruction to reinstate the

11 towers in H6 Block was done at 9.30 am?

12 A. Well, it must have been slightly before that, somewhere

13 around that, because by 9.30 the instruction went down

14 to the block. So ...

15 MR O'CONNOR: Nothing further. Thank you.

16 THE CHAIRMAN: Mr Waite?

17 Questions from MR WAITE

18 MR WAITE: Just to clarify one matter. It has just been put

19 to you in cross-examination that it was only when pushed

20 in evidence today that you said that you were told by

21 Governor McKee to stand down all of the towers. In

22 fact, you were later taken to the passage in your

23 statement which shows that that assertion was made in

24 your statement.

25 A. Yes.

24
 1 Q. You recall saying that to the Inquiry when they took

2 your statement?

3 A. Yes, yes.

4 Q. Can we come to the first meeting with Governor McKee

5 when the instruction was given to you in relation to the

6 standing down of the towers? It is said on behalf of

7 Governor McKee that Brian Barlow was present at that

8 meeting. Can we just see what Brian Barlow says about

9 that, so you can have an opportunity to comment on it?

10 It is WS015-0065. That's paragraph 161. If we turn to

11 the final sentence in that paragraph, he says:

12 "However, I had not been present at any earlier

13 meeting between Witness ZL and PO Witness T, so I do not

14 know what was actually said at that meeting."

15 That accords with your recollection, does it, that

16 the earlier meeting Governor Barlow was not present at?

17 A. That's correct.

18 Q. You were asked if you ever raised a query in relation to

19 the instruction given by Governor McKee. I would just

20 like you to comment on one aspect of the evidence. Can

21 we go to WS073-0013? This is a statement from ZQ.

22 I understand that his anonymity has been lost; he is

23 actually Governor Helm.

24 THE CHAIRMAN: Yes, it has.

25 MR WAITE: I would like you to turn, please, to paragraph 35

25
 1 of that statement. He refers to overhearing an argument

2 that:

3 "... took place between Governor McKee and the

4 Duty PO in the Duty Office."

5 That's in paragraph 35. It relates to the standing

6 down of towers. Then if we go to paragraph 36,

7 WS073-0014, it says:

8 "I think during the course of the argument the

9 Duty PO was trying to keep the H Block 6 watchtower

10 posts filled, but the Governor said the instruction was

11 to send those officers to visits."

12 First of all, the reference to the Duty PO there,

13 would that be a reference to you?

14 A. I think so, yes.

15 Q. He recalls you remonstrating in relation to the

16 instruction. Could it be possible that you did actually

17 do so?

18 A. It may be possible, but I can't remember, to be quite

19 honest.

20 Q. In any event, when he refers to the Duty PO there, it

21 could only have been you. There is no-one else it could

22 have been, is there?

23 A. No, no.

24 Q. I put this question to you. If you were told not to

25 stand down H6, can you think of any reason why you would

26
 1 go straight ahead and stand down H6?

2 A. No.

3 Q. Do you ever recall an occasion where you were told to

4 stand down yard towers with the exception of

5 a particular block?

6 A. No. Excuse me. No.

7 Q. If such an instruction had been given, is that something

8 you would have questioned or sought further clarity in

9 relation to?

10 A. I may have asked why, but ...

11 Q. Is it probable that had that instruction been given at

12 the time, that you would have asked why?

13 A. Probably, yes.

14 Q. You said in your evidence yesterday that after

15 a meeting, a subsequent meeting later in the day, with

16 Governor McKee and Mr Blundell, you recall coming out of

17 that meeting and saying words to the effect of, "He's

18 telling lies in there".

19 A. Yes.

20 Q. Just be clear. Why did you say, "He's telling lies in

21 there"?

22 A. It was in relationship to the H6 towers.

23 Q. What were the lies that he was telling?

24 A. It was that he had said that he didn't say to stand them

25 down.

27
 1 Q. In your experience of Governor McKee, would it be in

2 character or out of character for him to behave in that

3 way?

4 A. How do you mean? In the way he did?

5 Q. Yes.

6 A. In character.

7 Q. Could you elaborate on that, explain that?

8 A. Do I have to really? Well, he was given to --

9 Q. The reason I ask the question is the Inquiry may have to

10 reach a decision on whose evidence they prefer. That's

11 why I am giving the opportunity to explain that answer.

12 A. Well, he could make up stories. He could make up

13 stories.

14 Q. Can you just give perhaps some examples?

15 A. I can't remember now, but it was widely known throughout

16 the prison.

17 Q. You say widely known.

18 A. Yes.

19 Q. Could we come now to the apparent standing down of

20 C/D tower earlier in the day? You are clear that you

21 had no part in that decision whatsoever.

22 A. That's correct.

23 Q. It is your evidence, isn't it, that the only person who

24 could give authority for the standing down of a tower is

25 the Duty Governor?

28
 1 A. That's correct.

2 Q. But that blocks would on occasions do their own thing?

3 A. That's right, yes.

4 Q. So the position is that if it was not you who, upon the

5 instruction of a Governor, had ordered C and D to be

6 stood down, it could only have been the most senior

7 officer in H6 at that time who issued that instruction.

8 Is that right?

9 A. That follows, yes.

10 Q. When, after the meeting with Blundell, the H6 yard tower

11 was re-manned, is it your recollection that that

12 instruction was issued immediately?

13 A. Yes.

14 MR WAITE: Thank you very much.

15 THE CHAIRMAN: Mr Macleod?

16 Further questions from MR MACLEOD

17 MR MACLEOD: Just a couple of matters to conclude from me,

18 Mr McCallum.

19 First of all, with regard to the diminishing task

20 lines which we looked at yesterday, can I ask you to

21 look at WS124-0019? I should perhaps have put this to

22 you yesterday, but I am sure there is no dispute about

23 this. Mr Duffy says that this was the diminishing task

24 lines that was in place at the time.

25 A. Yes. I recognise that, yes.

29
 1 Q. You recognise that?

2 A. Yes.

3 Q. Again, though, we see that the watchtowers do not

4 feature on that. Is that correct?

5 A. That's correct.

6 Q. That can being taken off the screen, please.

7 Various times have been put to you, 9.20, 8.50,

8 9.45, 9.15, 9.30 and so forth. You are trying to

9 remember what happened on a morning 11 years ago. Is

10 that correct?

11 A. That's right.

12 Q. So it must be very difficult for you to do that.

13 A. It is sort of.

14 Q. However, I wonder if we can just try to establish what

15 the normal practice was. It wouldn't be uncommon for

16 you to phone around asking for towers to be stood

17 down -- is that correct -- following an instruction from

18 a Duty Governor?

19 A. That's correct.

20 Q. About what time would you start making these calls?

21 A. As soon after 8.00 as possible. It wouldn't be on the

22 button of 8.00, because all the staff wouldn't be in

23 post. So as soon -- especially on a Saturday, to get

24 the visits going.

25 Q. As far as you are aware, was there only the one call

30
 1 relating to H6 on the morning, and that was the call

2 that you have been asked about? There was not

3 an earlier call to call down another tower?

4 A. No.

5 Q. I wonder then if we could look at the relevant PO/SO

6 journal entry for H6, which can being found at

7 NP14-3552. If we can enlarge the text, please, so the

8 bottom half or so of the page. If we look carefully, we

9 can see at 0845:

10 "C/D tower no light. Reported to ECR for works."

11 Then at 0850:

12 "From AMIS office, drop C/D tower. ECR and SIC

13 informed."

14 First of all, that relates to another tower and,

15 secondly, it is at a significantly earlier time than you

16 say you made the call to the block. Is that correct?

17 A. That looks like it, yes.

18 Q. Was it always the case that towers were dropped on your

19 say-so or did you tell us yesterday that the block might

20 choose to drop the towers from time to time?

21 A. Yes. As I said yesterday, I mean, the local manager,

22 for whatever reason, may take it upon himself to drop

23 posts without letting us know.

24 Q. Right. There is no mention in that entry of the tower

25 being dropped to facilitate visits. Is that correct?

31
 1 A. That's correct.

2 Q. If we can reflect on Mr Hill's position, which is

3 I think at WS074-0045, at about halfway down, maybe 12

4 to 14 lines down, towards the right-hand side, we can

5 see the words:

6 "At about ten minutes to nine I received a call on

7 my intercom to come down from the tower and report to

8 the PO's office. I did as I was told but at the main

9 gate of H6 I was informed by one of my colleagues that

10 there had been a change of heart and I was to return to

11 the tower."

12 Then he says:

13 "At approximately 9.30 I was again contacted via the

14 intercom and told to report to prison visits."

15 So, in fact, it would appear, would it not, from

16 Mr Hill's statement, that the only time he was to be

17 dropped for visits was on this second occasion? Is that

18 right?

19 A. That's what it looks like, yes.

20 Q. That would correspond with the time, broadly speaking,

21 of your phone call, certainly much better than the 8.50

22 one that he describes and the journal describes earlier.

23 Is that correct?

24 A. No. I mean, by 9.30 it was -- the block was told to

25 actually re-establish the towers.

32
 1 Q. Right.

2 A. So I can't really understand the timings there.

3 Q. But in terms of the 8.50 timing that we heard about

4 earlier, that was too early.

5 A. Yes.

6 Q. Is that correct?

7 A. Yes, yes.

8 Q. When we look at Mr Blundell's evidence, which you were

9 taken to, at WS008-0027, if we look to paragraph 75,

10 unfortunately there is no timing mentioned here, but

11 Mr Blundell says:

12 "Later in the morning I received a phone call from

13 Officer Ray Hill telling me he had been stood down

14 a second time from his post in the A and B watchtower of

15 H Block 6."

16 Again, this appears to be Mr Hill only calling or

17 making an issue of this on the second occasion he was

18 stood down. Is that correct?

19 A. That's what it looks like, yes.

20 Q. That appears to be the case.

21 A. Yes.

22 Q. Just to try to understand this, is it a possibility that

23 you did, in fact, only make the one call to that block

24 and it was in relation to the problem with visits, and

25 that the first time he was stood down was actually

33
 1 something to do with the block? Is that a possibility?

2 A. That could be a possibility.

3 Q. Thank you.

4 You have been asked at some length about the

5 reaction from the POA to the decision to drop the

6 towers. Assuming that we are right and the documents

7 are correct, and that the towers were dropped down not

8 infrequently, fairly often in fact, did the POA, for

9 want of a better phrase, protest about that on a regular

10 basis, or is this the first time you can remember there

11 being such a fuss, as it were?

12 A. Yes, that's about the -- yes. I mean, the POA would

13 jump up and down about some other things, but in

14 relation to yard towers -- it is difficult to remember,

15 but for the dropping of yard towers there was a bit of

16 hoo-ha from them that day.

17 Q. Had there been previously?

18 A. I can't comment. I can't ...

19 MR MACLEOD: You can't comment on that. Fair enough.

20 I have no more questions. Thank you.

21 THE CHAIRMAN: Mr O'Connor?

22 MR O'CONNOR: I wonder if I could make a statement to the

23 Panel? There is a matter raised about my client,

24 Mr McKee, in relation to his character and credibility

25 and then it was further pushed by my friend.

34
 1 I wonder if my Lord would allow me to ask a few

2 short questions in relation to that from this witness

3 before the Panel actually conducts their own questioning

4 in relation to it? I am obviously subject to my Lord.

5 THE CHAIRMAN: You would have no objection, would you?

6 MR WAITE: My Lord, no. My question did arise from what he

7 said in evidence.

8 THE CHAIRMAN: Sorry?

9 MR WAITE: My re-examination did arise from what he said in

10 evidence yesterday. I have no objection, provided it is

11 obviously limited to the additional questions which

12 I raised.

13 MR O'CONNOR: It will be specifically on that point,

14 my Lord.

15 THE CHAIRMAN: Very well.

16 Further questions from MR O'CONNOR

17 MR O'CONNOR: You indicated that my client, whom

18 I represent, who is the Governor, you indicated at that

19 stage that he was known to make up stories; that you

20 couldn't remember examples, but it was widely known.

21 You made a statement to the police after the event.

22 Isn't that correct?

23 A. Made a statement ...?

24 Q. To the police in relation to this incident.

25 A. Yes. Uh-huh.

35
 1 Q. You didn't mention in your statement to the police in

2 relation to Mr McKee's character or that it was widely

3 known that he was known for telling stories. Isn't that

4 correct?

5 A. That's right.

6 Q. You also made a statement to this Inquiry. Isn't that

7 correct?

8 A. Yes.

9 Q. You didn't state in that statement either that it was

10 widely known or that Mr McKee was known for making up

11 stories etc. Isn't that correct?

12 A. Yes. I didn't want to say.

13 Q. Would it surprise you that there is no other evidence

14 that has been given to this Inquiry thus far, to the

15 best of our knowledge, that Mr McKee had been known or

16 widely known to make up stories?

17 A. That's correct, yes.

18 Q. Would it simply be now that the question I put to you

19 earlier in relation to the phrase that Mr McKee said to

20 you "but leave H6" when he referred to the towers, is

21 the reason you are raising this now because you simply

22 got that wrong and you are trying to shift the blame on

23 to Mr McKee?

24 A. No. I didn't want to raise this at all.

25 MR O'CONNOR: Nothing further.

36
 1 Thank you, my Lord.

2 THE CHAIRMAN: Professor Coyle.

3 Questions from PROFESSOR COYLE

4 PROFESSOR COYLE: Mr McCallum, can I ask you a general

5 question about detailing? My memory of detailing is

6 more outdated than yours, but I remember until the

7 mid-1980s in the United Kingdom detailing was done

8 centrally; that is, all staff were allocated to their

9 daily duties from a central point, which was usually in

10 the Chief Officer's office, the Chief Officer's clerk or

11 someone like that. Then in the late 1980s group

12 detailing was introduced; that is, the staff were all

13 allocated to discrete groups, say a block or reception

14 or visits, and sufficient staff were built in for leave

15 and rest days and sickness, and each group had to be

16 self-sufficient in the way it detailed.

17 Which of these operated in the Maze?

18 A. Well, we went through a few different systems.

19 Originally, way back in the dark days, it was centrally

20 and then we went into group management, where the group

21 manager managed his own and had a cost centre number and

22 what have you. There was a group manager's meeting held

23 every morning, so if some groups were overstaffed and

24 other groups were understaffed there would be a change

25 of staff between themselves, but after a while it didn't

37
 1 sort of work too well and it fell down, so it was --

2 Q. So by the time we are interested in, in late 1997?

3 A. The blocks had their own staff and it was up to the

4 MIDAS office to relocate staff on a daily basis then,

5 rather than each group manager getting in touch with

6 each other. So each group still had their staff,

7 staffing levels and detailed to their own posts.

8 Q. But instead of having a morning group managers' meeting,

9 if there was shortage in a group they would report to

10 the MIDAS office, which in effect was yourself.

11 A. Yes. We would actually ring round. That's why I was

12 saying about, you know, who was on their next for the

13 hit.

14 Q. You said at one point yesterday, I think to Mr Macleod,

15 a local manager might drop a post:

16 "Maybe he was friendly with a particular officer or

17 something and, I mean, wanted to make sure he got an

18 easy post or whatever, or maybe dropped a post to fill

19 up something that he wanted done on the day ..."

20 Does that mean that, in effect, the group manager

21 may have operated his own personal diminishing task

22 list?

23 A. Yes. I mean, it was keep one up your sleeve or keep a

24 couple up your sleeve, you know, that sort of way.

25 Provided they didn't tell us, we wouldn't know anything

38
 1 about that.

2 Q. But it was recognised that this happened?

3 A. Yes.

4 Q. You seemed, if I understood you yesterday, to be

5 suggesting that might be what happened in C/D tower,

6 when it was put to you that the man from C/D tower was

7 taken down to be a relief circle officer.

8 A. That's correct.

9 Q. You said you would not have approved such

10 an arrangement.

11 A. No.

12 Q. Again, if I understood it this morning, it was being

13 suggested to you by Mr Macleod that perhaps on the first

14 occasion that the officer was taken from the A/B tower

15 might have been a similar block arrangement, rather than

16 from you.

17 A. Could have been. I just couldn't say.

18 Q. When Officer Blundell, on behalf of the POA, came to

19 complain about standing town A/B tower in H6, by that

20 time C/D tower had been stood down, as we have heard.

21 A. Yes.

22 Q. Did he complain about the standing down of C/D tower?

23 A. Well, my recollections, given the time, is it was about

24 both towers being stood down.

25 Q. I see. I mean, the discussion I think we have heard so

39
 1 far has concentrated on the A/B tower, but you now think

2 he also complained about standing down C and D?

3 A. I can't be 100% sure. I would have thought it was both

4 towers, you know, because the towers shouldn't have been

5 stood down. They were beyond the diminishing task

6 lines.

7 Q. So we have the situation where C and D tower was stood

8 down by the Block PO or acting PO as the group manager,

9 but you as the MIDAS officer were standing down the A

10 and B tower, not knowing that the other one had been

11 stood down.

12 A. That's right, yes.

13 Q. And although you are not sure, you suspect that the POA

14 might have been objecting to both of the towers being

15 stood down.

16 A. Yes.

17 Q. Turning to the root cause of all this, which was the

18 shortage at visits, you have explained to us that on

19 that morning the visits group was eight officers short.

20 A. To my recollection, yes, somewhere around that.

21 Q. What subsequently happened? Did you find the eight

22 staff from elsewhere?

23 A. I don't think we did. I think the PO came round and he

24 ran the visits short of men.

25 Q. Because obviously if he had stuck to his guns and

40
 1 refused to open visits, then this Inquiry would not be

2 here today.

3 A. That's right.

4 Q. So as far as you are aware, he went ahead on that

5 morning still a significant number of staff short?

6 A. Yes.

7 Q. Would this have happened frequently?

8 A. He did run visits staff short, but I think he had had

9 enough of it that particular day.

10 Q. Quite a dramatic threat, to close down the group. Would

11 that have been unusual or ...?

12 A. Well, it was pretty drastic action in that, you know,

13 you weren't opening visits on a Saturday, obviously to

14 prompt some action and give him some men.

15 Q. But you can't recollect whether in fact you were

16 subsequently able to find extra staff for him?

17 A. I don't think we were, to be honest.

18 PROFESSOR COYLE: And he went ahead eight short.

19 Questions from THE CHAIRMAN

20 THE CHAIRMAN: I am puzzled, I confess, Mr McCallum, about

21 the entry in the PO/SO journal, which is to this effect,

22 and it is at 8.50:

23 "From AMIS office drop C/D tower."

24 That's what the entry says.

25 A. That's correct, yes.

41
 1 Q. Would that entry be accurate?

2 A. Not to my knowledge, no.

3 Q. Because you were effectively that day the Duty Officer,

4 were you not, in the AMIS office?

5 A. That's correct.

6 Q. And you did not give that instruction. Is that right?

7 A. No, not until after 9.00.

8 Q. Ah, but what instruction did you give after 9.00?

9 A. Whenever I first went up to Governor McKee's office and

10 sought posts to get visits opened, whenever I came back

11 down I then got in touch with 6 to drop the towers. So

12 that would have been shortly after 9.00.

13 Q. That's both towers.

14 A. Uh-huh.

15 Q. So in your opinion this is not an accurate entry then,

16 because you did not give an instruction specifically to

17 drop C/D tower.

18 A. No.

19 THE CHAIRMAN: Thank you.

20 Bishop Oliver?

21 Questions from RT REV OLIVER

22 RT REV OLIVER: That was a question I was going to ask.

23 To go back to Professor Coyle's question about group

24 manager, this phrase you have used, I am not quite clear

25 who the group manager is. The PO in a block would be

42
 1 the group manager, would he?

2 A. The Principal Officer.

3 Q. Or the Block Governor?

4 A. The Principal Officer, and if the Principal Officer

5 wasn't available it would be the Senior Officer who

6 would assume the role of group manager.

7 Q. So if, in fact, it was the Senior Officer on this

8 occasion on this particular day who stood down C/D, he

9 would be doing it as group manager without informing

10 you, because you say that was not on your authority that

11 C/D tower was stood down.

12 A. That's correct.

13 Q. Can you account for the fact of that entry being put in

14 the journal?

15 A. I can't comment on it at all.

16 Q. Can I just look briefly again at your statement, please?

17 WS124-0014. The end of that long paragraph, that's

18 really starting at sort of ten lines up from the bottom

19 of that paragraph:

20 "The three of us then had a discussion ..."

21 If that perhaps could be enlarged:

22 "I told him that he should keep the yard towers

23 manned."

24 You already knew that C/D had been called down

25 without your authority, but were you hoping that

43
 1 Senior Officer Gallagher would be able to find someone

2 to put back into C/D as well as putting Raymond Hill

3 back into A/B? That was your intention?

4 A. Well, I mean, I didn't think about it at the time,

5 because whenever the instruction was given to close both

6 towers, C and D is already down.

7 Q. If your timing is right, and this was 9.30, at which

8 point Raymond Hill would have been asked to go back to

9 A/B tower, if that timing is right, he would have been

10 back in the tower by about 9.40.

11 A. Yes, around about that.

12 Q. So he would have been able to see the INLA prisoners

13 emerging, going through the wire, up over the roof.

14 Does this indicate to you that perhaps your timing is

15 not right? Because he certainly doesn't give any

16 evidence that he did see that happen. His evidence is

17 that he saw them coming back just after 10 o'clock.

18 A. Well, obviously I can't be spot on with my timing, but

19 that's as near as I can remember it. I mean, at the

20 time.

21 Q. You would agree that if he had gone back at that time,

22 he would have seen the prisoners going over the roof?

23 A. Probably, yes.

24 Q. The last question is about another piece of evidence you

25 have gave right at the beginning. It is NP31-0038. It

44
 1 is really about the manning of the prison in general at

2 weekends. What occurred to me when I looked at this --

3 this was the Saturday arrangement -- it is under

4 "Miscellaneous" in the middle:

5 "SST must retain 14".

6 The Special Search Team?

7 A. That's correct.

8 Q. That must in no circumstances be reduced in number.

9 A. That's correct.

10 Q. But are those the people who effectively were being used

11 at weekends to search in visits?

12 A. Yes, I think that's correct at that time.

13 Q. What is not mentioned here at all is the IRF, but that,

14 presumably, is right outside this whole range of posts.

15 A. That's correct. The IRF had to remain in place at all

16 times.

17 Q. And that included weekends?

18 A. Uh-huh, yes.

19 Q. But not at night.

20 A. How do you mean?

21 Q. Well, the IRF was not on duty at night.

22 A. Oh, on night guard. It is on association period, but

23 not on overnight.

24 Q. The IRF was only on duty during the day.

25 A. Right through to evening, what used to be lock-up.

45
 1 Q. But this "must keep 14" is really in fact another

2 requirement in relation to visits?

3 A. That's correct.

4 RT REV OLIVER: Thank you.

5 THE CHAIRMAN: Thank you very much, Mr McCallum, and thank

6 you for returning too. You are free to go.

7 A. Thank you.

8 (Witness withdrew)

9 THE CHAIRMAN: We will break now. Can we have 15 minutes,

10 please?

11 (11.10 am)

12 (Short break)

13 (11.25 am)

14 THE CHAIRMAN: Mr Macleod.

15 MR MACLEOD: My Lord, the final witness today is

16 Mr Gerald Thompson.

17 MR GERALD THOMPSON (called)

18 THE CHAIRMAN: Before you sit down, could I ask you: do you

19 wish to take the oath or would you prefer to affirm?

20 A. Yes.

21 MR GERALD THOMPSON (sworn)

22 THE CHAIRMAN: Thank you. Please sit down, Mr Thompson.

23 Mr Macleod.

24 Questions from MR MACLEOD

25 MR MACLEOD: Thank you.

46
 1 Mr Thompson, did you join the Northern Ireland

2 Prison Service in 1976?

3 A. That's correct.

4 Q. For the first 11 years of your employment did you work

5 at the Maze compound?

6 A. That's correct.

7 Q. Did you then have a spell at Her Majesty's Prison

8 Belfast between 1987 and its closure?

9 A. I did, yes.

10 Q. Then did you return to the Maze, this time to the

11 cellular Maze Prison, following the closure of

12 Belfast Prison, and remain there until 2000?

13 A. That's correct.

14 Q. For that second time at the Maze were you in H Block 6?

15 A. I was.

16 Q. Can you recollect in 1997, from April/May 1997 until the

17 end of that year, that the INLA were co-located in

18 H Block 6 with the Loyalist Volunteer Force?

19 A. They were, yes.

20 Q. The INLA included among their number

21 Mr Christopher McWilliams and John Kenneway.

22 A. That's correct.

23 Q. Were you posted to a particular role every morning that

24 was different or did you tend to do the same thing?

25 A. No, it was general duties.

47
 1 Q. What was your duty on 27 December 1997?

2 A. I was a relief officer to some of the staff from 8.15.

3 I was giving breaks from 8.30 onwards, and at 10 o'clock

4 I was due to go up to the A and B towers to relieve the

5 officer there.

6 Q. Can we just pause there, please, Mr Thompson? When you

7 say you were giving breaks from 8.30 onwards, does that

8 mean you were essentially standing in for officers when

9 they went away for their break?

10 A. That's correct, yes.

11 Q. Can we look, please, to WS282-0009? This is a document

12 that will appear on the screen in front of you,

13 Mr Thompson. This is the daily planner for the

14 Saturday, 27 December 1997. Have you seen this before?

15 A. No.

16 Q. If we look towards the middle column, we will see the

17 words "Officer 27" has been scored out and then

18 "Danks A" and so forth. Do you see that? The operator

19 will highlight it. Just where the pair of scissors

20 appear on the screen. Just below that.

21 A. Danks, yes. Uh-huh.

22 Q. You can see that?

23 A. Yes.

24 Q. If we look down six or seven entries do we see the name

25 "Thompson"?

48
 1 A. That's correct, yes.

2 Q. If we look two more down from that, we see again

3 "Thompson" has been scored out and the word "Hill" has

4 been put in for A and B tower. Do you see that?

5 A. Yes, yes.

6 Q. Is that correct?

7 A. Yes. Uh-huh.

8 Q. If we look about seven or eight entries down, we see

9 another Thompson, WB Thompson. Was that Brian Thompson?

10 A. I would imagine it was, yes.

11 Q. So you are --

12 A. G.

13 Q. -- described as Thompson. We can see that opposite your

14 name is "A and B patrol". When we see the words "A and

15 B patrol", what did that mean normally? Would that

16 involve relieving these other officers?

17 A. That would be me relieving them ones.

18 Q. Because we know a Mr Blair and Mr Hanna were the people

19 between the grilles that morning on A and B side. Are

20 you with me?

21 A. Give us them names again, please.

22 Q. I think it was Mr Hanna.

23 A. Hanna, yes.

24 Q. And Mr Blair, Ivan Blair.

25 A. Ivan Blair. Yes. Well, I know Mr Hanna was definitely

49
 1 there. Mr Blair, that I'm not sure of.

2 Q. Where we saw your name stroked out in that column,

3 Thompson, so it is two beneath yours, if we look two

4 beneath that we see "I Blair". Do you see that?

5 A. Yes, uh-huh.

6 Q. If we look across, we see he is on A and B patrol.

7 A. Right. Okay.

8 Q. So he would have been on the A and B side as well. Is

9 that right?

10 A. Yes.

11 Q. With Mr Hanna.

12 A. Yes.

13 Q. You are also described as an A and B patrol officer, but

14 does that mean really you were --

15 A. Relief.

16 Q. -- relief that day?

17 A. I was giving all that side reliefs.

18 Q. I am with you now. So you would be relieving the

19 A/B tower, the A/B grille officers and suchlike.

20 A. Yes, but the tower would have been the last one, because

21 he would have been going off for his dinner break.

22 Q. Right. I'm with you.

23 On 27 December what time did you actually come into

24 the block?

25 A. Approximately 8.15.

50
 1 Q. Were you allocated that job on the day, or did you know

2 you would have it beforehand?

3 A. Well, you would probably -- I would probably have known,

4 like, you know, because you normally get three days

5 notice when a detail goes up.

6 Q. In fact, did you speak to a Mr Gallagher that morning,

7 the Senior Officer?

8 A. I did.

9 Q. Did he tell you in particular what to do as part of your

10 role?

11 A. Well, he probably just took it as general knowledge you

12 knew what to do, like, you know. So more or less

13 I would have went in and he would have ticked me off as

14 being present on duty.

15 Q. Right. Who was in charge that morning in H Block 6?

16 A. Well, I can only assume that it was the SO, because

17 that's the only person I had seen. I didn't see any

18 Principal Officer.

19 Q. We know that there were two SOs there that morning,

20 Mr Molloy and Mr Gallagher. I think Mr Gallagher was

21 one of the regular SOs. Is that correct?

22 A. Mr Gallagher was a regular, oh yes.

23 Q. This other gentleman was there, Mr Molloy. Which of the

24 two was the senior man that day?

25 A. Well, being -- SO Gallagher, being the regular SO,

51
 1 I would imagine he would have been in charge.

2 Q. Was he doing the detailing that morning?

3 A. Well, the detail, as I say, was made out coming in.

4 Sometimes, if an officer was in before the SO, he would

5 have ticked himself off and maybe went to his post

6 without the SO coming.

7 Q. Because when we look at this screen, we see that there

8 are some typed names and rolls. That would have been

9 the central detailing. On the morning would the names

10 have been scored out and people reallocated to various

11 positions?

12 A. Not on the day, I wouldn't imagine that.

13 Q. That would have been before?

14 A. That would have been before.

15 Q. For instance, if someone didn't turn up?

16 A. Maybe for that they might have to reschedule.

17 Q. Was Mr Gallagher doing that in the morning?

18 A. Well, he would have been just been ticking any staff off

19 coming into the block in the morning.

20 Q. Did you see Mr Hill that day?

21 A. Just at a later stage I noticed him coming into the

22 block.

23 Q. At about what time?

24 A. I suppose anything from 9 o'clock till 9.30, but I can't

25 be sure. I can't be sure. Because, as I say, I had

52
 1 cause to shout over to him when he came in.

2 Q. Where were you when you had cause to shout over to him?

3 A. I would have been down the wing.

4 Q. Which wing?

5 A. A and B, giving the break.

6 Q. Well, when you say down the wing, of course, what you

7 mean, I think, is you would have been down the corridor

8 that leads to the wings, between the grilles.

9 A. Yes, yes.

10 Q. You wouldn't actually have been down any wing.

11 A. Correct. That's correct. Just on a grille down there.

12 Q. Because if you had been down the wing, you wouldn't have

13 been able to see him.

14 A. Well, I was able to see him from my location.

15 Q. How did he appear to you to be?

16 A. Whenever he came in, I shouted over to him, "Raymond,

17 what's wrong?", because, you know, he should have been

18 up the tower. I shouted over "What's wrong". He more

19 or less shrugged his shoulders and, "I'll see you in

20 a minute", something like that there, words to that

21 effect anyway, but I never seen him again after that.

22 Q. You said in your statement that he appeared to be

23 agitated.

24 A. He seemed to be. Whenever he came in, like, he seemed

25 to be, you know, not in the best of tune, like, you

53
 1 know.

2 Q. Did you see him again after that?

3 A. No, no.

4 Q. Did you, in fact, have cause to relieve him of his

5 position in the tower?

6 A. No, no.

7 Q. So between 9.00 and 9.30, that's as well as you can

8 assist us?

9 A. I would probably imagine it would have been maybe about

10 9.20, maybe a bit later on, you know, in and around that

11 time. I would imagine that would have been.

12 Q. Did you know whether he had come into the block before

13 that from the tower?

14 A. No. That was the first I had seen him, in and around

15 that time, I would imagine, you know.

16 Q. Is it possible that he had come to the block earlier and

17 you might not have seen him?

18 A. Quite possible, yes.

19 Q. In any event, Mr Thompson, after you had this brief

20 conversation with Mr Hill, what did you do then?

21 A. Well, I waited till my relief went back, because the

22 first thing I thought of when Raymond came in, where

23 well he should have been on the tower: has he been

24 called out of the tower or is he not well and has

25 reported in? "I have to come down, I am not too well".

54
 1 Whatever reason, like. I just didn't know. But

2 whenever I got relieved, I think I went for a cup of tea

3 and then approximately 9.45 I went in to see the

4 SO Gallagher.

5 Q. So you would have gone in the teaboat, as it is called,

6 first of all.

7 A. Yes, I would have went and got a cup of tea and then

8 approximately 9.45 I went in to see the SO for the sole

9 reason to find out if he has been recalled from the

10 block to go elsewhere.

11 Q. Was that uncommon?

12 A. Was it ...? Sorry.

13 Q. Was it uncommon for people to be called?

14 A. I have never known the block to be dropped. Never.

15 Q. When you say you have never known the block to be

16 dropped.

17 A. Sorry, sorry. The tower to be dropped. Sorry.

18 Q. Had you worked in that block regularly in 1997?

19 A. I have, yes.

20 Q. We have information, or the Inquiry has information from

21 the Northern Ireland Prison Service that, in fact, the

22 towers were blocked (sic) on numerous occasions from

23 October onwards. I beg your pardon. From April of 1997

24 towards the end of that year. Does that --

25 THE CHAIRMAN: You used the word "blocked". You mean

55
 1 "dropped"?

2 MR MACLEOD: Yes, sorry. It's contagious I think.

3 A. You mean "dropped". Well, I can only say that I myself

4 have never known it to be dropped. Never.

5 Q. Were you ever posted to the tower?

6 A. I was.

7 Q. And all you can say then is --

8 A. I certainly wasn't ever took out of it.

9 Q. You were never taken out of the tower.

10 A. And certainly if I had been, I would have caused

11 a rumpus too.

12 Q. Did you often work association periods?

13 A. I did, yes.

14 Q. Even on those occasions you were never called from

15 towers on H6?

16 A. The only time I would have been called out of that tower

17 was to lock up. Once the lock-up was completed, you

18 would have seen the staff, you'd observe the staff

19 coming into A and B yards, locking down grilles, you

20 know, the grilles in the yard, and then generally what

21 you done, you waved up to the tower man that was okay.

22 He then informed the Control Room through the intercom

23 that: the yards have now been locked, the staff has now

24 went back in, permission to stand down. Then you would

25 have stood down, brought your keys round and put them in

56
 1 the Control Room.

2 Q. We weren't really talking about the system for

3 withdrawing prisoners from the yards. We will maybe

4 return to that in due course.

5 A. Okay.

6 Q. As far as the towers being stood down, as far as you are

7 aware, they weren't stood down in 1997?

8 A. Not to the best of my knowledge, no.

9 Q. If the Inquiry has evidence that in fact on numerous

10 times one or other, sometimes both, towers were stood

11 down, might it be the case you are mistaken?

12 A. Well, if they have proof, then by all means.

13 Q. As I say, we will maybe return to the issue of the use

14 made of the towers in due course, but I was asking you

15 about what had happened on the morning. You said you

16 went in to see Mr Gallagher to ask him what was going

17 on, essentially. Is that right?

18 A. That's correct.

19 Q. That was at about 9.45?

20 A. That was about at 9.45.

21 Q. How long were you in with Mr Gallagher?

22 A. I suppose about fifteen minutes, coming up towards

23 10 o'clock. I would have kept a wee eye on the time,

24 because I did say to the SO, "If Raymond has been

25 recalled to go elsewhere, what do I do? Have I to go

57
 1 somewhere else if the tower has been dropped?"

2 Q. What did Mr Gallagher say to you about what was

3 happening?

4 A. More or less he said there was a bit of a dispute on and

5 Raymond was seeing to it. I assumed by that he meant he

6 was going down to see the POA union to see why this

7 tower was dropped.

8 Q. As far as Mr Hill was concerned, was he in the block at

9 that point, as far as you were aware?

10 A. I don't know where he was. I didn't see him after he

11 came in after that. He certainly wasn't in the teaboat

12 when I went in the teaboat at 9.30.

13 Q. You were in with Mr Gallagher in the SO room. Was

14 anyone else there?

15 A. I can't really remember. I just remember speaking to

16 the SO Gallagher and then whenever I said "What's

17 happening then to me," he said, more or less, "We'll

18 just have to wait and see what comes back". That was

19 about the height of the conversation. We just talked in

20 general after that there, like, you know, until a later

21 time, 10.00.

22 Q. Was that conversation interrupted by something?

23 A. No, no. I mean, he said enough when he turned round and

24 says, "We just have to wait and see". That's it. Just

25 wait and see.

58
 1 Q. In your statement you say that:

2 "When Billy Wright was shot, I was probably in the

3 PO's office with SO Gallagher."

4 A. I would imagine so, yes.

5 Q. Did you hear anything at that time?

6 A. I heard absolutely nothing, absolutely nothing.

7 Q. What was the first thing that you saw or heard when you

8 came out of the PO's room?

9 A. Whenever I was -- we were heading out, and just as I was

10 heading out of the office I heard the commotion from the

11 LVF prisoners. My first reaction was there is a bit of

12 a digging match going on, whatever.

13 Q. What is a digging match?

14 A. A digging match is when two people are squaring up to

15 each other.

16 Q. Was that something that you had seen before in H Block 6

17 between the two factions?

18 A. Well, yes, it comes. It happens. It does happen.

19 Q. Had it happened in H Block 6 between the two factions

20 that year?

21 A. No, not that I know. No, I don't think -- no, it

22 didn't.

23 Q. Right. Thank you. Were you able to hear shouting then

24 between the factions on this occasion?

25 A. No, not between the factions. It was the LVF, not

59
 1 between the factions. The LVF was shouting.

2 Q. What was it that they were shouting?

3 A. Well, they were shouting things like, "Let us out. Let

4 us out. We want over to them", and things like that

5 there, like, you know. Whenever I went over, I could

6 hear them shouting, "Billy Wright's been shot".

7 Q. When you say they were saying, "Let us out. Let us

8 out", did you understand what they were meaning? Let us

9 out of where?

10 A. Obviously they wanted out probably to get to the other

11 side and then get into that other block to have a go at

12 the INLA.

13 Q. Did you understand them to be wanting out into the yard

14 or wanting into the circle or what?

15 A. Out to the circle, and then they would have had to go

16 through into the A and B to get at the other faction,

17 like, you know.

18 Q. How realistic was that?

19 A. It wasn't realistic.

20 Q. It wasn't going to happen?

21 A. No.

22 Q. Did you hear what had happened?

23 A. What way hear?

24 Q. Did you find out what had happened outside?

25 A. Oh, find out.

60
 1 Q. Yes.

2 A. Well, I mean, the first I knew of it was when the LVF

3 was shouting up that Billy Wright had been shot.

4 Q. Did you hear an alarm being activated?

5 A. No, no, but I hit the alarm. I would imagine my alarm

6 was probably the last alarm to go off, like, you know.

7 Q. Did you become unwell a short time after that?

8 A. I did, yes.

9 Q. What happened?

10 A. Well, basically, like, obviously we were locked down

11 because the Main Control Room takes control over

12 everything and, okay, nerves set in. Adrenalin pumps.

13 Once we got unlocked, I had asked staff, "Does anybody

14 know if there was staff injured?" because I already knew

15 that Billy Wright had been shot, but I didn't know what

16 condition the man was in, to be quite honest, and

17 I says, look, I was going out into the yard to see if

18 there was staff needed help, or whoever. Whoever, it

19 didn't matter who, you know. Did people need help out

20 there.

21 Somebody said to me, "Look, wait till I tell you

22 something, they are probably still on that roof", and

23 I use the word "probably" because we didn't know. Well,

24 I knew Crip McWilliams was back in again, because

25 I'd seen him. They were giving a pow-wow across to each

61
 1 other, like, so they were, you know.

2 Whenever I went out into the yard, I kept saying to

3 people, "Where did the shooting take place? There is

4 nothing in the yard. There is nothing". I seen the

5 reaction force outside the main block.

6 Q. Yes.

7 A. I went down there and I asked, "What's ..."

8 Q. Did something happen to you? Did you fall ill? Did you

9 collapse?

10 A. Right. I'm coming to that sir, with all due respect.

11 Q. Very well. In your own time.

12 A. Whenever I went out I asked, "Billy Wright, what's his

13 condition". They said "Gerry, they pumped the lot into

14 him". I just seemed to black out from then.

15 Q. You collapsed at that point.

16 A. I did.

17 Q. Were you taken to the hospital?

18 A. I was taken to the prison hospital, and I walked in

19 okay, like, on my own. They recommended that I go to

20 the Lagan Valley Hospital, which I did.

21 Q. Can we return finally to something you said to me

22 earlier about the clearing of the yards and the

23 watchtowers? Do you remember you mentioned something to

24 me about that? Just let me finish.

25 A. Okay.

62
 1 Q. How someone in the tower would look to see if the yards

2 were empty before someone walked in to close the grille.

3 Do you remember you said that?

4 A. Yes. That's on association.

5 Q. I beg your pardon?

6 A. That would be on association.

7 Q. Was that the position in late 1997 or was it the case

8 that no-one went in to lock that grille and, in fact,

9 essentially the prisoners had the run of the yards

10 overnight?

11 A. Not overnight. When you say "overnight", exactly what

12 do you mean when you say overnight? Lock-up, there was

13 nobody in the yard after lock-up, nobody in the yard.

14 Q. Was there a problem with the turnstiles being broken?

15 A. No.

16 Q. There wasn't. The Inquiry has heard there was a problem

17 with the bolts in the turnstiles. There was difficulty

18 in making sure that the prisoners couldn't get through

19 them. In fact, we have heard that on occasions they

20 were able to get through them and they were in the yards

21 all night.

22 A. Well, not to the best of my knowledge they weren't.

23 Q. We also heard from Mr Duffy, who was your -- were you in

24 the Prison Officers' Association?

25 A. I was, yes.

63
 1 Q. He was the branch secretary, was he not?

2 A. Yes, uh-huh.

3 Q. He told us that from mid-June 1997 there was a POA

4 directive to staff that they shouldn't go into the yards

5 to lock up the grilles at night, from June 1997 to the

6 end of 1997, and it was only early 1998 that the system

7 you describe came back into place.

8 A. I couldn't swear to that now, to be honest.

9 Q. Is it possible you can't remember what the situation

10 was?

11 A. Well, that would probably be more the thing, but I know

12 many a time I went out into the yards to lock up when

13 I was down the wing and lock-up came. Many a time

14 I went down.

15 Q. That would be about 8 o'clock that you remember this

16 happening?

17 A. 8 o'clock is when you went in for the headcount.

18 Q. So it is towards the end of the association period that

19 you are referring to.

20 A. Yes, that's it exactly.

21 MR MACLEOD: Thank you very much.

22 THE CHAIRMAN: Mr Kane?

23 Questions from MR KANE

24 MR KANE: Mr Thompson, I just want to ask you about the

25 period during which you went into Mr Gallagher's office.

64
 1 You indicated in the statement which you provided to the

2 police that that was from about 9.45, and you were in

3 there for about fifteen minutes.

4 A. Approximately fifteen, yes.

5 Q. Are those times correct in your --

6 A. Well, to the best of my knowledge. I would have been

7 relieved myself approximately 9.30. My relief officer

8 would have come back to me. I was the relief officer,

9 but the officer who I relieved would have come back at

10 9.30 for me to go and get a cup of tea.

11 Q. If you were due to be up in the A and B area again --

12 A. A/B tower.

13 Q. The tower for 10 o'clock.

14 A. For 10 o'clock.

15 Q. How long would it take you to get from that office to

16 the tower?

17 A. If you had a straight run, we are talking about

18 a straight run now, just straight out, people letting

19 you straight out the grilles.

20 Q. Can you assist us and tell us how long that would have

21 taken?

22 A. Okay. Less than five minutes.

23 Q. Were you meant to be there at 10 o'clock?

24 A. Well, give or take a few minutes. Nobody ever said

25 nothing, like, you know. What I am saying by that

65
 1 there, I could have come out and the main yard, there

2 could have been movement coming in. So he would see to

3 the movement before he would let me out. But that's

4 what I am saying.

5 Q. The point I am just asking you is, are you meant to be

6 there at 10 o'clock so the other man can be away at

7 10 o'clock?

8 A. Yes. You would say, "I'll see you at 10.00".

9 Q. During that fifteen minutes you were there in the SO's

10 office, what was going on in that office? What did you

11 talk about?

12 A. I went in to see if Raymond was called out to go

13 elsewhere, then do I have to go elsewhere too? In other

14 words, is the tower being dropped?

15 Q. During that fifteen minutes what were you being told?

16 Obviously you just didn't sit there in silence with

17 Mr Gallagher. You were in there for a particular

18 purpose, to find out about going back up into these

19 towers and were the towers being dropped. What was

20 being said to you?

21 A. Well, what was being said to me was, "We are just going

22 to have to wait and see".

23 Q. Was any explanation given to you as to what they were

24 waiting on?

25 A. No explanation. The explanation was, I assume, "I am

66
 1 going to have to wait and see" from the SO. I suppose

2 what he meant by that -- but you needn't quote me on

3 this, you may ask him this -- I would imagine what he

4 meant by that was Raymond is going to come back and say

5 what's happening, if he is going elsewhere or has he to

6 go back to the tower.

7 Q. Did you understand there was anyone in the tower in that

8 fifteen minute period between 9.45 and 10 o'clock?

9 A. Well, I hadn't a clue where Raymond was. I don't know

10 whether he went back to the tower or whether he went to

11 see the POA reference anything. I don't know.

12 MR KANE: Okay. Thank you.

13 A. Thank you.

14 THE CHAIRMAN: Mr Bourne?

15 MR BOURNE: No questions, my Lord.

16 THE CHAIRMAN: Mr Fortt?

17 MR FORTT: No questions.

18 MR O'DONOGHUE: My witness, my Lord.

19 THE CHAIRMAN: I know that. That's why I didn't call upon

20 you.

21 Mr Hunter?

22 Questions from MR HUNTER

23 MR HUNTER: Mr Thompson, I represent Officer Raymond Hill.

24 As regards the timings, in an answer there to Mr Kane

25 you indicated that your relief was at approximately

67
 1 9.30.

2 A. That's correct.

3 Q. So it is at 9.30 you were going -- where were you going

4 from at 9.30?

5 A. At 9.30 I would have went and had a half hour break

6 myself.

7 Q. Where did you go from to go for your break?

8 A. Just into the teaboat.

9 Q. No, no. Where had you come from? Where did you leave

10 to go for a break?

11 A. I forget the post I was on. It's ten years ago. It was

12 probably down A and B grille, and from there I would

13 have went in for the teaboat.

14 Q. So was it at that point that you met Raymond Hill?

15 A. It was just before I was relieved.

16 Q. Just before you were relieved?

17 A. About 9.20. I would say approximately 9.20, but I can't

18 be sure of that.

19 Q. You can't be sure?

20 A. Because, you know, you are not sort of keeping time and

21 anything like that. I was just a bit surprised to see

22 Raymond coming in.

23 Q. Where was it you saw him?

24 A. He came through -- he came into the block and, as I say,

25 I shouted over to him, "Raymond, what's wrong?"

68
 1 Q. So you see him as he comes into the block.

2 A. That's correct.

3 Q. That's the first you saw of him that morning?

4 A. That was, yes.

5 Q. You say that your timings are approximate, Mr Thompson.

6 Isn't that right?

7 A. Yes. I don't think they are too far out.

8 Q. You see, Mr Hill's recollection, Mr Thompson, is that it

9 was roughly around 9.30 that he was called down from the

10 tower and entered the block and went into the office.

11 A. Well, I wouldn't dispute that. If Raymond is saying

12 that, that's fine. That's fine. As I say, I don't have

13 a specific time that I seen him at.

14 MR HUNTER: Thank you very much.

15 THE CHAIRMAN: Mr Dunn?

16 MR DUNN: No questions.

17 THE CHAIRMAN: Mr O'Connor?

18 MR O'CONNOR: No questions, my Lord.

19 THE CHAIRMAN: Mr O'Donoghue?

20 MR O'DONOGHUE: No questions, my Lord.

21 THE CHAIRMAN: Mr Macleod?

22 MR MACLEOD: No questions. Thank you, my Lord.

23 Questions from THE CHAIRMAN

24 THE CHAIRMAN: Could I just ask you one question, please?

25 You said that when you were in the SO's office

69
 1 Mr Gallagher said to you, "We'll just have to wait and

2 see what comes back". These are the words you used this

3 morning. What did you understand him to mean?

4 A. I would imagine what he meant was whenever I said,

5 "What's going on?" and he said, "There's a bit of

6 a dispute", meaning Raymond has been asked to stand

7 down.

8 Q. Yes.

9 A. And Raymond had, you know, made it known to the SO,

10 like, he wasn't happy at being dropped in this tower.

11 Then my understanding was, right -- I was more concerned

12 about what I was going to do, not what Raymond was going

13 to do. I mean, do I go back up the tower for somebody

14 to page me up and turn round and say, "Go elsewhere"?

15 I had no idea why Raymond came into the block. He could

16 have come in for any reasons. He could have been not

17 well. I just don't know. But when I went in to see the

18 SO, then he informed me, "There's a bit of a dispute".

19 So I said, "Well, what do I do? Do I go back up the

20 tower or do I have to go elsewhere?" and he says, "We

21 are just going to have to wait and see".

22 THE CHAIRMAN: Thank you.

23 Professor Coyle?

24 Questions from PROFESSOR COYLE.

25 PROFESSOR COYLE: Can you just explain to me a bit little

70
 1 more this roll of relief officer? I am familiar with

2 the description "general duties officer".

3 A. Right.

4 Q. But I am not familiar with the notion of having a relief

5 officer actually on duty on a day. Was there always

6 a relief officer?

7 A. Yes.

8 Q. Just one for the block or one for the wing or --

9 A. Just one for the block.

10 Q. For the whole block?

11 A. You only gave one relief and then you were allocated to

12 a post after that. Ie myself, that day I would have

13 went up at approximately 10 o'clock to let the officer

14 in that tower go for his dinner break and I waited there

15 till he came back to relief me from the tower for my

16 dinner break then.

17 Q. Yes. The staff, you told us, came on duty at

18 approximately 8.15?

19 A. That's correct.

20 Q. How long was their tour of duty? When did they finish

21 duty?

22 A. On the day?

23 Q. Uh-huh?

24 A. Some could have been finished at 1700 hours. Others

25 could have been finished at lock-up, 8 o'clock.

71
 1 Q. Right. Would they have a meal break during that period?

2 A. Yes, very much so.

3 Q. When would the meal break be?

4 A. Well, you had what was called early meals, 10 o'clock,

5 and then you had your normal at 12 o'clock.

6 Q. That I understand. How long was the meal break?

7 A. Well, it is supposed to be an hour, but we got a wee bit

8 longer.

9 Q. So in excess of an hour?

10 A. Yes.

11 Q. So all staff came on at 8.15. Those who were on early

12 lunch went off at 10.00 and those who were not on early

13 lunch went off at midday for an hour or so.

14 A. That's correct.

15 Q. Tell me about the breaks. Staff came on at 8.15 and you

16 started giving breaks from 8.30?

17 A. From 8.30.

18 Q. Why would a man who came on at 8.15 need a break at

19 8.30?

20 A. Well, that's the way that breaks had to go, like, you

21 know. Even at night-time on the night shift, you could

22