- Application 1—- Lewisham and Greenwich are refusing to provide the identity of 3 groups of its senior staff that it refers to as the “senior clinicians” , “senior team” and “senior doctors”. Both the Trust CEO and the Communications Director make multiple references to these groups in their statements and seek to rely on them but are also refusing to identify them. These individuals have not been produced as witnesses for the hearing. The senior manager that acted as the instructing client has also not been produced as a witness which is astonishing. This application seeks an Order from a Judge for the individuals referred collectively as the “senior team”, ” senior clinicians” and “senior doctors” to be identified.
- Application 2 — The Trust are seeking to exclude the below statements from 2 consultant anaesthetists
- Application 3 — The Trust are resisting me submitting a statement responding to Mr Ben Cooper QC’s allegations made against me that I was dishonest under oath. It is my position that after reading my statement it becomes clear who is really being dishonest out of me and Mr Cooper! The Trust cannot allow their barrister to make such serious allegations then refuse me a right of reply.
See below relevant supporting documents