Page 49 - tmp

evidence are set out in the appended chronology. The court is invited to take particular
note of the evidence supporting the conclusion that the Appellant was integrally involved
in the organization of raves and/or the supply of equipment:
4. The Appellant was identified by gate security as the organizer of a rave of about 300
people on 7/8 June 2014 (see evidence of Insp. Hamill JR38] and supporting evidence of PS
Miles [R36]).
5. The Appellant admitted to Insp. Skinner that he was the organiser of the rave on 7/8 June
2014 [R41].
6. The Appellant admitted to Insp. Skinner that he was the organiser of the rave organised
and prevented on 19 July 2014 [R39, R41].
7. The Appellant admitted to PC Edgoose that he lent his sound equipment for use at raves
and that he could get a significant number of people to turn out for a rave [R48, R88]; and
8. The Appellant was the organiser of the rave on 9 August 2014 and provided the sound
equipment as well as laughing gas [R42, R44-5, R47]. When a crowd turned up and tried to
force entry, the Appellant encouraged them to break the police line [R43, R45-6].
(13) The Respondent further relies on the information set out in the intelligence reports and
the documents provided to the court in the Respondent’s bundle. The evidences show the
Appellant has witnessed by many different police officers supplying equipment for or
helping to organise a rave.
(14) The court will be invited to reject the Appellant’s account as t:o his activities on the
relevant, days as not credible.
The second limb of the test under section 1 of the Act
(15) It is first submitted that an ASBO is, in general terms, necessary.
47
92,
Simon Cordell’s Skeleton Argument (2) Pdf
Simon Cordell Skeleton Argument.pdf
(16) There is a significant body of evidence showing the impact of raves on people who live
near where they occur [R51-66, R155-298]. The level of distress that these individuals
suffered as a result of the raves organised by the Appellant was high. 'There is a need to
prevent these events occurring in the future.
(17) The ASBO (and interim ASBO beforehand) have been effective. The only time where
the. Appellant’s behaviour has improved is when these proceedings were commenced,
and it was made clear to the Appellant that his actions could not be tolerated.
(18) "The Appellant has denied the acts alleged by the Respondent. He has shown no
acknowledgment or desire to change his ways that might make an ASBO unnecessary.
(19) As to the particular prohibitions on the ASBO, significant effort was made by the
Respondent and by the court to ensure that any legitimate business activities that the
Appellant wished to undertake would in no way be inhibited by this order. Tor the
Appellant to provide recorded music to a gathering of people he would either need to
have a licence for that event or to provide the music on a licensed premises for fewer than
500 people with, a general licence to play recorded music (see s. 1 and Sch.l of the
Licensing Act 2003). This order specifically does not preclude him from providing
regulated entertainment under the auspices of a valid licence.
(20) The only amendment that the Respondent would seek is that the words “or s.63(l. A)” be
added after the words “s.63(l)” in prohibitions a, b, and c of the ASBO.
(21) It is submitted that the terms of the ASBO as drafted are necessary and proportionate in
that they should have minimal impact on the Appellant’s life and legitimate business
activities.
ROBERT TALALAY

Page 47 of 139