Carol who were the victims of Romero’s representations and also the subject of the alleged WhatsApp messages between the CJ and the PM (on the material in this application) had not in fact received HDC housing as at 21st December 201712. Nor were they even on the list of persons recommended. A fair minded and informed observer in this country would be likely to pay regard to the fact that Romero pleaded guilty to fraud. Such observer would therefore be unlikely in those circumstances to leap to the conclusion that Romero could have been facilitated in this by a CJ, far less one who had reported him to the police when he became aware of it13. Given all of these circumstances now known to him, a fair-minded and informed observer in this country would, like the LATT committee recognise the unlikelihood of a Chief Justice of this country being involved in this fraud. He would accordingly be at least skeptical concerning any allegations of following up in relation to Dylan and Carol Huggins. Lobbying/follow up with HDC 38. The reasonable observer would be aware from the LATT report, now that it has been filed in the judicial review proceedings, that there are also allegations of the CJ’s following up of those recommendations via i. telephone and ii. via an alleged contact on his behalf with an HDC manager. Allegations of undated follow ups WhatsApp messages from the CJ to a senior HDC manager 39. The report of the Committee of the Council of LATT referred to material which it unearthed relating to the HDC recommendations14. It refers for example to an interview with a reporter who “claims to have seen WhatsApp messages from the CJ to a senior HDC manager making the recommendations 12 See Record of Appeal at page 462 See Record of Appeal page 292 paragraph 24 of Executive Summary of final report of committee of LATT. 14 At paragraph 57 of that report at page 669 of the record of appeal 13 21

Select target paragraph3