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problems and also did not even have his own bundle which
                 he had never had from his solicitors we was never told by
                 the acting solicitors that we should have had one, but you’d
                 also seem there was a large amount of documents missing
                 from The Appellant’s bundle, when The Appellant took the
                 stand the Judge did asked where his bundle was, he stated he
                 had never been given one, and did not know he needed one,
                 the Judge did asked if there was a spare bundle that The
                 Appellant could use which there was not the Judge carried
                 on by allowing The Appellant to be cross-examined clearly
                 anyone could see The Appellant was unwell, from time to
                 time the Judge passed The Appellant her own bundle as you
                 can clearly see The Appellant because the appellant did not
                 know what he was being asked, the problem with this is how
                 is someone with learning difficulties meant to read what is
                 contained within the bundle, if The Appellant had had access
                 to his own bundle prior to the hearing with help of software
                 and his family he would have been able to memorise what
                 was in his own bundle. With the line of questioning, his
                 learning problems and his health this was totally
                 inappropriate, but was allowed by the Judge. The Appellants
                 barrister questioned the applicant’s barrister about the
                 legitimacy and the fact if every CAD being used in their
                 application case was linked to Progress Way and if there was
                 an illegal rave taking place at the same time on Crown Road.
                 The Appellants mother had asked The Appellants barrister to
                 ask this question, the reason being the acting solicitors had
                 not gone over the CADs although they was asked to many
                 times, you can clearly see although there was multiple
                 reductions within the applicants bundle clearly there was
                 CADs within the bundle that had nothing to do with the
                 application case. He stated every CAD related to Progress
                 Way and there was not an illegal rave taking place on Crown
                 Road, and the police also said this was the case under cross
                 examination, to further this the Judge then asked the same
                 question was every CAD linked to the applications case, and
                 was given the exact same answer yes. Now I show you the
                 freedom of information act which was obtained from Enfield
                 Council.
                 (See attached)
                 In point of fact there are multiple inconsistencies pertained
                 within the CADs within the application, timestamps also do
                 not match up within the CADs, there is also all the missing
                 CADs. Some of the intelligence reports also have been
                 updated with no reason as to why. There are also the
                 breaches of data protection within The Appellants PNC
                 record which are incorrect which also can be proven, also
                 contained within the police officer statements there are
                 errors which can be proven as untrue and a breach of the
                 data protection act and multiple inconsistencies within police
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