IN THE COURT OF APPEAL
B E T W E E N
|SHROPSHIRE COUNTY COUNCIL
|ANNE GREIG ON BEHALF OF HOLLIE GREIG
| -AND –
Statement of Case
- This matter relates to Hollie Greig, a Down Syndrome woman of 31 years, who is the subject of campaigns named ‘Google Hollie Greig’, ‘Justice for Hollie’ and ‘Hollie Demands Justice’. On 22.04.10 as part of the campaign Hollie, her mother Anne Greig and their advocate Robert Green, gave an interview on Edge Media which was then uploaded to Youtube on 24.04.10. On 28.04.10 Stuart Mills, Information officer of the Down’s Syndrome Association threatened a negligence action against Shrophsire Council for failure in their ‘duty of care’. Stuart Mills states that “Psychiatric Advisor Professor Tony Holland concurs with the view of the DSA’s Information Team that the interview was abusive and highly inappropriate”. 1 Up until this date the Down’s Syndrome Association had been supportive of Hollie’s campaign and had been contemplating a press release themselves shortly before press officer John Smithie was dismissed on 26.10.092
- Helen Ogilvy, a Social Worker instructed by the Carer’s Association, initially assessed Anne as a paid Carer for Hollie. Helen Ogilvy was later Hollie’s appropriate adult during her police interview and produced a statement on Hollie’s media campaigns. The report was commissioned by Shropshire Council and has been dated 28.04.103 Helen Ogilvy recommends Hollie’s capacity is tested and that decisions are made by the Court in relation to Hollie, rather than by Anne, alleging that Hollie does not have the capacity to understand the consequences of making false allegations, which are potentially worse than the trauma, fear, hopelessness, suicidal feelings she would suffer from being separated from her mother.
- Adrian Johnson, Head of Community Learning Disability team at Shropshire Council, Tim Collard, Local Authority Solicitor and Nicholas O’Brien of Coram Chambers attended the Royal Courts of Justice on the afternoon of 12.05.10 without any notice to the named defendants Anne Greig and Robert Green 4. They filed Adrian Johnson’s statement signed that day5 and issued a Claim form under CPR Part 8 by Claire Kathryn Porter, Assistant Chief Executive of Shropshire Council, that same day6. The matter was heard in secrecy and exparte the same afternoon by Mrs Justice Hogg at which time a Media Injunction ordered that the continued campaign would be a contempt of court resulting in the imprisonment of the defendants7 if Hollie’s medical records are disclosed or if she attends events where her history of being sexually abused by influential Scottish Paedophile rings is discussed8. The matter was listed to be heard with the defendants invited on 01.07.10. The court papers were posted through the letterbox of Anne and Hollie’s home at 20:10 on Sunday 16.05.10 while they were away. An unsworn statement was filed, falsely claiming that the injunction was left ‘ it in her presence because she refused to accept it’.9 Anne and Hollie were away visiting friends at the time.10
- The defendants have travelled from their homes in Shropshire and Cheshire to attend the Royal Courts of Justice in London on 01.07.10 and 14.06.11. The defendants have requested disclosure of documents but such requests have been consistently denied.11 Hollie Greig has also attended Court. Hollie and both defendants have attended with litigant friends. Hollie’s litigant friend Mrs Hurst, the partially sighted wife of a retired policeman, was denied the opportunity to speak on behalf of Hollie and was wrongly described as Hollie’s carer12. The Judgment of Mrs Justice Pauffley contains a number of errors of fact and law however the defendants were not properly advised to appeal it at the time having not had the opportunity to seek appropriate legal advice.
- Shropshire Council submits Hollie does not have the capacity to consent to taking part in the campaign, as she does not have the capacity to appreciate the real risk of significant harm which will result from the Campaign. Shropshire Council have not stipulated how the real risk of ‘significant harm’ would manifest. Hollie submits that a government ‘cover up’ will not protect her from significant harm. Hollie has already experienced trauma, not only from being the victim of sexual abuse by influential paedophiles between the age of 6 and 20 years old, but also as a direct result of her bravely disclosing the abuse to the Police.
- Hollie has experienced the murder of her uncle shortly after he said the words “If you abuse her again, I will kill you”13 to one of Hollie’s abusers, the abduction of Hollies’ mother instigated and authorised by the friends and advisors of Hollie’s abusers14 claiming that Anne Greig’s reporting of Hollie’s allegations of abuse were symptoms of a paranoid illness.15 Hollie has been incarcerated in institutional care whereby her abusers were allowed access to her to tell her they would kill her.16 Hollie’s home was ransacked by Police and Shropshire Council on 03.06.10 in response to Hollie’s mum sending Shropshire Council a Notice of Claim of Right.17 On 3 occasions over 5 years Hollie has been threatened when she is out of sight of her mother in a public place. These occasions have then been used to suggest that Hollie is imagining things as she has not had the benefit of witnesses to corroborate her evidence.
- Mrs Justice Pauffley has found that Hollie does not have the capacity to litigate and has therefore invited the official solicitor Julie Hine /Helen Clift and their Counsel to represent Hollie. Judge Pauffley has denied Hollie the opportunity to instruct an LSC funded solicitor of her choice18. When Anne Greig has attempted to instruct a solicitor she is told “we are unable to assist19” after being contacted by the Official Solicitor to warn them of the potential damage to their reputation20 or there has been a sudden withdrawal of legal funding leaving a large bill to be paid.21
- Anne Greig responds to the application by Shropshire Council in the capacity of Hollie Greig’s mother, full time (24/7) sole carer of 11 years and legal guardian. Anne Greig submits that she has an acute understanding of Hollie’s needs and her priority is to act in Hollie’s best interest. Anne Greig requests that the court proceedings are struck out as an abuse of process and vexatious proceedings engineered to intimidate Hollie and deprive her of her constitutional rights, liberties and freedoms. Until her case is proved Hollie requests to be party to proceedings, with the help of a litigant friend with whom she has an established relationship of trust.
- Anne Greig submits that, while Hollie may not have the capacity to represent herself due to her communication difficulties, Hollie’s intellectual ability and understanding gives her the capacity to choose who should represent her. Hollie has made it quite clear that she does not wish to be represented by the official solicitor.22 The official solicitor has produced a statement without the benefit of meeting Hollie, demonstrating a conflict of interest between Hollie and the official solicitor.23 The official Solicitors change too frequently for any meaningful relationship to build up necessary to adequately represent Hollie’s interests24.
- Hollie’s capacity to instruct a representative or litigant friend is evidenced by her previous instructions of a solicitor, Nicola Smith of Enable25, in an action for criminal injuries compensation. Hollie through her representative, was successful in achieving 100% Level 14 compensation based on there being evidence that, on the balance of probability, Hollie had been sexually abused including medical evidence of penetration.26 The Criminal Injuries Compensation Appeals Panel relied on the evidence given by Hollie in police interviews, Medical Forensic report of Dr Frances Kelly27 and psychological assessments by Dr Jack Boyle28 and Dr Eva Harding29. Hollie has proved herself to be a truthful and reliable witness despite her communication difficulties.30
- Hollie had to wait 9 years for justice by way of criminal compensation due to Grampian Police ensuring that the investigation into her abuse is ‘restricted’ to senior officers only31, giving the investigating officer DC Alison Durward sick leave during the panel meeting and calling Mr Raymond Cooper, who had been retired for 3 years and who, other than interviewing the main perpetrator Denis Mackie, had no knowledge whatsoever of the case , to give evidence at the Criminal Injuries Compensation Panel on 16.03.05.
- Hollie has a number of confidents in which she trusts to act in her interest. Hollie does not trust strangers due to a number of abuses and traumas she has experienced, in particular;
- Her sexual abuse by 21 named people32, including her own family and families of social workers, police, judges, head teachers and others in positions of trust. The names of the abusers have remained consistent since her allegations were first made and throughout the subsequent 11 years. Hollie has provided police interviews of 19.05.0033, 24.05.00, 17.06.0134, 08.09.0935 however the defendants have been denied access to the original recordings of the ABE interview.
- The murder of her uncle Robert (Roy) Greig on 17 November 1997, being someone Hollie was very close to as she lived with him for 8 years immediately prior to his death. Robert Greig died in very similar circumstances to Claire Morris, whom Malcolm Webster has been convicted of murdering 17 years after her death. Grampian Police would not investigate until there was pressure from Strathclyde and Leeds Police. Robert Greig’s death has never been investigated, despite the suspicious circumstances of his death36 and the connections with the murder of Claire Morris, including two of Hollie’s abusers giving evidence as friends of Malcolm Webster.37 Information regarding the death is being closely guarded with only the autopsy being released after 12 years of requesting it, and the deceased’s Human Rights being used as an excuse.38
- The attempted murder of Hollie’s mother on 02.12.9839.
- The sudden and unexpected abduction of Hollie’s mother 05.09.00, for a period of 72 hours. Hollie observed her mother being forced to the ground by 3 police, 3 social workers and a doctor, injected with a sedative inducing unconsciousness, and taken away in an ambulance as she went to take the rubbish outside in the middle of preparing sandwiches.40 Hollie was then taken by police and a social worker to a Care Home. She reports meeting the perpetrators of the sexual abuse upon her whom told her they would kill her during this period of detainment.
- A wife of a police officer threatening Hollie with the words “I will kill you, I will get you” while she is sitting in the car waiting for her mother to return from the co-op at about 6:30pm on 29.07.0641.
- A further stranger behaving aggressively towards Hollie while she waited for her mum’s treatment to finish from in the dentist waiting room on 13.09.06.
- A further stranger threatening Hollie with the words “We will get you” while waiting in the car at Morrisons on 20.05.10 .
- One of her abusers threatening her and behaving aggressively on 04.03.0242
- The Police raid on Hollie’s home on 03.06.10 in which she returns home to find clear signs of forced entry such as broken doors, and signs of a raid such as her and her mother’s belongings strewn around the home. Since this time Hollie has been fearful of returning to her home. This raid had been carried out the same day as a meeting where Shropshire Council had reported to West Mercia Police that Anne had filed a Claim of Right and had been attending public meetings to speak about Hollie’s abuse. Shropshire Council were aware that there was a public meeting due to take place at a high profile venue in Aberdeen on 05.06.00. Despite having contacted friends and neighbours of Anne and Hollie who had reported that they were safe and well, West Mercia forced entry into every room of their home simply because they were not in. Shropshire Council now deny that they had instigated this break in or took part in it. Police reports clearly state that a Shropshire Council Housing officer attended and that social worker Helen Ogilvy, instructed by Shropshire Council had recommended use of statutory powers.43 West Mercia Police indicated there was an intention to invoke s136 of the Mental Health Act in order to prevent Anne and Hollie attending the event in Aberdeen.44
- The arrest and imprisonment of Hollie’s good friend and advocate Robert Green for ‘Breach of the Peace’ while he was simply walking down the street, the consequence of which has been that Robert Green has been banned from Aberdeen and under bail conditions for two years requiring him to report to his local police station 3 times per week.45
13Hollie submits that while her abusers remain untried for their crimes there is a real and constant risk that she will be separated from the safety of her mother, incarcerated and placed at risk of sexual abuse, death threats and murder. Hollie’s present psychological position is more clearly explained in the report of a recently instructed Psychiatrist and Psychologist46, Counselling records 47 and GP records 48. Hollie’s way of dealing with her fears is to say “Mum, I need a hug”, knowing that hugs are freely given and are always close by. On occasion Hollie is known to express her emotion using pen and paper as taught by her Counsellor to prevent her self harming.49 Since Shropshire Council have commenced proceedings against Hollie and her mother. Shropshire Council and Shropshire NHS have denied Hollie access to therapy for her PTSD and instead insist upon Hollie taking medication which has dangerous side effects such as suicidal ideation.
14Hollie has disclosed the names of her abusers so that she may be protected from them, however her evidence, while considered to be truthful and compelling50 has not been followed up by a proper criminal investigation.51 The perpetrators of the abuse on Hollie are therefore still able to abuse others and abuse their positions of power by tormenting Hollie into keeping silent and commencing proceedings threatening incarceration of her or her mother if she continues to expose their abuse, either by contempt of Court or invoking emergency powers under the Mental Health Act.
15It is Hollie’s case that the proceedings to place Hollie in the Court of Protection is a further instance of the above described abuse, and will be used as a step to remove her from her mother. Due to Hollie’s truthful allegations of sexual abuse having been ignored, the death of her uncle not being investigated, the unjustified abduction of her mother and unwarranted police raids on her home Hollie does not have faith that decisions will be made in her interest when they are made by government officials who have no personal and direct knowledge of her, have a conflict of interest whereby they have sworn an oath other than to uphold the Common law of God as in the bible, and who are protected by the secrecy of the Family Court and Court of Protection.
16On 28.09.04 Aberdeen City Council attempted to formulate a case to remove Hollie from her mother and sought supporting evidence from Dr Sneddon.52 This attempt failed as there had been no medical records since her case was closed from a psychiatric point of view on 23.01.01 by Dr Palin. However, this unceasing harassment by the Scottish Establishment resulted in Hollie and Anne having to escape Aberdeen and set up home in Shropshire, where they had no previous history53.
17Unfortunately the influential paedophile ring seems to have influence over government workers in Shropshire, whereby Shropshire council joined by West Mercia police are justifying the raiding of Anne and Hollie’s home and removal of documents, laptops and photographs by alleging Anne and Hollie were ‘missing persons’ despite having no warrant to break into their home and there being no reason why Anne and Hollie should have been reporting to either government body, and despite police enquiries establishing that Anne and Hollie were safe and well at the time from a local solicitor and their advocate Robert Green.54 Dr Fiona Brodie Fraser also seems to have fallen foul of the influence of the Scottish Paedophile ring by taking steps to instruct a psychiatrist and manipulating the electronic consultation records by Anne and Hollie to suggest that they are suffering from paranoia and a hyperactive imagination.55 It can be evidenced that the notes of the GP who authorised the emergency detention of Anne, Dr Valerie Morris’ handwritten records were also manipulated to discredit Ann & Hollie’s allegations due to the additional writing that has been added at a later date.56
18Hollie knows from 31 years experience that it is her mother who protects her, rather than strangers. Due to the abuses of position that they have been victims of, Hollie and Anne have become very careful of who they place their trust in and have been fortunate in the confidents they have found, who have included lawyers, doctors, psychologists, psychiatrists, Members of Parliament, journalists and other qualified professionals. Anne and Hollie consent to being assessed by those whom they trust. They do not consent to being assessed by complete strangers whose identities require secrecy, such as Kevin L Baker.57
19 Throughout Hollie’s life there has never been any evidence of the following;
- Hollie ever having suffered any kind of abuse at the hands of her mother.58
- Hollie making decisions that have not been in her best interest.
- Hollie lying.59
- Hollie’s mother making decisions that are not in Hollie’s best interest.
- Hollie’s mother having any impairment that would affect her decision making ability with regards to Hollie.60 While Hollie’s mother was detained for 72 hours as described above, she was released after the doctors found there being no grounds to detain her. The concerns of ‘paranoid ideas’ in relation to Hollie’s sexual abuse, embezzlement of Robert Greig deceased’s Estate61 and threats of murder of Anne and Hollie62, that were raised as reasons to incarcerate Anne have since transpired to have been ‘probably’ true, whereby the lack of police investigation is evidence of the police being influenced by the paedophile ring. It seems the incarceration was more likely to have been a tactic to discredit Hollie’s allegations and to frustrate Anne and Hollie’s claim against the perpetrators of the abuse.63 Anne Greig’s psychological position is more clearly detailed in her recent Psychological report64
- Hollie’s medical records being published.
- Hollie suffering as a result of attending events at which details of her abuse is exposed.
- The media attention in relation to Hollie’s exposure of abuse being used in any proceedings for defamation or libel by anyone that is alleged to have abused Hollie or their position of power.
20When considering Hollie’s interests, her mother has the benefit of understanding Hollie’s special needs for which she has endeavoured to meet ever since Hollie was born prematurely weighing only 2lb 10oz.65 Hollie has had hearing and speech impediments66 which her mother has sought to overcome by intuitively understanding what Hollie is saying. Hollie feels more able to communicate when her mother is available to assist her.
21Neither Stuart Mills, nor Professor Tony Holland, as mentioned in his email have ever met Hollie. There has never been any appropriate investigation into Hollie’s welfare by Shropshire Council. Shropshire Council seek to rely on a statement by Adrian Johnson who is not registered by the GSCC and has never assessed Hollie, having only met her once in connection with direct payments, and a report by Dr Carolyn McQueen, a Scottish psychologist who has never met Hollie and Helen Ogilvy a Social Worker who has never assessed Hollie.67
22Hollie has a fault in the tissue of her heart and scoliosis of the spine entitling her to disability transport. Hollie’s disability causes her discomfort and to tire quickly. Hollie requires plenty of rest and it is therefore not considered to be in her interest to be out in the community, away from her mother, particularly when coupled with the recollections of Brokerage Services employed carers prostituting her. It seems Shropshire Council’s only intention is to separate Anne and Hollie without taking into account Hollie’s very traumatic history of abuse.
23Hollie enjoys being ‘home’ with her mother, helping keep the home and garden, shopping, pets, bowling, soap operas, writing, reading magazines and watching sitcoms. Hollie also enjoys meeting the carefully selected friends that she is introduced to, who show Hollie warmth and empathy.
24Hollie feels very angry about the abuse she has suffered as a child and as a young adult. Hollie was prostituted by her father and her employed carer among families with powerful connections, such as Sheriff Graham Buchanan.68 Hollie would like the perpetrators of the abuse to be tried in a criminal court with a jury and requests that prosecution is initiated without further delay. Until a proper criminal case is conducted, Hollie finds relief by sharing her experience of abuse with those who recognise that she is telling the truth as this gives her some hope that justice will be served and she will at last be protected from her abusers.
25Hollie submits that it is not in her best interest to prevent her from sharing her experiences of abuse, as this would deny her the opportunity to seek public support in placing pressure on Grampian Police to convict her abusers. Hollie feels empowered when able to exercise her freedom of expression. Hollie feels discriminated against when her disability associated with Down Syndrome is used as an excuse to take away her freedoms and liberty and to deny her a fair trial.
26Hollie would like her case to be heard in the public arena so that she can be tried by her peers before any decision is made to incarcerate her or take away her rights or liberties. This is her fundamental right to freedom.69 However, Hollie does support the injunction of against Greg Lance Watkins and other government disinformers from publishing derogatory articles regarding Hollie and her mother.70
27Hollie would like her mother to be recognised as a safe full time carer for Hollie, who is able to recognise Hollie’s needs and act in their best interest. Hollie would like to attend activities and counselling but only in the presence of her mother.
28In the interest of a fair hearing Hollie requires further disclosure in order to make out her case. Hollie, Anne and Robert Green have attempted to retrieve the relevant information from various sources independently but are met with unreasonable delays and refusals. Directions are therefore requested to assist in the disclosure of the relevant material held by various government agencies.71