Transparency New Zealand

I have just completed  my submissions to the human rights commission on access to  justice   it is as follows

The right to Justice submission by Grace Haden                                    to    Infoline@hrc.co.nz

I am a former Police Prosecuting Sergeant; I prosecuted for 3 years in the Auckland district court and youth courts. I was in the New Zealand Police for 15 years and had passed all pre requisite exams to become a commissioned officer.

I believed that our system was fair and equitable.  I left the police and became a mother and later became a licensed Private Investigator.  The comments below reflect my personal experience and those of my clients over the past 7 years of practice as a Private investigator specialising in verification, anti fraud and anti corruption processes and conducting investigations often pro bono because many have found that the law is now inaccessible to the average New Zealander.

I am a director of Transparency New Zealand, Verisure investigations Ltd    a member of the certified fraud examiners association .

International context

I strongly challenge the following statement

“The fact New Zealand has consistently ranked as among the most least corrupt countries in the world on Transparency International¹s Corruption Perceptions Index suggests the system is operating satisfactorily.”

The key word is perception. I have evidence that in New Zealand the perception is kept alive by Suing those  who question corruption then denying them  the right to justice thereby concealing corruption and allowing the perception to remain.

In 2009, concerned with the levels of corruption I came across in my work as an investigator, I attempted to join transparency Internationals NZ Branch.

My application stated no more than that I was a member of the certified fraud examiners association, Former Police Sergeant and now a private investigator.  I was rejected without comment and denied the review of my application which was mentioned in the application papers.

I did have a chance to meet  informally with a number of transparency Internationals members, and in my opinion they all appeared to be  from the wealthier  , predominantly white sector of  our community , many had held  government portfolios  and most would have a commercial interest in keeping  that  perception  alive. These people who keep the illusion alive do not live at the coal face of society as I have done.

FRAUD & CORRUPTION

The reality is that in New Zealand we control the exposure of corruption by making it impossible for people to report corrupt practices.  Few companies have a fraud policy and unlike the united Kingdom New Zealand   does not have a Fraud Act .

Whistleblowers are dealt with harshly and I can give examples where those who have spoken up have lost their jobs, been bankrupted or both.

Fraud is the fastest growth industry worldwide yet our police have only a handful of people who police it.  The energy which the police put into “keeping the  road toll down”   is grossly disproportionate to the   effort put into crime prevention and prosecution of  fraud.

Every year more people commit suicide than die on our roads. We cannot produce statistics for the people who   die while before the court or suffer stress related illnesses through injustice or through being victims of fraud or corruption.

Because these are not measured they are not responded to but the situation is serious and ignored.

I left the police in 1989 and have found that since user pays , much has changed. Government departments which used to control various aspects now have responsibilities to be a viable business and as such economics   plays a major role.

The police is one such business, by turning it from a service into a business the word economy was introduced which in turn has had a major effect on people’s right to justice.

In the days when I served in the police, people were seldom turned away   when making a complaint now they are more often than not shown the door and told to consult a lawyer for their CIVIL matter.

Victims of fraud cannot fight back, most would not know how to get the evidence and cannot afford to pay for the investigation, without which the police will not touch their complaints.

The serious fraud office require proof that the fraud is above a certain threshold before the will investigate. Ordinary people are powerless to get that sort of proof as often warrants are needed to obtain that proof.

Police officers are performance rated and   it is far easier to get statistical clearances by charging people for minor offences for which it is far more economic to plead guilty even if you are not than trying to defend it.

On the other hand police avoid complex investigations as the time and effort in investigations and prosecution is not economic compared to the outcome, this   brings about a determination from the police that a matter is not worth proceeding with as it is not in the public interest.

One needs only to look at the sentences handed out for fraud to see that it is an economic crime to commit, if caught   the penalties are very light compared to the   sums gained.

In the end many companies which suffer fraud let it slip by or if the offender is an employee a confidentiality clause, a payout and a clean reference   is the most economic way of disposing of the   problem   and look no fraud.

Corruption exposure has been very well controlled in New Zealand by denying that it exists and making it almost impossible to expose.  Economics is corruptions greatest ally  and user pays and the business model we have ( Rogernomics )  is the greatest preventer of justice  as  all our rights  have now  only become available at a price.  If you cannot afford that price you cannot afford your  rights to justice.

The United Nations convention against corruption.

New Zealand is a signatory to the convention but it has never been ratified.  We pretend every day that we are the least corrupt and keep this   concept alive by allowing our courts to be used to conceal corruption.

The  fundamental right to  justice

The rights conferred on us through the Universal declaration of human rights are accessible only to New Zealanders who can afford to pay for their right to access those rights or those with the right connections to facilitate it.

Those who can afford access to courts can use it to silence those who could expose corrupt practices. Defamation claims and harassment claims are frequently used with much success because the consequences of going to court are so costly. It is effective  and it works.

Having been a victim of both these processes I have come to the conclusion that if you assault someone with a base ball bat   you will be arrested for assault. But if you take legal action you get to beat up your victim over years, it can do far more damage and sometimes even kill your opponent and it is called legal.

Similarly if I make threats to any one  it is an offence  but if I get a lawyers letter  and tell people  that my action will bankrupt them if they don’t comply   then it is legal.

There are many acts which if done   through any other means than through a lawyer and court would be criminal offences but  by using  lawyers and the court  these  very wrong acts are legitimised.

Civil litigation  penalties   are much higher  and rights to justice are far lower than  in the criminal section e.g. Lynne Pryor   guilty of fraudulent  running a business penalty $18,000 her  unjust action against me  cost me $49,000  .  Another such case Vince Siemer   had to pay $940,000  for words which  have never proved to  be false   yet  the lady who  has been scarred for live in the RSA murders  struggles to get $50,000

By placing a price on the accessibility to justice, especially in the civil sector the ordinary citizen is denied access to justice especially when lawyer’s hourly rate ( $350-450) is marginally lower than the  average weekly income. ($530)

1. The law must be accessible, intelligible, clear and predictable.

Accessibility to the law should not be conditional to the ability to pay  for it.

Those who have been financially stripped cannot fight back, your right to justice is directly proportional to your ability to finance investigations and court action.

Our law is accessible only at a price, without money there is no representations, lay litigants don’t get heard and the court insists that you use a lawyer. The rules are so complex that evidence does not come into play, procedure any your lawyers  ability to manipulate the court largely determines the outcome.

In new Zealand it is also possible to  write legislation for your own business plan , I have evidence where a barrister who wrote a bill it to facilitate his own business venture. He was employed  by the  select committee as an “ Independent adviser”  he was also  advisor to MAF.

When the bill passed into law he applied for an “organisation ‘to become approved. Except that there was no evidence that this organisation was more than a trading name for the barrister.

This “organisation” without proof of existence was given law enforcement ability and then contracted to central and local government to provide services to the public.

When I questioned the lack of transparency and existence of this “ organisation “ I was sued .  Because it has been before the court for the past 4 years no government body has acted.  The court action is a text book example of how justice is denied and the level of evidence ( nil )  which is required by the court to financially cripple a person .

I have documents in which statements have been made by the plaintiffs that their desire was to   ruin my life and bankrupt me , I am not yet bankrupted  but my family has been torn apart and my 25 year marriage has ended. Wells and anor V Haden . The plaintiff a barrister used public charitable funds   to fight me in court.. how can any one compete with that.

Another such case  was a parallel proceeding  Hay and Pryor V  Haden .  I was taken to court for harassment   and  later  for contempt of court  by these persons who have subsequently been charged with  fraud . One charged with 22 charges  is a fugitive from our laws but still uses our courts  to pursue me , the other  has been found guilty of fraudulently running a business.

I need to explain that I was trying to locate a director and liquidator of a company, neither existed , false harassment claims were laid to  stop me from  exposing the fictional characters.

These proceedings serve to prove that in New Zealand it is entirely possible

1.       for an undefined trading name  to be given the same status as a real person

2.       For truth to be considered defamatory

3.       That you can obtain a restraining order without any evidence

4.       That judges threaten citizens into compliance from the bench- possibly seeing that   compliance is the best option than to stand up and protect their rights.

5.       For a claim to be won  without  production of any  evidence on part of the plaintiff

6.        For a right to a defence of truth an honest opinion, to be denied for the inability to pay large sums in a short time frame.

7.       To  have a quantum  for defamation determined  without establishing that there was  defamation

8.       For a judge to do his own fact finding after the fact via the internet and have this upheld by another judge.

9.        For the Uncorroborated evidence of the person who stood to gain to be accepted.

10.   For evidence in mitigation of damages, submitted in accordance with legislation, and made by way of affidavit, to be used against the person swearing the affidavit.

11.   For The defendant to be discredited (without evidence) to such an extent that the judge forms a totally negative opinion of her.

12.    For Public charitable funds to be used  to fund the litigation  and obtain a financial befit for the plaintiff.

13.   For perjury to be  condoned by the police  who claim that it is not in the interest of the pubic to prosecute ( not economic )

Suggested  solutions

The requirement for a mediation service before matters being taken to court may be a solution and any one taking action which is not provable should be held accountable to the fullest extent.

Proof should be filed with a claim. Everyone should be accountable to the truth and prosecutions for   perjury undertaken as diligently as speed camera offences.

2. Fundamental human rights must be protected by the law.

My rights to BORA have been ignored at every step of the way, even to the extent that the application for judicial review was objected to without giving any reasons, this action only served to push up my costs   .

3. Civil disputes, which the parties themselves are unable to solve, should be resolved through established procedures without prohibitive cost and in a timely fashion.

Court is often used as a means of bullying people into compliance, It is often used by those who wish to deny some one of their freedom of expression, to silence them so that others cannot be forewarned.

The courts do not consider at all what negotiation has occurred outside the court and whether or not what was said was fair comment.  It is evident that the plaintiff is frequently believed  in preference to the defendant, the court dos not  seem to  realise that some cases are brought  for ulterior motives , they presume  that there is  good  and honourable reason for bringing the proceedings.

Court action by those with the financial means and the necessity to conceal corruption is taken with the intention of bringing about financial loss and even bankruptcy on the target.

Court is a lottery.. a bit like gambling, you may have the best hand but if you don’t have the cash to see  the other parties hand  you will never win.  Successful White collar criminals will always have money money than their victims.

4. Ministers and public officers at all levels must exercise the powers conferred on them reasonably, in good faith, for the purpose for which the powers were conferred and without exceeding the limits of such powers.

For  four years I have been  embroiled  in court action because I questioned  the actions of a public official who contracted to himself and  operated in a situation which is defined by the United Nations as corruption -being  Public office for private gain.  NZ appears to be ignorant of corruption and internal fraud to the point where it is extremely dangerous for anyone to question such activities.

The mechanisms for questioning the activities for those in power do not work, it appears that those who are in power hold the position without accountability and without question. No one investigates and   any one questioning their actions is disparaged and prosecuted.. it is like  the middle ages  all over again.

Part of the problem is that somewhere along the  line there has  to be responsibility for a public servant  who  did not check , as in the Wells V Haden  matter  MAF  had a legal obligation to ensure that they were contracting to a bona fide organisation which was registered as it had claimed, they failed to  do so.

Instead of admitting this and watching heads roll it  has been easier for them to  withhold information, put up a  brick wall  and regard me as mad   thereby protecting their “ business structure”    and preventing liability claims for the damage which has been done  .. cover up  is therefore  the best strategy  and  it keeps  inefficient colleagues in jobs.

Because my matter was before the court not one of the so-called Public watchdogs   would do anything  ,the classic being  the office of the  auditor general, when I asked  for  them to audit the contract of government and local government to this no existent  body  I  received a simple letter saying   you are being sued for defamation   we are not interested. They could not even take time for an independent investigation.

Ask questions of accountability in new Zealand and you are on your own. Ironically this is reflected in what happens overseas  see this news item  http://www.youtube.com/watch?v=BW2nmcmivZ8

5. Adjudicative procedures provided by the state should be fair.

In my experience the court process appears to be about forcing one party out of the proceedings, and allowing the other party to win by default. This is usually by attacking the financial resources, the more you can draw out the proceedings the greater the cost for the other party. Interlucatories, debates on the need for discovery, objections to anything the other party  applies for are all stalling  tactics  each step  incurs costs of  several thousands of  dollars on the other party.

Resolution is then offered at a price which one party will see as an economic escape, it is however not justice  and  is more akin to  black mail.

When matters can be won without evidence being produced there cannot be any fairness. I have always believed that “he who asserts must prove “, When people can allege and not be required to  prove then the court is denying  justice.

The courts do not have a mechanism to deal with the corrupt using it to conceal the actions, however if the United Nations Convention against corruption had been adopted  cases such as mine would have redress through articles 33-35

Article 33. Protection of reporting persons

Each State Party shall consider incorporating into its domestic legal system appropriate measures to provide protection against any unjustified treatment for any person who reports in good faith and on reasonable grounds to the competent authorities any facts concerning offences established in accordance with this Convention.

Article 34. Consequences of acts of corruption

With due regard to the rights of third parties acquired in good faith, each State Party shall take measures, in accordance with the fundamental principles of its domestic law, to address consequences of corruption. In this context, States Parties may consider corruption a relevant factor in legal proceedings to annul or rescind a contract, withdraw a concession or other similar instrument or take any other remedial action.

Article 35. Compensation for damage

Each State Party shall take such measures as may be necessary, in accordance with principles of its domestic law, to ensure that entities or persons who have suffered damage as a result of an act of corruption have the right to initiate legal proceedings against those responsible for that damage in order to obtain compensation.

When I was a member of the police, I was worthy of belief   I   am still the same person but it appears that no amount of evidence will make me believable before our courts, those with a higher  ranking in life are far more believable to the court , than  I am a mere  woman.

The man who has had me in court is a Barrister  , many  barristers habitually  tell lies and they all laugh about it   even a judge said to me   that that is what lawyers  do.. She would know   she was one once.  If lawyers were held accountable to the truth then we may have a different situation.

Police have a very low priority for prosecuting perjury, so what is the point in having statutory declarations and affidavits when    the persons swearing those statements   have no fear of being prosecuted for telling lies in these documents of truth.   Swearing a document does not make it true yet they are treated as that and it  it then for  the other party to have to prove that it is not true,  all without consequence for the   one  telling the lies.

Persons swearing  affidavits and  statutory declarations  must  have real fear of being prosecuted for telling lies  otherwise the  document is  not one which can be relied on.

Honest people are  jeopardised in court  as truth only has one version  and those who  tell lies  can create any story to counter the truth.

When courts do no evaluate factual evidence and interpret the law as written then there is no justice.

I have had two judges  who both sat on the  two separate  legal issues, neither took the opportunity to recluse themselves and I had to  make an application  to the  chief district court  judge to have one  who had struck out my defence remove from sitting on the case further.

I  found it  simply  too  coincidental that of all the judges available  the same two   recurred on my   cases both judges  denied me  my right to justice.

I was shocked when at the commencement of proceedings and before any evidence was  heard , I was told by a judge to  take certain action, give an apology  and give the plaintiff $2,000 “or my life would be ruined  and  I could  well be bankrupted.”

I did not take up the judge’s offer and found that she later hiked up the  costs against me in the interlocutory hearings and then  struck out my defence of truth and honest opinion in an alleged defamation matter where I was questioning corrupt practices in local government.

This same judge refused to recluse herself from another matter where she forced me to sign an undertaking   in a matter where it has now been conclusively proved that the plaintiffs were acting against me to conceal fraud.

In then end   my complaint to the judicial conducts commissioner   and the request to have the judge removed did not help my case. My case is a great case study of how justice is denied in New Zealand.

Complaint procedures

We appear to have a tendency in New Zealand to make complaint procedures available then under resource the compliance bodies, which will then look  at methods of “ writing off “complaints rather than investigating and dealing with them.

The standard of proof which is required by the various watchdogs is way beyond that which the average person is capable of supplying, even with the police there seems to be a need for people to supply a fully investigated complaint, and for them to tell the police which Act and section to enforce, before action will be considered.  Ordinary people do not have access to the conclusive evidence and as in my case seeking that evidence leaves you exposed to litigation to silence you .

Judicial review

My application for judicial review cost me $10,000 and costs are still growing. The other party opposed my right to a judicial review.  I am not aware if my judicial review has been granted or not.

This right should be a conclusive right which no other party can object to.

The legal system

Our legal system is complex with judged reviewing their own decisions on appeal; it is a system which bankrupts people not one which supports rights.

New Zealand context

As an anticorruption professional I have an equation   which works in any situation   this is

Corruption = Monopoly + discretion – accountability.

Monopoly

Both Judges and lawyers   have a monopoly in the courts, I thought that as a former prosecutor I was well equipped to take my own case but found that judges simply do not listen to those who are self represented.

Many Lawyers appear to give advice based on the amount of money that they believe they can extract from a client  and  will either tell you to pay  up  regardless because it is the most economical thing to do  or  will take  thousands of dollars from you without any visible progress.

The average New Zealander does not have $300 to spare per week yet this is a  very low hourly rate for lawyers. I have experienced lawyers who claim they are not the highest paid but will happily complete a document with two finger typing at $450 per hour.

Ironically if you are called up for jury duty you are rewarded with a sum which is less than the minimum wage. I believe the rate is $31 for 3 hours.

The Police is also a monopoly and so are the various watch groups such as Judicial conducts commissioner, Independent police conduct authority and law society.

Further law enforcement  authorities which are a monopoly  in their area are – councils  with by-laws and the RNZSPCA. The RNZSPCA  has  to be of  concern  as this  is a private sector  law enforcement agency  which  has no accountability to any one  and is not subject to  the official information act.

Legal aid

Everyone should have free access to justice.  When Justice has a price there can be no justice.

Civil litigation  should not provide less rights than those who have been charged  with criminal offences  as the standard of proof for civil is nonexistent and the  defendant  has  virtually no rights.

Solution

All of  these bodies  would benefit from being accountable  to an independent commission against corruption such as the one they have  in  Australia.

Discretion

Judges

An independent and impartial judiciary is a cornerstone of a legal system; however we have a very small pool of people   and as the emails   on the NBR indicate that judge’s talk amongst themselves.

I made a complaint to the judicial conducts commissioner but because the judge had discretion about the notes she caused to be made from the day it was her word against mine.

It is therefore in my mind essential that everything in court is recorded continuously   to keep all parties accountable.

I also had cause to complain about another judge who admitted to searching the internet during his deliberations, his discretion went beyond the evidence which was heard in court and such wide discretion is apparently condoned.

Lawyers

Lawyers should not have the discretion to   use the court for any purpose, they have a responsibility under the lawyers and conveyances act to ensure that they do not mislead the court or use the court for an improper purpose.

They have wide discretion as to how many hours they put in and the size of the bill for the client, I have known lawyers to charge for completing their accounts and for taking credit card payments , this is on top of  their   already very high   hourly rate.

Police

Police have very wide discretion which reaches beyond their right to   investigate, prosecute I have found that they wish to appease their statistics and avoid taking on anything which will result in an offence which is not  cleared.

While people are prosecuted every day for minor offences, the offences which are at the serious end of the law are not enforced with the same diligence.  This reflects in why we have more Maori offenders than any other part of the population.

Maori are targets because they generally do not belong to the old boy network which provides protection to many wealthy corrupt, they cannot afford   their right to justice  and the offences  they commit are generally  more easily proved because their actions are more spontaneous rather than carefully planned to avoid detection. They have become frustrated   with  the brick walls which stand in the  way to  their rights  and many have come out punching.

A good police tactic  is  to   get people on a secondary offence ,  fist you deny  someone their rights, then  they lash out  then you arrest them for assault.

In January of this year I was given a ticket for something I did not do , and for  which  the police had no  evidence for .Despite bringing this to their attention a number of times, they went ahead with the prosecution .  I had to travel to an out of town court to defend it, the instant fine would have been  $150  which  on the hourly rate of lawyers makes it uneconomical to defend.

I won in court, because the police had no evidence.  I took the complaint to the IPCA. The police admitted that the charge should never have been brought.   Repercussion for the cop- Counselling. Cost to me in lost wages, travel  etc   well over $1,000.

The law is not accessible to people, the police turn people away and call the complaint civil rather than accepting the complaint and investigating. This did not occur in the days when I was a police officer, complaints were taken and   after investigation  were filed as no offence disclosed if that was the case.

Those who already have suffered financial loss cannot afford to pay to prove their case so that the police will accept it. I can see this trend of turning people away ultimately resulting in people taking the law into their own hands.

I was involved with an incident where a car was reported as stolen four times before the police would take a complaint. Only after I investigated and provided the names of the offenders did the police take the complaint and the offender was subsequently arrested charged and my client   saw his right to justice upheld.

Fraud and perjury files even when they are prepared by a private investigator are held and assessed before they are given a file number, frequently they are rejected because of the cost of prosecution and a determination is made that it is not in the public interest to prosecute.

A client lost his property through a corrupt accountant, while the lawyers cleaned him out with civil action which went nowhere, especially when this broke and broken man had to come up with huge security for costs.    The police sat on the   complaint file for several years and   this still has not seen progresses.

Clients  had their house sold  from under  them by a company which  falsely claimed to  be the mortgagee, The case is too complex for the police  but not  serious enough for the SFO  it has fallen between the cracks and the file I submitted to the police has disappeared. Dealing with these bodies is like continually banging your head against a wall. The system is geared for people to give up in hopeless frustration; criminals are taking advantage of this.

Councils, SPCA

As with the Police many of the offences dealt with by the councils and the SPCA are  minor offences  which  people commit  unintentionally   and are strict liability offences  with  relatively  low value penalties.

While there is an opportunity to write in the enforcement authority generally digs in their toes and   forces the person receiving the infringement to go to court to prove their innocence. There is no compensation for the defendant when successful,   the economics of law dictate that it is generally cheaper to pay it than to defend it as most people  would not have the ability or skill to  face up to professionals in court .

What is particularly dangerous with the SPCA /RNZSPCA is that section 171  of the animal welfare act allows them to keep the  fines which they impose  this opens the door to  corruption .

Accountability

Accountability is what keeps people honest and where there is no accountability corruption will flourish.

To complain about a judge, lawyer or police brings about more issues for you than it solves, and there is no way that your complaint is going to be upheld any way.

The whole system means that only the brave or the foolish complaint and you soon find that the time and effort involved in lodging complaint is fruitless there is only one consistent outcome-exoneration.

While citizens are held accountable to the law for minor errors of judgement and transgressions, those in roles of enforcement appear to have no accountability for deliberate  and intentional  actions.

Judiciary

I am aware that  just today  Simon Power announced that there will be a law that prevents people  from speaking out against the judiciary, such laws which prevent  free speech   and  prevent accountability can only serve to  support corruption.

When judges act in a fair and just manner there will be no room for criticism.

Judges like everyone else should  be accountable to the truth and to what they say and do  to the same extent as paul Henry was.  It is therefore necessary that all court proceedings are recorded and every party  leaves the court with their own  copy.

Judges currently prevent anyone except press from taking notes in  court  , when there is secrecy there is room for  corruption.

Lawyers

Over the years I have made complaints about lawyers for both myself and my clients, I have never seen one complaint upheld.

My worst experience was  when I complained about a lawyer who had brought charges against me for  something which I had not done ,  his clients proved to  be fraudsters and were subsequently charged with criminal offences, One has been convicted but  his client with the money  is a fugitive from our law and living in Honolulu.

I used Judgements  from other  proceedings involving the same lawyer where the  judge had said that the  action was   heavy handed and ill conceived , that he was using the  scorched earth approach  ( financial burning out of the   defendant )  I showed parallels in  my case to the earlier case.  I had no reply from the law society.  When I followed up I was told that they had sent a letter out several months earlier and it was now too late for me to appeal. They had effectively not done anything they claimed I had other redress available.

While white collar criminals are using the court to silence and beat up those that who could expose them , the police fail to act  when   complaints of perjury or  harassment are  made.  There is no repercussion for any one laying a false claim in court and there are no repercussions for lawyers who facilitate this action.

Police

The IPCA takes recommendation from the police,  when the police  officers investigate  and the IPCA  accepts the recommendation then there is  no  independence. For true accountability there needs to be independence .

SPCA /RNZSPCA

These private law enforcers  can take action based on the inspectors opinion, there is not even a register for inspectors  and they have wide powers . People can be prosecuted  because they did not take their animal to the vet , something  which they may have avoided  due to cost.

Government /Councils,

OIA and LGOIMA  information is not freely available  and when maters of corruption are brought to the attention of a government department the first reaction appears to be to cover up  rather than to investigate  it.

Many are  covering their backs, there is no  independence in  the supply of information . I can show you documents supplied under OIA where by everything was blanked out except one line.  Had I  seen the entire document   instead of the heavily edited one it would have prevented the perjury  which occurred in my court case.

Prohibitive pricing is often enforced on the applicant. As our watchdogs are so useless at  looking  for corruption the cost of the time effort and  obtaining the information falls on those who  have an interest in seeing he corruption exposed.  This  further prevents accountability and reduces transparency .

I thank you for the opportunity    to   have made these submissions, the people   who use the justice system but are not   part of it are the best to comment.

My experience is practical and through my own persona experience as a prosecutor I believe have a unique insight.

I will be happy to make submissions in person.

Grace Haden

Director