| Flowers in Gods Garden - Holly Wells
and Jessica Chapman - Documents |
25/11/03 - Soham Trial Transcript
Tuesday, 25 November 2003
SKY News
Richard Latham is the chief prosecutor; his colleague
on the prosecution team is Karim Khalil QC. Stephen Coward
QC is Ian Huntley's defence barrrister. Michael Hubbard
QC is Maxine Carr's defence lawyer. Mr Justice Moses is
the judge. Other witnesses and lawyers are introduced
as they appear.
Page 01 02
03
MR COWARD
did you at any time go into the ditch at the deposition
site, where the bodies were?
PATRICIA
WILTSHIRE
yes.
MR COWARD
no doubt because you say right having got there you looked
for evidence for a continuation of B, up to the deposition
site ?
PATRICIA WILTSHIRE
no I didn't.
MR COWARD
you didn't?
PATRICIA WILTSHIRE
a continuation of B up to the deposition site, no the
obvious way in was point A, the obvious way in from where
to where the bodies lay was in the point A.
MR COWARD
if you were standing near the bodies you have already
said you could see footprints near the bodies?
PATRICIA WILTSHIRE
yes.
MR COWARD
if you could see footprints near the bodies wasn't it
worthwhile looking to see if there were any footprints
heading on the line to point B?
PATRICIA
WILTSHIRE
you don't understand. The ditch was full of twig litter
and leaf litter you would never have seen a footprint.
I certainly could see footprints, it was not soil leading
up from the ditch.
MR COWARD
I'm looking at my notes, target sampling was where a person
probably stood because there were foot marks?
PATRICIA WILTSHIRE
yes, that's going down the bank into where the bodies
lay.
MR COWARD
I see so there were foot marks there?
PATRICIA
WILTSHIRE
Yes.
MR COWARD
and were there any foot marks between the position of
the bodies and the line of B, you didn't look?
PATRICIA WILTSHIRE
no, there couldn't have been because it was just thick
litter, you couldn't have seen footprints in soil because
it was thick twig litter.
MR COWARD
at some point if someone had to come from B up to where
the bodies were found, they will have to go up a bank
wouldn't they?
PATRICIA WILTSHIRE
I didn't investigate the bank at that point.
MR COWARD
that's not the answer to my question, they would have
had to go up the bank?
PATRICIA WILTSHIRE
I'm not even sure if there was a bank there because I
didn't approach the bank. I didn't know how steep that
bank was; I didn't approach it so I can't answer your
question.
MR COWARD
my Lord, I'm looking at 6292. Mrs Wiltshire, if you have
the witness statements with the page number at the bottom
right hand corner, you will help us all?
PATRICIA
WILTSHIRE
I don't have it.
MR COWARD
do you have your statement of 12 June 2003?
PATRICIA WILTSHIRE
yes. The one relating to the nettles.
MR
JUSTICE MOSES
find the statement, 12th June 2003. Is that the one you
want?
PATRICIA WILTSHIRE
I have got one of 12th May.
MR JUSTICE
MOSES
do you want the 12th June?
MR COWARD
12th June, my Lord, yes.
MR JUSTICE
MOSES
I have not got that one?
PATRICIA WILTSHIRE
I have got 12th June 2003, my original.
MR
COWARD
here it is, 12th June 2003, you are going back over what
you did on the 18th August 2002. you say, at the bottom
of our 6292, "Accompanied by Peter Murphy I visited
the site on 18th August", that's 2002, "at 9
o'clock in the morning, before other specialists were
allowed access, officers had preserved the environment
of the deposition site very carefully and I was able to
recognise now a band of vegetation that had been trampled
in the recent past." that's A?
PATRICIA
WILTSHIRE
yes.
MR COWARD
this is June of 2003, and there is still no mention of
B, is there?
PATRICIA WILTSHIRE
no, but I told you, I didn't take any notes about B.
MR COWARD
how did it come about that you did begin to take notes
of B, how did it come up?
PATRICIA WILTSHIRE
I was asked about it, I suppose.
MR
COWARD
by whom?
PATRICIA WILTSHIRE
I honestly can't remember. I think it must have been counsel.
MR COWARD
can you help us as to when you were first asked to consider
whether there had been a second line of entry? if it is
a conversation with counsel, I'm not going to enquire
about it. All I would like to know is when. Do your notes
help you as to when you were first asked to incorporate
this in your----?
PATRICIA WILTSHIRE
no, I can't help you I am afraid.
MR
COWARD
I understand my learned friend, very helpful as usual,
can give a date. We can see with confidence though it
is June 03?
PATRICIA WILTSHIRE
I don't remember the date. I can't remember the date.
MR COWARD
we can check it this way, I think, if we look at 6334
G, which is 29th August, you do make reference in that
statement to pathway B, that's August this year?
PATRICIA WILTSHIRE
I am afraid I don't have a copy of that statement.
MR JUSTICE MOSES
we do anyway.
MR COWARD
this is on 18th August the previous year and says "At
this time I noted two faint pathways." you say this
"the second pathway was approximately thirty meters
from the viewing point, also in the direction of the airbase
perimeter, this pathway ran diagonally from the Common
Drove drag to the ditch. I initially said in North-westerly
direction, it turned out it was North, North-east."
MR COWARD
it goes on I have identified an Alder tree this second
pathway passes very close to. The pathway was to the north
of the tree trunk base about half a meter from the base.
The tree itself had a starring on its trunk, the tree
I identified. At this time there was a detached branch
leaning against the tree which I do not remember being
there.
MR JUSTICE MOSES
will someone ensure she has this statement in front of
her?
PATRICIA WILTSHIRE
I remember this statement , I gave it to a police officer,
I did not make this statement myself, I just signed it.
MR COWARD
on 29th August you remembered all this detail?
PATRICIA WILTSHIRE
yes.
MR COWARD
Mrs Wiltshire, this is not a case, is it of trying to
help with it?
PATRICIA WILTSHIRE
no, it isn't, I actually remembered the place, I remember
the path and the vegetation there. I just remembered it
as I would remember your face.
MR COWARD
one question I think I can ask without breaching legal
privilege, but pause before you answer it, in case objection
is taken to it. At the time you made that second statement
on 29th August, were you aware in your own mind that one
of the possibilities being considered by the prosecution
as a whole was the possibility of a return visit to the
site?
PATRICIA WILTSHIRE
I wasn't really aware of that. I wasn't quite - didn't
really understand the significance of that path.
MR JUSTICE MOSES
I am sorry I do not really understand the answer. What
do you mean you are not really aware?
PATRICIA
WILTSHIRE
well, I wasn't aware that there was any, that this might
be considered to be another path taken by the offender.
MR JUSTICE MOSES
that's not the question you were asked. ask it again.
MR COWARD
my Lord, I will try and remember it. .
MR
JUSTICE MOSES
the point about the the theory being advanced that there
were two visits to the site.
MR COWARD
at the time you made this first statement on the 29th
August this year, were you aware of the question as to
whether there had been a return visit to the site?
PATRICIA WILTSHIRE
I wasn't aware that other people were asking that question
but I had asked it myself, of myself.
MR
COWARD
why did you think to ask yourself that question in August
of 2003?
PATRICIA WILTSHIRE
because of the evidence from the shoes, the position of
local evidence from the footwear.
MR
COWARD
when had you done your research of boots and trainers?
PATRICIA WILTSHIRE
I would have to go back to the dates in the record. could
you help me on that one.
MR COWARD
I do not mean the exact date, what month and what year?
PATRICIA WILTSHIRE
the analysis of the shoes, the footwear, was done as soon
as I was given the exhibits.
MR COWARD
which was roughly when?
PATRICIA WILTSHIRE
I am afraid I would have to look through all my notes
because I can't remember.
MR COWARD
it was relatively shortly after you had visited the site
in August 2002?
PATRICIA WILTSHIRE
yes, that would be correct.
MR COWARD
you do your test and according to your evidence, you find
significant evidence which may connect the trainers to
the deposition site?
PATRICIA WILTSHIRE
yes.
MR COWARD
not quite so good but still some significant evidence
that the boots were connected with the site?
PATRICIA WILTSHIRE
yes.
MR COWARD
let's say that was in September/October of 2002, you did
that work. You don't have to be a rocket scientist to
work out there and then that there might be something
significant in both items of footwear having a possible
link to the Drove, do you?
PATRICIA
WILTSHIRE
Yes, I think you are right but it need not be significantly
associated with that other path.
MR
COWARD
you, as a scientist, examined two pairs of foot wear?
PATRICIA WILTSHIRE
three, actually.
MR COWARD
one we discard because you couldn't find any connection.
but you have two which potentially connect to the site?
PATRICIA WILTSHIRE
yes.
MR COWARD
and you as a highly intelligent woman to think yourself,
hang on a minute, did he go in with one pair, change his
shoes and come out or is the only logical explanation
that there have been two visits to the Drove?
PATRICIA WILTSHIRE
I thought to myself there could well have been two visits
to the drove.
MR COWARD
the statement that you made in relation to the boots we
can date. 6277 is the reference to the boots themselves.
the date of that statement is 12th May 2002 - I beg your
pardon, 2003. was that shortly before ----?
PATRICIA WILTSHIRE
I'm sorry this statement is about what?
MR
JUSTICE MOSES
boots?
PATRICIA WILTSHIRE
I wish had the same papers that you have.
MR
JUSTICE MOSES
well, a set of these papers it is 12th May 2003. 6277.
page 9 of the relevant pages, the statement 12th May 2003.
yes, what was this question?
MR COWARD
paragraph 6.3, towards the bottom, predominantly, the
brown suede boots are unlikely to be relevant to the inquiry,
however both Nike trainers and black boots have assemblages
similar to that of the deposition site. the Nike trainers
were more heavily laden (inaudible) and it is notable
both left and right trainers had spores. it is possible
the accused made two visits to the site or other very
similar place, wearing each pair of shoes on one occasion?
PATRICIA WILTSHIRE
yes .
MR COWARD
and the statement goes on to say "and this accords
with what I observed at the scene on 18th August 2002",
namely two tracks?
PATRICIA WILTSHIRE
whether does it say that please.
MR
COWARD
it doesn't, I am asking you why it doesn't?
PATRICIA WILTSHIRE
Well, why should it.
MR COWARD
according to the evidence you are giving the Jury now
you had known since August the previous year that there
were two tracks. You have now examined the boots, you
are doing a report about the boots. You say this suggests
two visits to the site?
PATRICIA WILTSHIRE
Yes.
MR COWARD
Yet there is no reference to finding a second route. Why
would there be a second route?
PATRICIA
WILTSHIRE
He could have gone along the first one twice or he could
have just been in the general area.
MR
COWARD
you would have told the Jury you identified two routes,
both leading towards the deposition site. You have now
discovered two pairs of footwear; could potentially he
have been to that site?
PATRICIA WILTSHIRE
yes.
MR COWARD
and you failed to mention that back in August you had
actually identified route B as well?
PATRICIA
WILTSHIRE
the person that committed this offence could have been
to that site in two separate pairs of shoes, anywhere
along that track really, in the vicinity of where the
victims lay and they would pick up a similar assemblage.
I fail to say that they would have had to walk down this
a track to pick up on the other pair of shoes.
MR COWARD
do you think it might have assisted the investigating
officers when you examined the boots to tell the senior
investigating officers you do remember I told you about
the second route, B, that I saw in August?
PATRICIA
WILTSHIRE
I thought that was the function of the statement. They
had my signed statement they can see my conclusion. I
had told people about the two paths. I reported on what
I was asked to do.
MR COWARD
what we know is as late as this statement in fact, you
had nothing in writing either in your notes, or in any
statement you have made, referring to path B?
PATRICIA WILTSHIRE
no, because we didn't consider it important at the time.
MR COWARD
there isn't a possibility, Mrs Wiltshire, that maybe you
are trying too hard to help here?
PATRICIA
WILTSHIRE
no, I really don't think so.
MR COWARD
The sequence of events is actually that you examined the
boots; you see both could be linked to the site, and there
has to be an explanation - if both are linked to the site
- so B has to have to come into existence?
PATRICIA
WILTSHIRE
no, no. I just explained to you. I didn't even consider
that the two pairs of boots - or one pair of boots - had
been down path B. I said that both pairs of shoes could
pick up that assemblage along that track anywhere near
where the deposition site was; they don't have to have
gone along path B.
MR COWARD
I move to the boots.
MR JUSTICE MOSES
are you going to be much longer.
MR
COWARD
my Lord, I am. .
MR JUSTICE MOSES
then we'll stop for lunch. Five past two, ladies and gentlemen.
Don't talk to anybody over lunch.
Hearing
adjourned - will resume after lunch
MR COWARD
Mrs Wiltshire, before we broke off remember I was asking
you if you could help us as to when you completed your
examination of the trainers and the boots. Having had
the chance at the break, can you help us any further as
to when your research on those two items was completed?
PATRICIA WILTSHIRE
I have not been able to - I did not think about the case
over lunch at all. I didn't speak to anyone or think about
it, so I'm very sorry I haven't read my notes but I think
we established it was shortly after we had the exhibits.
MR COWARD
do you have a record of when you received the boots in
your notes?
PATRICIA WILTSHIRE
they are in the lab notes, I believe, they are not here,
but it is shortly after I received the exhibits that they
were processed by my technician and soon after that I
analysed them. also my colleague, Dr Judy Webb, helped
me do the analysis.
MR COWARD
the boots arrive; you are assisted by colleagues, you
do your work, when the work is finished obviously the
boots are sent back to the police?
PATRICIA
WILTSHIRE
yes, they are collected and taken to anyone else that
needs them.
MR COWARD
I take it on the date they were taken back from you to
the police by then you had completed your examination?
PATRICIA WILTSHIRE
not necessarily, but I believe it was in this particular
case.
MR COWARD
thank you. so far as coming now to the question of what
was found on the boots, would I be right in saying that
every single item that appears on the list that we have
in our jury bundle, is an item of plant, shrub or herb
which is found widespread in East Anglia?
PATRICIA
WILTSHIRE
many of the plants there are very common.
MR
COWARD
very common? I think some of the most uncommon ones, if
we look right at the bottom, rock rose, 61, is relatively
uncommon, isn't it?
PATRICIA WILTSHIRE
yes, it is, very.
MR COWARD
and (inaudible) 63, is quite a rare one?
PATRICIA
WILTSHIRE
I have come across that quite frequently.
MR
COWARD
the rock rose is fairly rare?
PATRICIA
WILTSHIRE
usually confined to more chalky areas.
MR
COWARD
what this chart shows us is that in fact when you were
taking your samples you did find rock rose?
PATRICIA WILTSHIRE
yes.
MR COWARD
but it wasn't found on the boots or the car or anything
else?
PATRICIA WILTSHIRE
no.
MR COWARD
that's why it is on the bottom of the list?
PATRICIA WILTSHIRE
yes.
MR COWARD
did you go anywhere else in East Anglia to choose a spot
roughly similar to Common Drove to see what results you
got there so that you have got a control sample as it
were?
PATRICIA WILTSHIRE
a control sample of Wangford Drove you mean?
MR COWARD
yes?
PATRICIA WILTSHIRE
no, what we normally do, we did go to different places.
I was unable to go because I had been in hospital and
Mr Murphy did it for me, but he actually looked at many
of the other Droves to see if there was any similar vegetation.
MR COWARD
no collection was done of samples of anywhere else at
all, was it?
PATRICIA WILTSHIRE
some were taken at the college but we didn't take control
samples as such, soils from anywhere else, no.
MR COWARD
when you say at the college, where were the samples taken
from, that were taken at the college?
PATRICIA
WILTSHIRE
again these were taken by Mr Murphy and they were taken
in relation to the playing field.
MR
COWARD
yes but where? the garden of number 5?
PATRICIA
WILTSHIRE
is that the accused's house?
MR COWARD
yes?
PATRICIA WILTSHIRE
no I didn't take samples from number 5, there is no need
to, absolutely no need to.
MR COWARD
why not?
PATRICIA WILTSHIRE
because I would have no, I have really vast experience
of looking at strands of vegetations and making a reasonable
prediction of what I'm going to find and if there is somewhere
that could be similar, obviously one would take control
samples, if it doesn't have the similarity of taxa growing
there I can tell you now it is unlikely for me to get
a similar assemblage on any exhibit.
MR
COWARD
surely as a scientist this is a way, isn't it, in which
you get a truly solid basis for coming to your conclusions.
You don't just take the site of Common Drove and a pair
of boots; you take 40 pairs of boots, 20 from the policemen
at Common Drove, 20 from the policemen who had done the
searching at the college. Did you do that?
PATRICIA
WILTSHIRE
No, I didn't, there was no need to.
MR
COWARD
do you see any advantage in doing it?
PATRICIA
WILTSHIRE
no I don't, not in that particular instance. I have done
very many cases now where I have analysed very many shoes,
and been able to just eliminate the ones that are not
relevant and pick on ones that are relevant, and even
in cases where offenders have admitted their guilt, I
have usually been right - always been right in actual
fact - in the cases I have dealt with.
MR
COWARD
the Members of the Jury know because we have had evidence,
that following the disappearance of the girls, Mr Huntley
was present at various parts of the college, near the
playing field, while searching was going on. We also know
Mr Huntley has a dog and one takes dogs for walks. He
therefore is likely to go to a variety of places, isn't
he, around number 5 and pick up pollen?
PATRICIA
WILTSHIRE
yes, I'm sure he would.
MR COWARD
if of course you have taken footwear from other people
who have been covering the same sort of area that Mr Huntley
had been covering, if they were the same as Mr Huntley,
that would be one position, if their pollen was significantly
different, it would be position number 2, wouldn't it?
PATRICIA WILTSHIRE
yes.
MR COWARD
what would that tell you as a scientist?
PATRICIA
WILTSHIRE
I don't think it would be very useful. You must remember
I did do another pair of shoes from Mr Huntley that actually
came from his own home and they did not match the site.
There were certain taxa in common but they simply did
not match the assemblage of the site and to take the people
at random and shoes at random would be most unproductive.
I know this from experience in past cases .
MR COWARD
if you think about the method that you used, could I suggest
an analogy of the technique you used, the science that
you used? We are all familiar with identity parades, aren't
we?
PATRICIA WILTSHIRE
yes.
MR COWARD
and the essence of an identity parade is that you have
a suspect in a line with a number of other people, 6,
8, 10, whatever?
PATRICIA WILTSHIRE
yes.
MR COWARD
and then the witness is brought in to try to see if he
or she can identify the one that she says attacked her?
PATRICIA WILTSHIRE
yes.
MR COWARD
your identification parade only has the possible suspect
on, there is only one person there, isn't there?
PATRICIA WILTSHIRE
I think it is a particularly good angle actually. If you
have an identity parade, when people are identifying the
faces, they are subjected to all sorts of subjective prejudices
and so on. In this particular instance I have no pre-conceived
ideas as to what I'm going to find on any shoes at all.
I'm not trying to make anything match anything, I just
find what is there and it is sensible to target rather
than do things at random.
MR COWARD
you have said that, but in actual fact, the sole exercise
you carried out was to see whether you could establish
a link between Mr Huntley, his car, his boots and the
Drove?
PATRICIA WILTSHIRE
yes.
MR COWARD
thank you. And you made no attempt to get any sort of
controls into your experiment?
PATRICIA
WILTSHIRE
but----
MR COWARD
you were looking in a straight line between the Drove
and Mr Huntley, weren't you?
PATRICIA
WILTSHIRE
if what, sorry.
MR COWARD
between the Drove and Mr Huntley.
MR
JUSTICE MOSES
the Drove and his boots, actually.
PATRICIA
WILTSHIRE
Mr Huntley's boots. yes, but I have done, as I explained
to you, very, very, very many dozens of shoes and boots
and other footwear from many, many offenders over the
past and I have a large experience of finding out what
I am likely to find where on footwear. I think that the
road you are going round is erroneous.
MR
COWARD
Mrs Wiltshire, isn't it exactly in those circumstances
that the greatest danger arises? It is because of exactly
that state of mind, I suggest, that it is essential to
do proper controlled, scientific tests?
PATRICIA
WILTSHIRE
what you are suggesting is that it is not a proper controlled,
scientific test.
MR COWARD
but it is better than yours?
PATRICIA
WILTSHIRE
no, it is not.
MR JUSTICE MOSES
Mr Coward, just before you continue the argument, can
you be - it is my fault - be precise what you say the
control ought to have been? It is pointless preparing
my boots if I have not been to East Anglia, so quite what
is it you are suggesting? I'm not seeking to undermine
it - I just want to know what the specific suggestion
is.
MR COWARD
that what might have been of value is if you had taken
possession of the shoes of 20 police officers who had
been at the Drove, and 20 police officers who had been
on the college campus and the fields around at Soham.
Of course we all wear foot covers at the Drove so nobody
had exposed footwear to start with, and these are plastic
and not really relevant.
MR JUSTICE
MOSES
you are not meeting the point. Ask the question again
forget about covers for a moment, forget about the reality,
think about the scientific approach.
MR
COWARD
Mrs Wiltshire, may I suggest you have exactly fallen into
the trap. if you had taken the footwear of 20 police officers
at the Drove who were wearing covers on their boots, and
they turned up with results like the trainers and the
brown shoes, what do you say then?
PATRICIA
WILTSHIRE
on the covers? or on the boots.
MR COWARD
no - on the boots?
PATRICIA WILTSHIRE
from my experience it would be highly unlikely that they
would unless they had contacted the soil of the Drove.
MR COWARD
forgive me, I don't think that's an answer to my question.
if results were found on the police officers' boots -
even though they had worn covers at the site - that were
roughly similar or very similar to the results from the
trainers and the boots, what would it tell you?
PATRICIA WILTSHIRE
it would tell me that they had been to a place like the
Drove or had been to the Drove. if they were as similar
as Mr Huntley's boots were.
MR COWARD
but by result of the methods that you used, this is now
unascertainable, isn't it?
PATRICIA
WILTSHIRE
not really, we could go back and do it, if you like.
MR COWARD
what, take the boots now?
PATRICIA WILTSHIRE
yes, we could go back to the site, we could take and see
what the similarity is because broadly the vegetation
is similar and of course pollen and spores are residual
are still there in the soil and it could be repeated if
you so wish.
MR COWARD
again Mrs Wiltshire have you not fallen into the trap
of saying those boots would have to go back to the site?
PATRICIA WILTSHIRE
well, we could do whatever you wanted, we could test it
any way you like, I chose not to do it because I did not
think it was appropriate because of my past experience
with boots and shoes.
MR COWARD
if of course those 20 pairs of boots of which had been
protected at the site by covers, you found a similar pattern
to that of Mr Huntley on the boots, and that police officer
said that was the first and only time I ever went to the
Drove, where are you then?
PATRICIA
WILTSHIRE
could you repeat that, please?
MR COWARD
if you took the shoes of Officer Smith, who has worn covers
at the scene and you examine the shoe, the cover, and
you find a similar pattern as you found on the trainers
and brown shoes, and police Constable Smith says that
was the only day I ever went to the Drove, I have never
been there before, I'm a Cambridgeshire officer, what
would you say then?
PATRICIA WILTSHIRE
then he had been in a place very similar to the Drove,
with the same assemblage of plants.
MR
COWARD
of course, the more of those you found the less convincing
it would be to make the connection which you are making
agreed?
PATRICIA WILTSHIRE
it would still not deter me from saying that Mr Huntley's
boots had been either at the Drove or in a place very
similar to the Drove, whatever anyone else found on their
boots.
MR COWARD
but you do appreciate the difference as seen through the
eyes of anybody having to decide a very important criminal
case between those two positions, or don't you?
PATRICIA WILTSHIRE
I do see the need for proper controlled experiments. there
are many constraints in forensic investigation which do
not allow you to do such experiments. What you are suggesting
is highly conjectural but feasible and of course what
you are saying is perfectly reasonable, that in this particular
instance I think it is an erroneous path to go down.
MR COWARD
thank you.
MR KHALIL
you made your work available to others to consider?
PATRICIA WILTSHIRE
yes I do.
MR KHALIL
have you in return been presented with any sets of the
boots or shoes and asked to consider them?
PATRICIA
WILTSHIRE
in other cases.
MR KHALIL
in this case?
PATRICIA WILTSHIRE
in this case? no, I was only given the three pairs.
MR KHALIL
as the- as to two of those pairs of shoes and boots, BMX
5 and 6, they appear on the schedule?
PATRICIA
WILTSHIRE
yes, they do.
MR KHALIL
as to the third pair of boots, the Brasher boots, why
are they not on your schedule, Miss Wiltshire?
PATRICIA WILTSHIRE
because the assemblage did not match anywhere near the
assemblage of Wangford Road.
MR KHALIL
a point was made of the common occurrence of many of the
items under the taxa heading?
PATRICIA
WILTSHIRE
yes.
MR KHALIL
are you saying that because they are all common you would
expect to find them on any sets of boots or shoes you
examine or not?
PATRICIA WILTSHIRE
no, I wouldn't because what is important there is the
assemblage and there are taxa there that are really, well
not rare but unusual to find in such an assemblage.
MR KHALIL
so far as the trainers ----.
MR JUSTICE
MOSES
I'm terribly sorry could you pick up that point, the unusual
ones in that assemblage. We have had two or possibly one,
I wonder whether any of the first 58.
MR
KHALIL
my Lord, I was about to do that by reference to the footwear,
if I may. Mrs Wiltshire, so far that the trainers and
the boots are concerned and the coincidence of taxa on
those items, can you assist us as to whether any of the
taxa are less common than others in your terms, please?
PATRICIA WILTSHIRE
one that stands out to me is tucryum, sorry the wood sage.
MR KHALIL
46 is that?
PATRICIA WILTSHIRE
number 46, that is a wooden (inaudible) plant. another
one is the meadow sweet.
MR KHALIL
number 50?
PATRICIA WILTSHIRE
number 50, which is a plant of damp places, damp ditches
and so on, you don't pick that up so readily from gardens
but remember, please that we have to consider the whole
assemblage. it is in relation to the whole assemblage.
MR KHALIL
have the point about looking at the entirety of course?
PATRICIA WILTSHIRE
yes, again cereals, a considerable amount of cereal on
the boots and shoes and there were cereal fields either
side of Wangford Drove and quite a lot of cereal pollen
in the controls.
MR JUSTICE MOSES
number?
PATRICIA WILTSHIRE
29, my Lord.
MR JUSTICE MOSES
thank you?
PATRICIA WILTSHIRE
another one, although it is a common plant, mugwort was
very prolific, that's number 23, mugwort was very, very
common at Wangford Drove and it is present on every exhibit.
The heather is a very, very common plant in East Anglia
but not common around Wangford Drove, but it is there
on the boots and it is on the car. from the tree point
of view there are taxa there for example; hawthorn, and
of course the alder itself and even the maple, they are
not easily picked up - well certainly not hawthorn and
willow is not easily picked up unless you walk underneath
the trees or very, very close to the trees - and then
we have the sedges, that is number 49, now, they are very
common plants but they are plants of wet, damp places
and there was a lot of sedge pollen at Wangford Drove
and of course the fern is terribly important because the
ditch itself was dominated by ferns and there was plenty
of fern pollen in the control and of course there are
on the trainers.
MR KHALIL
that's number 57, is it?
PATRICIA WILTSHIRE
number 57 particularly, yes.
MR KHALIL
Pollen on it?
PATRICIA WILTSHIRE
And bracken too were on the training - please remember
number 57 could be number 53 or 54 if the spore lost its
outer coat.
MR KHALIL
so that's a sub class?
PATRICIA WILTSHIRE
a sub class, yes.
MR KHALIL
57 could be an example of 53 or 54, depending on its (inaudible)?
PATRICIA WILTSHIRE
that's right.
MR KHALIL
from what you saw you couldn't differentiate between the
two?
PATRICIA WILTSHIRE
no, it wasn't possible.
MR KHALIL
you told us you have experience of examining many types
of shoes or numbers of shoes in many cases?
PATRICIA WILTSHIRE
very many.
MR KHALIL
Can you assist us with any example that may help here,
please, as to examining a number of shoes, either including
or excluding them from your consideration, practical comparison.
MR JUSTICE MOSES
do you understand the----
MR KHALIL
The practical comparison of ruling shoes in or ruling
shoes out in the----
PATRICIA WILTSHIRE
I'm still not clear.
MR JUSTICE MOSES
nor am I.
MR KHALIL
have you done other cases where you have had more than
simply one or two pairs of shoes to compare?
PATRICIA WILTSHIRE
oh, yes.
MR KHALIL
in such cases have you examined numbers of pairs of shoes?
PATRICIA WILTSHIRE
yes, I have.
MR KHALIL
and have you been able to differentiate for your purposes
between those which may have a link to the site and those
which may not?
PATRICIA WILTSHIRE
Yes, I have, many times.
MR KHALIL
is there any example that you can afford us which would
demonstrate that?
PATRICIA WILTSHIRE
a specific case? .
MR KHALIL
Yes a specific case?
PATRICIA WILTSHIRE
Yes there was a case last year in Hampshire, where there
were 12 pairs of shoes involved and I was able to, I did
it without knowing who the shoes belonged to and I was
able to pick up two pairs of shoes that really matched
a department site. there were the ten other pairs that
came from the homes of the two offenders, this was in
Portsmouth and both had worn the shoes around Portsmouth
and its environs and I was able to pick out the two pairs
of shoes, (inaudible).
MR KHALIL
as far as this case is concerned, you examined three pairs
of footwear?
PATRICIA WILTSHIRE
yes.
MR KHALIL
of the three, you exclude one?
PATRICIA
WILTSHIRE
yes.
MR KHALIL
in addition to footwear you examined also a motor vehicle?
PATRICIA WILTSHIRE
yes, I did.
MR KHALIL
you also examined a petrol can?
PATRICIA
WILTSHIRE
yes.
MR KHALIL
and your conclusions as to those?
PATRICIA
WILTSHIRE
well, the motor vehicle had so many of the taxa that were
common to Wangford Drove, one could only assume it had
been a place or very likely to have been there. as regards
the petrol can, if you compare the petrol can with the
profile of the boots, DMX 5 and 6, there is very close
accordance between them and one might assume that they
had been in similar places.
MR KHALIL
right. I will just ask you, you have been pressed on dates
of examination of different items and when they were completed,
you told me initially your first test would be by way
of screening or scanning?
PATRICIA WILTSHIRE
yes.
MR KHALIL
I think your first report relating to your - page 6269?
PATRICIA WILTSHIRE
I still do not have the papers.
MR JUSTICE
MOSES
why don't you just put the dates and if there is any -
she can go away, look it up and if they are wrong the
defence can be told.
MR KHALIL
on the 12th May of this year, you were provided with what
was described as an interim report?
PATRICIA
WILTSHIRE
yes.
MR KHALIL
on the results of panalogical scanning of exhibits?
PATRICIA WILTSHIRE
Yes.
MR KHALIL
Has that always been carried out as of that date?
PATRICIA WILTSHIRE
yes, simply scannings so I could look for the most pertinent
exhibits.
MR KHALIL
you then provided a statement on 1st July, my Lord 6306,
in which you dealt with what I think were your counted
results, beyond the mere scanning results, is that right?
PATRICIA WILTSHIRE
yes, not all of them but most of them.
MR
KHALIL
so far as the two routes are concerned you have been asked
about what we call route B?
PATRICIA
WILTSHIRE
Yes.
MR KHALIL
we know you returned there on 29th August of this year?
PATRICIA WILTSHIRE
yes.
MR KHALIL
when you returned there on 29th August were you able to
see the location of the route that you claim to have seen
the previous day?
PATRICIA WILTSHIRE
yes I could.
MR KHALIL
was there anything there that assisted you with that?
PATRICIA WILTSHIRE
it was simply the configuration and the - just like remembering
someone's face. I remember the place, I remember the plants,
I remembered the ditch.
MR KHALIL
have you in any way made up the fact that you say you
saw that second route?
PATRICIA WILTSHIRE
definitely not.
MR JUSTICE MOSES
you said it before, when looking around the area of the
Close, number 5, and round there, did you need to take
any samples to tell you that it was not the same sort
of site as the ditch round the Drove?
PATRICIA
WILTSHIRE
I didn't really need to take them.
MR
KHALIL
what is the distinction?
MR JUSTICE
MOSES
what this distinction doesn't run through each plant?
PATRICIA WILTSHIRE
First of all I couldn't find any ferns and they were important
to the investigation. I couldn't find large Alder trees
but it understood an Alder tree has been found there now.
It was simply - also the mugwort, I found one or two mugwort
plants way over in the playing field. Most of the nettles,
they weren't with the mugwort, and I think to get the
assemblage I found ,one would need to have these things
in juxtaposition.
MR JUSTICE MOSES
thank you.
MR COWARD
I forgot to deal with one matter, could I also seek your
Lordship's leave to deal with one matter arising from
your Lordship's question.
MR JUSTICE
MOSES
absolutely.
MR COWARD
you said you were not able to find any ferns at Soham?
PATRICIA WILTSHIRE
I didn't find any Butler ferns no.
MR
COWARD
I am looking at our big schedule under boots DMX 5 and
6, you did not find any ferns on those boots did you?
PATRICIA WILTSHIRE
no I didn't.
MR COWARD
the other matter is this is it now within your knowledge
that in fact at Soham there are Alder trees present in
the wind break near to number 5 and there are also individual
specimens on the far side of the playing field behind
the hangar?
PATRICIA WILTSHIRE
yes, I understand there are.
MR KHALIL
does that knowledge effect any of your conclusions?
PATRICIA WILTSHIRE
no, it does not.
MR JUSTICE MOSES
that will teach me not to ask questions. thank you very
much. {the witness withdrew}.
MR LATHAM
Mr Moncrieff, please.
MR LATHAM
your full name, please?
ANDREW MONCRIEF
Andrew Charles Moncrieff.
MR LATHAM
since 1985 you have been involved in a series of publications
relating to particular sciences have you not?
ANDREW MONCRIEF
I have .
MR LATHAM
what has been your primary interest?
ANDREW
MONCRIEF
geology.
MR LATHAM
since 1985 and indeed your qualification was a degree
and indeed a doctorate in geology? Transcript delayed
- will resume shortly
ANDREW MONCRIEFF
it was, yes.
MR LATHAM
have you been involved in forensic examination of exhibits
and giving forensic evidence over a number of years?
ANDREW MONCRIEFF
Yes I have.
MR LATHAM
Mr Moncrieff, you were brought into this investigation
quite late in the day - in June of this year - were you
not?
ANDREW MONCRIEFF
that's correct.
MR LATHAM
you were asked to assess the strength of any match between
geological components found on Common Drove, the area
of the body deposition site, and the outside and inside
of the Ford Fiesta motor car, were you not?
ANDREW MONCRIEFF
yes.
MR LATHAM
and in order for you to do that you were provided with
a very large numbers of specimens which had been taken
from the area of the road itself, along Common Drove and
the area of the deposition site, were you not?
ANDREW MONCRIEFF
yes.
MR LATHAM
those had been seized by other scientists and, indeed,
police officers and scenes of crime officers way back
in the August and early September of last year?
ANDREW MONCRIEFF
yes.
MR LATHAM
in due course, I think you decided to take some of your
own samples from Common Drove, is that correct?
ANDREW MONCRIEFF
yes, I did.
MR LATHAM
in particular, I think you were informed of where the
general point in the ditch where the bodies had been found,
and I think you took specimens from the roadside of that
point where the bodies were found and then further on
up the track towards the air base, past where the bodies
had been found?
ANDREW MONCRIEFF
that's right, the road to the south.
MR
LATHAM
I think that even this year, the Ford Fiesta that we are
concerned with had been retained by the police in a secure
environment and you were able to look at particularly
the underside of that car in June this year?
ANDREW MONCRIEFF
I did, yes.
MR LATHAM
and although others had taken specimens from underneath
the car I think you yourself took some items from underneath
the car, did you not?
ANDREW MONCRIEFF
yes, I did.
MR LATHAM
any particular point that was of specific interest to
you of the under side of the car?
ANDREW
MONCRIEFF
do you mean the area?
MR LATHAM
yes?
ANDREW MONCRIEFF
the area of most interest was the near side suspension
arm connecting the chassis to the wheel.
MR
LATHAM
if we look at this photograph, please, we can see the
lower suspension arm there of the car, which is well below
the bottom edge of the bumper, isn't it?
ANDREW
MONCRIEFF
yes, it is.
MR LATHAM
if we imagine that as, as it were, a knife, horizontal
knife, where was it that you were able to to take specimens
from on that arm?
ANDREW MONCRIEFF
it is on the top surface of the knife, mostly towards
the left-hand end as you look at that photograph.
MR LATHAM
I think in doing your work you had the assistance of various
other scientists, did you not?
ANDREW
MONCRIEFF
yes.
MR LATHAM
two in particular?
ANDREW MONCRIEFF
yes, their names are Dr Haydn Bailey and William Gallagher,
both of whom are directors of the (inaudible).
MR LATHAM
that leads me straight on to talk, if I may,if you had
involvement of other substances, if I can describe them
as that, and specific involvement in chalk?
ANDREW MONCRIEFF
Yes, I have.
MR LATHAM
the two colleagues you have just mentioned, have they
also worked with chalk ?
ANDREW MONCRIEFF
they have, yes.
MR LATHAM
to most of us, chalk is chalk is chalk. is it possible
to differentiate however between various types of chalk?
ANDREW MONCRIEFF
yes, it is.
MR LATHAM
I don't want to go into great detail into how you can
differentiate, but can we take it as simply as possible.
First of all we imagine chalk in a refined sense as being
pretty much white, I think, blackboard chalk, one thing
of the white cliffs of Dover. Is there any way of distinguishing
between chalk simply by its colour or is it all the same
colour?
ANDREW MONCRIEFF
no, it is by no means the same colour although the majority
of it is white or very pale brown.
MR
LATHAM
when we speak of chalk is it mixed up with other minerals,
or is it on its own simply as chalk?
ANDREW
MONCRIEFF
Well, chalk is a rock which consists of various different
minerals, but nearly all of the same type.
MR
LATHAM
the first thing one can do is look at colour of the chalk.
Can one then start to look at the mineral itself and how
it is made up?
ANDREW MONCRIEFF
yes .
MR LATHAM
do we do this with the naked eye or under a microscope?
ANDREW MONCRIEFF
Both preferably. The naked eye is the first source of
examination followed by the microscope.
MR
LATHAM
what is chalk in fact made up of?
ANDREW
MONCRIEFF
chalk is made almost entirely of a mineral called calcium
carbonate, derived mainly of shells from creatures that
lived in the sea at the time it was formed.
MR LATHAM
we are talking millions of years ago?
ANDREW
MONCRIEFF
about 97 million years for this particular chalk.
MR LATHAM
what happened to these creatures, how does chalk as we
know it, come to be made?
ANDREW MONCRIEFF
the creatures live in the sea mostly near the surface.
When they die their microscopic shells sink to the sea
bottom where they form a calcareous mud which over the
years gets turned into rock.
MR LATHAM
as that?
ANDREW MONCRIEFF
it can remain under the sea or be lifted up to form a
landscape.
MR JUSTICE MOSES
Mr Coward, have you indicated to Mr Latham which, bits
of this witness's evidence are in issue.
MR
COWARD
I have said that none of it is in issue and I'm looking
at admission number 5.
MR JUSTICE MOSES
so am I yes. .
MR LATHAM
my Lord there is - it is not to waste time; I will take
it as quickly as I can - I have no intention of going
into huge detail.
MR JUSTICE MOSES
thank you very much.
MR LATHAM
in relation to these fossils, these creatures that have
died in the sea many millions of years ago, are you able
to, by looking under a microscope at bits of the fossils
of those creatures, to age and date those creatures?
ANDREW MONCRIEFFF
Yes, each part of the chalk usually has a (inaudible)
collection of fossils in it.
MR LATHAM
at this stage are we looking at what are known as micro
fossils?
ANDREW MONCRIEFF
yes, we are.
MR LATHAM
when you examine the various specimens which were taken
from Common Drove, either by you or by others, were you
able to, under a microscope and with the assistance of
your colleagues, date the type of chalk you were looking
at?
ANDREW MONCRIEFF
yes.
MR LATHAM
is it a wide band or narrow band of date, as it so happens
in this case?
ANDREW MONCRIEFF
in this case the band is no more than 6 meters thick,
less than 6 meters thick.
MR LATHAM
by date?
ANDREW MONCRIEFF
no, by thickness.
MR LATHAM
by thickness?
ANDREW MONCRIEFF
6 meters.
MR LATHAM
by date?
ANDREW MONCRIEFF
by date much harder but around 97 million years, give
or take 500,000 either way.
MR LATHAM
two other things about chalk if I may. You mentioned a
fairly narrow band. is this a band which is exposed on
the surface of the land in very many cases or not?
ANDREW MONCRIEFF
this particular chalk where it intersects the surface
of the earth forms a strip about 350 meters wide.
MR LATHAM
and is it a long strip stretching right across the country
or is it a fairly short strip in East Anglia?
ANDREW MONCRIEFF
Chalk of that age is a very long strip but chalk of that
age that also coincides with the appearance of the rock
is much shorter, extending probably from about Cambridge
to Kings Lynn.
MR LATHAM
in this a narrow band of about 350 meters wide?
ANDREW MONCRIEFF
just so, yes.
MR LATHAM
is most of that exposed on the surface or is it in fact
below ground level?
ANDREW MONCRIEFF
It is a very characteristic feature of chalk; it is extremely
soft, and thick soils tend to form on top of it, and in
fact there are no known natural exposures of this chalk
under the earth's surface.
MR LATHAM
it is covered with a coat of soil?
ANDREW
MONCRIEFF
indeed.
MR LATHAM
Excavates for a purpose its remains under----
ANDREW MONCRIEFF
Yes.
MR LATHAM
I think a ditch had been opened by a farmer, Mr ... on
the other side of Lakenheath?
ANDREW
MONCRIEFF
That's right.
MR LATHAM
did you compare specimens from that ditch with the specimens
taken from the surface of Common Drove?
ANDREW
MONCRIEFF
I did.
MR LATHAM
did they match or not?
ANDREW MONCRIEFF
they appeared to be identical.
MR LATHAM
if you and Mr Rutterford had been, when digging that ditch,
wearing Wellington boots, and been walking around on the
chalk, clearly you could get chalk on the shoes. as far
as you are aware are there many places in the area we
are concerned with, that 350 meters wide by the Kings
Lynn to Cambridge strip, if I can put it that way, where
one would be able to drive a motor car over exposed chalk
of that sort?
ANDREW MONCRIEFF
I don't know of any, but that is not to say one does not
exist.
MR LATHAM
most of it is covered as you say by soil?
ANDREW
MONCRIEFF
yes.
MR LATHAM
when you went to Common Drove and had a look at how the
roadway was made up, did you find the chalk was mixed
up with something else?
ANDREW MONCRIEFF
on the track yes. The chalk was mixed up with other constituents.
MR LATHAM
what appeared to be the primary source of the other constituent,
what were the primary elements?
ANDREW
MONCRIEFF
there was a mixture of concrete, a mineral called "churt",
a mineral called "horts" and brick.
MR LATHAM
of itself were the constituent elements rare or common?
ANDREW MONCRIEFF
extremely common.
MR LATHAM
but the mixture of those other elements and this particular
type of chalk, would that mixture be common?
ANDREW MONCRIEFF
this is something- it is extremely difficult to say. Mr
Rutterford made up the drive- the Drove in the way but
there is nothing to say another (inaudible) could not
have done the same, but I know of no other such.
MR LATHAM
while you were at Common Drove there was another particular
characteristic about the way the surface had ended up
as a result of being laid in the manner described by Mr
Rutterford and, indeed with the use of a bulldozer?
ANDREW MONCRIEFF
yes, that is so. Along the side of the Drove were some
long raised piles of chalky material. If you imagine a
bulldozer blade moving through the pile on the edges,
the surface will run off and possibly form these long
piles along the edge. these piles were distinct from material
on the track and they did not appear to have any dark
soil material mixed in with them.
MR
LATHAM
turning specifically to the sample which was taken from
the under side on the suspension arm, of the Ford Fiesta
was there any of the dark soil mixed up in that specimen
that you looked at?
ANDREW MONCRIEFF
I didn't find any on the near side suspension arm, no,
because the lighter variety is typical (inaudible).
MR LATHAM
comparing the chalk you found on the under side of the
vehicle with the chalk and, indeed, other elements, the
quarts, and so on, found at Common Drove, what are you
able to say?
ANDREW MONCRIEFF
I'm able to say they appear to be identical.
MR LATHAM
having actually visited the site and also looked at the
motor car and that suspension arm, can you say anything
about any mechanism which would have led to the chalk
getting on to that suspension arm?
ANDREW
MONCRIEFF
yes, I think we can ... soil is often deposited under
cars as a result of the wheel spinning or throwing material
up. in this case I think there was far too much of it
and it was deposited on platforms actually further forward
within the centre of the wheel, so I don't see how it
could have been thrown up by that. I think it more likely,
as described earlier, the suspension arm acted as a knife
and took off the top pile of what the car was driven on.
MR LATHAM
you also looked at specimen sweepings, as it were, taken
from the foot wells of the car, did you not?
ANDREW MONCRIEFF
yes I did.
MR LATHAM
what did you find in relation to those foot wells when
compared with your specimen samples taken from the roadway
we are dealing with, Common Drove?
ANDREW
MONCRIEFF
Well, I found all the constituents that were also on the
drove and the foot well, but in the drive foot well was
also a specimen of chalk that could be dated to the same
intervals as the one on the drove.
MR
LATHAM
does the specimen taken from the foot wells require a
qualification as far as you are concerned?
ANDREW
MONCRIEFF
In terms of their significance?
MR LATHAM
yes?
ANDREW MONCRIEFF
yes, they do, because they didn't form single deposit
as the material on the suspension arm did. There is no
way of knowing at all if they were all introduced to the
foot well at the same time, in fact it is highly likely
they were not. the significance is therefore that (inaudible)
the deposit on the suspension arm, however, the fragment
of chalk was dated to the same interval and, as I explained
earlier, it is not particularly uncommon.
MR
LATHAM
so the Jury understands the particular type and age of
chalk you speak of - I think you put it into a particular
sub zone, is it not?
ANDREW MONCRIEFF
yes.
MR LATHAM
the age and type of chalk. what this sub zone described
as?
ANDREW MONCRIEFF
as all these things it has a name it is called UC1 DS
sub zone of the (inaudible) stage.
MR
LATHAM
Of all chalk outcrop in this country how frequently does
that arise?
ANDREW MONCRIEFF
I can't give you a figure across the whole country; I
can comment that if you were to take an East-west line
across northern East Anglia that zone represents less
than 0.01 of the total.
MR LATHAM
you mentioned the chalk, both in the foot well and on
the suspension arm. Did you find the other constituent
elements of the Common Drove?
ANDREW
MONCRIEFF
I'm sorry?
MR LATHAM
the other constituent elements, the churt and the quartz?
ANDREW MONCRIEFF
in the footwell.
MR LATHAM
on both the footwell and the suspension arm?
ANDREW MONCRIEFF
yes I did.
MR LATHAM
one of the things I asked you about at the beginning was
whether or not you took specimens shortly before the point
where the bodies were found and then a little further
on up the track towards the Airbase?
ANDREW
MONCRIEFF
yes.
MR LATHAM
was there any distinction to be drawn to those two and
if so what?
ANDREW MONCRIEFF
yes, it was actually a series of specimens taken, one
every ten meters leading away from the point where the
bodies were found. large fragments of chalk only appeared
to be on the track up to the point, from the road up to
the point where the bodies were found. as you then moved
further on, chalk was still present but could only be
seen under a microscope. At a distance of 50 meters further
on from where the bodies were found chalk was absent from
the surface.
MR LATHAM
if the chalk on the suspension arm came from Common Drove,
what does that mean in your view in terms of where the
car had picked that chalk up?
ANDREW
MONCRIEFF
in addition to what I have said, I should add that the
elongated piles, which I think were instrumental in getting
this deposit onto the car, only occurred to the north
of where the bodies were found. So in my view, they would
have had to have picked up those deposits from the area
where the bodies was found and the main Wangford Road.
MR LATHAM
Mr Moncrieff, when you prepared your report and your long
witness statement dealing with your analysis of chalk
and the other minerals mixed up with chalk, did you know
whether or not it was to be admitted that the Ford Fiesta
had in fact been along that track?
ANDREW
MONCRIEFF
no.
MR LATHAM
what was your overall conclusion looking at the findings
on the suspension arm and the findings in the footwell,
in relation to the nature of the constituent elements
of the track?
ANDREW MONCRIEFF
my conclusion was that all the evidence I had accumulated
was consistent with the car having been on the track at
Common Drove and that the occurrence of similar settings
in which it could have accumulated, the deposit would
be rare.
MR LATHAM
thank you very much, would you wait there, please
(Cross-examined by MR COWARD.)
MR COWARD
Mr Moncrieff just this, I think you were provided with
some footwear, weren't you?
ANDREW MONCRIEFF
yes, I was.
MR COWARD
I can deal with it very briefly, my Lord, for the purposes
of 6376, you could find as a geologist no evidence to
suggest the footwear you examined had been worn on Common
Drove?
MR JUSTICE MOSES
is it a secret what that footwear was.
MR
COWARD
my Lord, no secret at all, I think we may find at 6364,
DMX 5 and 6, Nike trainers SLB 25, and some blue Adidas
trainers, SLB 24?
ANDREW MONCRIEFF
may I add one final point? I learned afterwards that some
of the footwear had actually been presented by other scientists
and had in effect been cleaned, I'm not clear as to what
the details of that are though.
MR COWARD
I think the boots - let's deal with them in reverse order
- the blue Addidas trainers, SLB 24, did contain one brick
or a clay tile fragment, but the soles were extremely
clean. The Nike trainer, SLB 25 were well worn with numerous
mineral grains trapped within the sole, they had quartz,
churt and limestone in them, some of which had a coating
of tar. No chalk was found on those shoes and with regard
the boots, DMX 5 and 6, the soles were clean and contained
no mineral grains. The material of the boots similar,
light wear and contained some quarts grains. so by the
time the boots got to you, you weren't able to find the
various footwear, you weren't able to find anything which
was a positive connection to the Common Drove?
ANDREW MONCRIEFF
no.
MR LATHAM
I have no re-examination. thank you very much
{the witness withdrew}.
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