Page 303 - Pages from 8. 2017 New 26-05-21 No Table- 2nd Half

stated to the district judge under cross-examination is not the truth as can be proven by a
copy of a freedom of information request that was sent in receipt's to Enfield Council and
ourselves, to further this the Judge then asked the same question was every CAD linked to
the case of the application, and was given the exact same answer yes.
26. Attached is a copy of the freedom of information act which was obtained from Enfield
Council.
27. In point of the facts 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 and should have never been contained
without the right application granted by a judge, also contained within the police officer
statements there are errors which can be proven as untrue and are therefore a breach of
the data protection act.
28. We know the police knew about the illegal rave at Crown Road because police were
deployed there. This can clearly be seen within the CADs which are within the
application's bundle, but there is so much reduction within the CADs we believe there is a
lot more that pertain to Crown Road, and we cannot see due to the reductions.
29. Part of the Appellant's barrister submission had been that the allegations were that the
Appellant was involved in the organising of illegal raves, but the applicant hadn't adduced
evidence of trespass which is a requirement for proving that an indoor rave was illegal.
30. The district Judge ruled that the applicant did not need to prove illegality - all that needed
to prove was the Appellant had acted in an Antisocial Manner.
31. In the Appellants barrister view this is a very questionable decision: firstly, the applicant
based their case on the illegality of the raves rather than the fact of the rave's themselves
and secondly, without proof of illegality the presumption of innocence leads to the
conclusion that the raves were legal, and thus the applicant being prohibited from
engaging in an ostensibly lawful activity requires more careful consideration on issues of
proportionality.
32. The barrister continued to state that the Applicant could go to judicial review in regards to
the case, but gave his legal advice that he did not think this decision was in the Appellants
best interest as he believed there is little merit in doing so, the reason he gave was
because the Appellant would then lose his right to Appeal to the Crown Court and even if
he succeeded in the high/div Court, they would merely remit it back to the Lower Court,
who would then probably go through the motions of considering proportionality before
coming to the same conclusion.
33. To summarise the Judge stated she did not need to prove illegality, but she proved the
Appellant had acted in an Antisocial Manner, how the district Judge came to this
conclusion we do not understand, not one police officer had stated the Appellant had
acted in an Antisocial Manner towards them, is also a fact that any application for an
Antisocial Behaviour Order has to be bought within six months of the dates, there were
cases going back prior to the six months which should have only been used for reference,
but the District Judge also included these cases to be proven.
34. Since this case started, we knew the police and the public order investigation unit held
information on the police systems that proved the Appellant was not the organiser of
these illegal raves. In fact, the police knowingly went around to the known organiser's
homes and also spoke with them on the telephone. This proves they have the information
we were asking for in disclosure. (This was found out via social media and Google by the
Appellant's mother) the Appellant's mother even called the public order investigation unit
and spoke to DS Chapman, and Val Turner.