55. From the notes of the interview the following matters emerge:- i. the alleged WhatsApp messages were allegedly seen by the reporter. ii. no copy of the alleged WhatsApp messages has been produced and the reporter did not obtain a copy of it. iii. that the logical inference must be that the reporter was relying upon her recollection of the content of the alleged WhatsApp message (s). iv. that the purported WhatsApp message from the CJ to the PM allegedly concerned Dylan Huggins and Carol Huggins. The informed observer would be aware of the fact that Romero has pleaded guilty to defrauding persons including the persons allegedly referred to in the alleged WhatsApp messages between the CJ and the PM. He/She, being intelligent and fair minded would probably wonder why would the CJ be communicating privately with a PM, possibly about provision of HDC housing, for persons whom, (the CJ having reported Romero to the police), were clearly and indisputably, in the CJ’s perception, victims of Romero’s fraud.25 He would remember that that fraud involved representing that Romero could obtain fast tracking of HDC housing because of pretended facilitation through contact with the CJ. However, even if such an observer might arguably have had lingering doubts about the authenticity of the reported, though unproduced, WhatsApp communications between the CJ and the PM, he would be aware that, subsequent to the interview with the reporter on December 21st 2017, further material became available. Response to pre action protocol letter 56. That material was: a. Letter on behalf of the CJ referred to above in response to the letter from Mr. G. Ramdeen which denied the allegation of lobbying. (See paragraph 57 of the Ramdeen letter) 25 (See statement of Huggins to the police – see record of appeal page 718 32

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